LCRA Griffith League Ranch Application (2018)
The Lower Colorado River Authority (LCRA) applied with the Lost Pines Groundwater Conservation District (District) for groundwater operating and transport permits for eight (8) wells, for a total combined maximum annual production of up to 25,000 acre-feet/year on February 21, 2018. The LCRA acquired groundwater rights in the Simsboro and Carrizo-Wilcox aquifers under the approximately 4,847 acre Griffith League Ranch (GLR) property in Bastrop County on January 9, 2015 by Warranty Deed. LCRA requested the permits include a phased approach to increase authorized pumping over time with Phase 1 total combined maximum annual production up to 8,000 acre-feet/year, Phase 2 15,000 acre-feet/year and Phase 3 25,000 acre-feet/y
LCRA claims it has existing firm contractual commitments in excess of 400,000 acre-feet/year for a variety of beneficial uses, including municipal, industrial, recreation, irrigation/agricultural and instream uses. With few exceptions LCRA claims that the contractual commitments generally provide that LCRA may meet its obligations from any source available to LCRA.
The map on the right shows the location of the proposed well-field site in Bastrop County, TX. The well-field is approximately northeast of FM1441 and northwest of HWY 21 going northeast out of Bastrop.
Environmental Stewardship filed its request for a contested case hearing with the Lost Pines Groundwater Conservation District on September 19, 2018. In our request we conclude that “Environmental Stewardship is significantly concerned with the potential impact of the pumping requested by LCRA. George Rice, a hydrogeologist, has been engaged by Environmental Stewardship to examine the impact of LCRA’s proposed pumping. As Mr. Rice’s work shows, the Simsboro is connected to other aquifers in the area, and LCRA’s pumping from the Simsboro will impact the water in those aquifers as well as the Colorado River. LCRA’s proposed pumping is not consistent with the desired future condition (DFC) for the area, and is not consistent with sustainable management of the aquifers in the area.”
Schedule for Public Hearing and Deadline for Registering Objections
The District has schedule a public hearing on the LCRA Griffith League Ranch Application for:
PUBLIC HEARING on LCRA Griffith League Ranch Application
September 26, 2018, 7:00 PM
Bastrop Convention Center
1408 Chestnut Street
Bastrop, TX 78602
Per instructions from the District on the Public Notice:
For more information contact the District by calling 512-360-5088, fax 512-360-5448 or emailing email@example.com
For more information regarding a contested case hearings, please see the District’s website FAQ at lostpineswaeer.org/FAQ.aspx
NOTICE NOTICE NOTICE NOTICE
To OBJECT to the LCRA Application you must submit your notice to the Lost Pines GCD FIVE (5) days before the hearing.
OBJECTIONS TO THE LCRA APPLICATION must be received by Lost Pine GCD by September 21, 2018 at 5:00 PM.
Citizens and especially landowners are encouraged to unite and challenge the
Lost Pines Groundwater Conservation District to address their concerns about the permit’s
impacts on water supply and property rights. The District says it is the “only tool available”
to protect the water supply of Bastrop and Lee Counties!
For more information call 512-333-0252 or firstname.lastname@example.org
(Please be sure to give your phone/email if we need to contact you before the meeting.)
Click here for a copy of the form needed to register your opposition to the LCRA application
For more information or help with the form contact:
Environmental Stewardship will attempt to notify persons who have signed up for our Newsletter
about the date, time and other details regarding the above meetings and dates (see “Sign Up For Our Newsletter” below).
More about the Application:
The maps below show the other commercial, non-exempt well fields near the LCRA Griffith Ranch project (left) and the drawdown in the Simsboro aquifer that is predicted to result from the pumping of 25,000 ac-ft/year over a period of 50 years by the same project (right). (Source: Review of LCRA Permit Application Packet).
Unfortunately the Groundwater Conservation District considers the pumping from each well field on an individual basis and only for the target aquifer (Simsboro) that is being pumped. The District does not consider the impact of the combined pumping from all of the well fields on surface water, the other aquifers that communicate with the target aquifer, nor do they specifically consider the impact of the pumping on shallow exempt domestic wells.
According to the District’s analysis, the model run results indicate that at the end of 40 years of pumping (in 2060), the project-specific drawdown (drawdown due to the proposed LCRA wells only) is as follows:
- approximately 225 to 250 feet at the three Aqua well locations (McDade, Behrend, and Highway 21).
