Amazing - Joyce's statement is a passionate, well-documented rebuke of the
development plan and our regulatory failings. While it's a great read, I am
saddened to the core at the same time. Texans who care already know how
these hearings barely pay lip service to environmental concerns (probably
because if our continuing one-party rule by politicians who are *always* in
developers' pockets). The Edwards alliance states that this permit is
expected to be approved.
That alone is shocking to me, along with how aquifer impact isn't a winning
argument in this case. If we were in a more eco-savvy state, developments
might be forced to build with less density, composting toilets,
xeriscaping, etc. - or not build at all.
This is a big deal for cavers, with huge implications for Texas' longest
cave.
It would be interesting to know where this money is coming from:
out-of-state carpetbaggers taking advantage of our lax regs? Whoever they
are, I'll be donating to the fight against them.

On Fri, Aug 23, 2019, 5:01 PM Bill Steele <cwilliamste...@gmail.com> wrote:

> Tuesday evening I attended the Texas Commission on Water Quality (TCEQ)
> public hearing in Bulverde regarding a developer's application to build
> four houses per acre, many hundreds of new homes, in the Honey Creek
> drainage basin and be able to dump 500,000 of treated sewage into Honey
> Creek, effluent which will at times of high water make its way into the
> pristine environment of Texas' longest cave. Comments were made by several
> Texas cavers, including Joe Ransau, Kurt Menking, Linda Palit, Sandy
> Mosier, Allan Cobb, Andy Glusenkamp, and me. To me, the most moving comment
> made was that by the cave's owner, and a good friend to our caving
> community, Joyce Moore. Here it is in its entirety.
>
> Bill Steele   speleoste...@aol.com
>
>
> Honey Creek Discharge Permit Comments
>
> from Honey Creek Spring Ranch
>
> by Joyce Moore
>
>
>
> My name is Joyce Gass Moore. I am a 5th-generation Texas, and a 5th-generation
> co-owner of Honey Creek Spring Ranch.  Our ranch is located in far
> western Comal County, and downstream of a proposed Silesia properties
> development known as Honey Creek Ranch. And so I speak to you today not
> only as an affected landowner, but as a very concerned citizen.
>
> When my son and nephew take over the management of Honey Creek Spring
> Ranch, it will represent 6 generations of continuous family ownership and a
> legacy of stewardship dating back to 1846 when my ancestors first set foot
> on Texas soil. As German-immigrants, my family was one of only a few who
> homesteaded western Comal County—3 of whom (all neighbors) applied for land
> deeds on the same day in 1871. Because the waters of Honey Creek were so
> important to the settlement of Comal County, our entire ranch was
> recognized as a State Historic Site by the Texas Historical Commission; and
> in 2018 was Listed in the National Register of Historic Places by the U.S.
> Department of the Interior National Park Service.
>
> My ancestors knew hardship and fought to protect their land and Honey
> Creek.  They carved the ranch out of cedar and live oak covered hills,
> suffered thru drought, disease, and bank failures, and sacrificed
> everything they had to nurture, protect, and improve the land they loved.
> And now—150 years later, once again we are threatened by those who seek to
> cash in on the land in order to capitalize on its value. Despite what they
> may tell you, these folks do not hold the best interest of the land or its
> natural resources at heart. This is very evident in the description of the
> development being planned. My ancestors would be so deeply disappointed in
> what western Comal County has become, and in the landowners, who are
> allowing this to happen.
>
> The Texas Hill Country is known for its aesthetic beauty—people have been
> drawn to this area for generations—drawn to its crystal-clear streams and
> scenic vistas. Unfortunately, all this beauty rests atop a particularly
> fragile ecosystem—a calcareous limestone substrate known as *karst*.
> Although not a geologist or a hydrologist, I do understand how infiltration
> works—how water moves thru a karst system. Surface recharge features
> (cracks, fissures, pits, sumps) are all designed to move water quickly into
> subterranean acquifers (the Edwards, the Trinity, and Cow Creek are all
> examples). These aquifers provide the drinking water for millions of
> people. Springs flowing from these same aquifers provide critical habitat
> to a unique group of plant and animal species—many of which are found only
> in the most protected streams and riparian areas of Central Texas. Until
> this proposed development and wastewater discharge became a possibility,
> Honey Creek was one of the most protected aquatic systems in the Hill
> Country.
