Someone slid me a draft memo from Vince Clause of Freese and Nichols to the Kinney County Groundwater Conservation District concerning desired future conditions. In case you hadn’t heard, Freese and Nichols is the District’s new hydrogeologic consultant. The [draft] memo starts off hum-drummy enough. We get a review of “how we got here” with desired future conditions and whatnot, drift over into some statistics, lean in for a quick, juicy peck of conditional probability, and then, suddenly, like a plot twist straight out of “Stranger Things,” we get a recommendation to “Consider the Edwards-Trinity (Plateau) Aquifer in Kinney County as Non-Relevant for Joint Planning in [Groundwater Management Area] 7.”
Talk about a demogorgon from the upside down!!! Declaring the Edwards-Trinity (Plateau) Aquifer not relevant would mean that there would not be a desired future condition for the aquifer in Kinney County.
There are technical and policy issues with this recommendation. On the technical side, Clause argues that “…Las Moras Spring flow is more sensitive to climate variability than to changes in groundwater pumping…” therefore “[t]here is insufficient evidence that policy-level changes in pumping are likely to generate a meaningful change in the [desired future condition].” By that logic, we shouldn’t try to manage flows in the entirety of the Edwards Aquifer (which feeds San Marcos, Comal, Barton, Salado, and Jacob’s Well springs) because those systems are also more sensitive to climate variability than to changes in groundwater pumping.
To try and (roughly) put things into perspective, Las Moras Springs flows at about 24 cubic feet per second while San Felipe Springs flows at about 148 cubic feet per second for a total of about 172 cubic feet per second. Assuming that Las Moras Springs is about 73 percent of the total springflow from Las Moras, Pinto, and Mud springs (from Bennett and Sayre’s observations), let’s add another 9 cubic feet per second to total to about 181 cubic feet per second for the entire flow system.
Pumping of about 10,000 acre-feet per year (the recent max) amounts to about 14 cubic feet per second. That’s about 42 percent of spring discharge in Kinney County and about 8 percent of the total spring discharge from the system. The current modeled available groundwater and permitted amount are about 70,000 acre-feet per year, which amounts to potential pumping of 97 cubic feet per second, more than twice the spring discharge in Kinney County and about half of the (presumed) total discharge from the system.
How is this insufficient evidence that policy-level changes in pumping are not likely to generate a meaningful change in the desired future condition? Furthermore, nothing says that the district has to keep the existing desired future condition.
On the policy side, the intent of the Texas Administrative Code for declaring an aquifer or part of an aquifer in a groundwater management area not relevant was to allow groundwater conservation districts in groundwater management areas to not have to assign desired future conditions for aquifers that no one or very few used, generally the slivers of aquifers that sometimes peek into a groundwater management area. I was at the Texas Water Development Board when the agency wrote and implemented the first version of these rules (see bottom of this post for the current rules). I recommended to districts then (and still do now) that if an aquifer is relevant enough for a district to permit use from, it’s a relevant aquifer.
Freese and Nichols states that their recommendation is “…grounded in (1) a strong correlation climate-driven variability and Las Moras Spring flow, and (2) the relatively small and localized role that Edwards-Trinity (Plateau) groundwater in Kinney County plays in the broader regional water supply planning.” I discussed the first bit above. The second bit is irrelevant as to whether or not an aquifer is relevant.
One of the reasons that the desired future conditions process was put into place was to require districts to have real management goals for their aquifers. There’s not a requirement to have a large role in regional water supply planning. Furthermore, doesn’t Kinney County pop up in discussions as a source for regional supply to other parts of the state? It certainly has in the past (and will probably appear more in the future). In addition, what happens in Kinney County affects what happens with Del Rio’s water supply from San Felipe Springs and wells in the aquifer. Management of groundwater to the north of Kinney County affects flows in Kinney County and, to a lesser degree, pumping in Kinney County could affect those counties.
One item to note is that the Texas Water Development Board rules say that districts can propose declaring an aquifer or part of an aquifer as not relevant. This infers agency approval. My guess is that this loophole would be too loopy for Board staff to approve it.
To be fair to Clause, he also included an alternate recommendation to “Replace the Existing [Groundwater Availability Modeling] Framework with a Statistical Analysis that Aligns with the Existing [Desired Future Condition].” Since everyone seems to agree that the models are deeply flawed, I appreciate what Clause is trying to do here, namely, use real-world information to define the desired future condition. Again, there’s nothing magical about the current desired future condition, so a different one could be chosen from his graph or different information could be used as well. Regardless, whatever is used, hopefully there’s a legit model available for next time.
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The full set of rules on this from the Texas Administrative Code, Title 31:
(c) The district representatives in a groundwater management area may, as part of the process for adopting and submitting desired future conditions, propose classification of a relevant aquifer or portions of a relevant aquifer as non-relevant if the districts determine that aquifer characteristics, projected groundwater demands, and current groundwater uses do not warrant adoption of a desired future condition. Non-relevant aquifers do not require a desired future condition. The districts must submit the following documentation for non-relevant aquifers to the agency as part of the desired future condition package:
(1) A description, location, and/or map of the aquifer or portion of the aquifer;
(2) A summary of aquifer characteristics, projected groundwater demands, and current groundwater uses, including the total estimated recoverable storage as provided by the executive administrator, that support the conclusion that desired future conditions in adjacent or hydraulically connected relevant aquifer(s) will not be affected; and
(3) An explanation of why the aquifer or portion of the aquifer is non-relevant for joint planning purposes.
so secret, occult, and concealed 