- approximately 250 to 275 feet at the proposed “Recharge” (End Op) well locations.
- approximately 160 to 180 feet at the existing LCRA wells near Lake Bastrop.
In comparison, the combined pumping of the Aqua, Recharge, LCRA, and Vista Ridge pumping — not including the LCRA Griffith Ranch project — are predicted to cause drawdowns in the Simsboro Aquifer of 900 – 1200 feet by 2060. See study below.
Study on the impacts of LCRA’s Griffith League Ranch groundwater pumping on the Carrizo, Calvert Bluff, Simsboro and Hooper Aquifers and the Colorado River.
Environmental Stewardship retained groundwater hydrologist George Rice to use the same GMA-12 Groundwater Availability Model (GMA-12 GAM) used by the Lost Pines Groundwater Conservation District — as required by the State — to evaluate the impact of LCRA’s requested Griffith League Ranch pumping over the 50-year planning period from 2010-2060. Not only the Simsboro Aquifer, but also the Calvert Bluff and Hooper aquifers in the Carrizo-Wilcox Aquifer Group will be impacted by the LCRA’s pumping. It should be noted that the District, in its permitting process, reports the impacts of LCRA’s proposed pumping solely on the Simsboro Aquifer, the formation where the LCRA wells would be located. The report also includes predicted impacts on the Colorado River and its tributaries. The District does not consider either impacts on other Aquifers or impacts on the Colorado River.
In summary, the GMA-12 GAM predicts that drawdowns in aquifers communicating with the Simsboro aquifer where the LCRA pumping alone will occur will be 22 feet by 2060 in the Calvert Bluff and Hooper aquifers at the LCRA well field. Average drawdown in Bastrop and Lee counties in the Calvert Bluff will be 13 ft. Average drawdown for the Hooper is predicted to be 16 feet in Bastrop County and 18 feet in Lee County. Drawdown in the Simsboro is predicted to be 339 feet at the LCRA wellfield, an average of 80 feet across Bastrop County, and an average of 37 feet across Lee County. See Tables 1 and 2.
The GMA-12 GAM predicts that groundwater discharge into the mainstream and tributaries of the Colorado River will be reduced significantly over the 50 year planning period and will cause the river and its tributaries to reverse their current relationship to the aquifers. The river and tributaries currently GAIN water from the aquifers as they flow through Bastrop County. LCRA’s pumping further exacerbates the impacts of baseline pumping that is predicted to possibly cause the river to LOSE water to the aquifers. This reversal will mean that groundwater will not flow into the river, a situation that will be most damaging to the river and the terrestrial systems it supports during drought and extreme drought conditions when the river baseflow is largely groundwater.
Rice concludes that LCRA’s proposed pumping would:
- Reduce hydraulic heads in the Calvert Bluff, Simsboro and Hooper aquifers.
- The reduced heads in the confined portions of these aquifers would cause water levels in wells to decline.
- Reduced heads in the unconfined portion of the aquifers (recharge area) would cause dewatering of portions of the aquifers.
- Reduce groundwater discharge to the Colorado River, thereby reducing the amount of water flowing in the river.
Rice FINAL REPORT: Evaluation of LCRA’s Proposal to Pump 25,000 Acre-Feet per Year from the Simsboro Aquifer.
Drawdown Maps from the Rice Report show that the GMA-12 GAM predicts impacts on the Calvert Bluff and Hooper aquifers as a result of LCRA’s proposed pumping of the Simsboro aquifer.
Though the Lost Pines GCD, LCRA and other water marketers will tell you that pumping groundwater from the Simsboro aquifer will not impact the other aquifers in the Carrizo-Wilcox group of aquifers, the model that is required to be used by the State to predict the availability of groundwater (GAM) predicts that these other aquifers will be impacted. The GAM model uses the best science available (2 documents, 789 pages, 398 Figures, 78 Tables, and 26 Appendices) as the basis of its design and development. Nothing in nature is impermeable, so there’s leakage between the formations. ES’ analysis of GMA-12 water budgets demonstrates and quantifies the predicted communication between the aquifers in the Carrizo-Wilcox Group and between the aquifers and surface waters.