>
> The number of these pristine riparian systems are shrinking rapidly—most
> of it due to rampant and unregulated development over the recharge area,
> and the failure of an already-broken system intended to regulate the
> disposal of wastewater. I think it very ironic that the name chosen for the
> area by my ancestors (Honey Creek) is the same name chosen by newcomers to
> become their sales pitch.  It is the same aquatic system that will be
> destroyed if this Honey Creek Ranch permit is approved.
>
> Treated effluent discharged into a tributary of Honey Creek will
> absolutely, negatively impact water quality--primarily through significant
> increases of Nitrogen and Phosphate levels. These nutrients will encourage
> the growth of algae and will degrade the recreational and aesthetic value
> of Honey Creek. Decaying mats of algae will impact Dissolved Oxygen levels
> and will almost certainly have a devastating effect on aquatic life.  The
> introduction of Pharmaceuticals and Personal Care Products contained in the
> effluent will eventually enter Honey Creek and then will become a dramatic
> example of how a once un-impaired aquatic system with exceptional levels of
> aquatic life use, was degraded due to wastewater and high-density
> residential development. It will become yet another Poster Child for Poor
> Management—all in the Name of Progress!
>
> And if 500,000 gallons of treated wastewater discharge were not a large
> enough problem, the non-point source pollution reaching the creek during
> storm events and leaching into the aquifer will be an even greater problem.
> Herbicides, pesticides, and fertilizers used on turfgrass lawns, and
> oil/fluids leaking from thousands of additional cars will wreak havoc on
> our groundwater.  Because of the immense footprint of this development,
> open ground will be significantly diminished; stormwater runoff will
> increase from the many impervious surfaces (roads, driveways, and
> rooftops). As a result, downstream flooding of Honey Creek will increase in
> both rate and severity, greatly increasing soil erosion along the
> streambed, and resulting in significantly diminished water quality. The
> pristine Honey Creek as I know it, as my family knows it, will be but a
> fleeting memory. This includes not only the stream itself, but also a 20+
> mile network of subterranean, water-filled karst passage known as Honey
> Creek Cave. The cave and spring system form yet another unique ecosystem
> which has been studied and documented on our ranch for over 40 years by
> trained experts (many of whom are in this room tonight). It is inhabited by
> unique aquatic species, several of which are state threatened, and at least
> one which may possibly receive federal protection, and all of which are
> considered Species of Greatest Conservation Need. Without question, ALL of
> these species (which require clean, clear water to survive) will be
> negatively impacted, and most likely extirpated. Who will monitor the
> effluent discharge with regard to its environmental impacts? And when
> violations occur, will the violators be held accountable? The irony is that
> *when* the sewage treatment plant fails (because ALL eventually fail),
> the damage suffered by the ecosystem will already have taken its toll.
>
> Trespass will now also become a major problem to those of us who live
> downstream. Ambitious adventurers will trek illegally from their suburban
> lots seeking open space. They will venture onto adjoining properties such
> as the state-owned Honey Creek State Natural Area and beyond. What
> assurances do neighboring landowners have that measures will be taken to
> prevent trespass and vandalism, and who will pay for it when it happens?
> Who will be held accountable?
>
> As a downstream property owner; as a directly-impacted landowner with
> standing, I respectfully request to file a contested case hearing in this
> matter. And I would ask the members of TCEQ (those present here tonight,
> and those who will decide the eventual fate of Honey Creek), to explain how
> such a permit can even be considered for approval? Unfortunately, God is
> not creating any more Honey Creek’s, and we are destroying these special
> places at a rapid pace. I urge TCEQ to do the right thing instead of
> rubber-stamping this project as your agency has a history of doing. And if
> it is approved, I hope that each of you can live with your decision, as I
> and Honey Creek will be forced to do.
>
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