ES’ analysis of GMA-12 Water Budgets used in developing and adopting the desired future conditions (DFC) for the Carrizo-Wilcox Simsboro Aquifer indicates that the most significant contributors of groundwater for pumping of the Simsboro aquifer are from:
1) a reduction in outflows to surface waters, and
2) the flow of groundwater out of other aquifers within the district
Here are the details:
a) Outflows to surface waters: Surface water is the single most significant contributor of water for pumping. Outflows to surface waters are modeled to have decreased by a total of 100,000 ac-ft/yr since 1975 with the greatest declines occurring in Post Oak Savannah, Lost Pines, and Mid-East Texas respectively.
b) Vertical leakage: Vertical leakage from other aquifers into the Simsboro is the second most significant contributor of groundwater for pumping since 1975 (modeled to contribute 83,300 ac-ft/yr) and is the most significant contributor during the DFC period (modeled to contribute 69,800 ac-ft/yr by 2070). Vertical inflow to the Simsboro is most significant in Post Oak Savannah, Brazos Valley, and Lost Pines respectively during the DFC period.
c) Lateral leakage: Lateral flow of groundwater from other districts into the Simsboro in Brazos Valley is significant during the DFC period. Lateral flows out of Lost Pines and Mid-East Texas are the most significant with moderate outflows from Post Oak Savannah.
d) Storage changes: Storage is the least significant contributor of water for pumping since 1975. Storage increased during the calibration period and decreases during the DFC period but is net neutral for the period. It is misleading to state that most of the groundwater pumped is contributed from storage.
The drawdown maps below reflect the best science available at this time. If the District and LCRA believe that these aquifers do not communicate with each other over the years, then they need to provide the science to refute the State approved model. Until the District complies fully with the below statute, it will not have discharged its duty to consider the affects of LCRA’s projected groundwater pumping on existing groundwater and existing permit holders — including registered exempt well owners in the Calvert Bluff and Hooper aquifers.
The Texas Water Code, Section 36.113(d)(2) requires that:
Section 36.113. PERMITS FOR WELLS; PERMIT AMENDMENTS. (a) Except as provided by Section 36.117, a district shall require a permit for the drilling, equipping, operating, or completing of wells or for substantially altering the size of wells or well pumps.
(d) This subsection does not apply to the renewal of an operating permit issued under Section 36.1145. Before granting or denying a permit, or a permit amendment issued in accordance with Section 36.1146, the district shall consider whether:
(2) the proposed use of water unreasonably affects existing groundwater and surface water resources or existing permit holders;
Another recent study predicts that the combination of all permitted and requested pumping of the Simsboro Aquifer will impact other shallower aquifers in the Carrizo-Wilcox Group. THE STUDY DID NOT INCLUDE THIS LCRA GRIFFITH LEAGUE RANCH PROJECT.
The combined pumping in the Simsboro Aquifer is predicted to cause 900 to 1200 feet of drawdown in the Simsboro Aquifer in Burleson and Lee counties by the year 2060 according to groundwater modeling conducted by professional hydrologist George Rice. The combined groundwater pumping within Lost Pines and Post Oak Savannah Groundwater Conservation Districts (GCD) are predicted to impact not only the Simsboro Aquifer, but also the Carrizo, Calvert Bluff and Hooper aquifers extending to points as far away as Gonzoles, Lavaca, Colorado, Austin, Grimes and Walker counties. These aquifers are hydraulically connected throughout the Carrizo-Wilcox Aquifer Group.
Leakage from the Carrizo, Calvert Bluff, and Hooper aquifers
According to the Rice report, the effects of the pumping would not be limited to the Simsboro Aquifer. The pumping would induce leakage from the Carrizo, Calvert Bluff, and Hooper aquifers. This leakage would reduce hydraulic heads in the aquifers. Where the aquifers are confined, the reduction in heads would reduce water levels in wells that draw water from the aquifers. Where the aquifers are unconfined (the shallow outcrop areas where many domestic wells are located), the reduction in heads would dewater portions of the aquifers. The position of these aquifers relative to the Simsboro is shown in figure 1.
Leakage is a common and well-known phenomenon that is discussed in standard hydrology texts. In figure 1, leakage (cross-formational flow) between geologic units is indicated by double-headed arrows. In a 2009 pump-test conducted in Lee County, it was estimated that 22% of the water pumped from the Simsboro was derived from leakage from adjacent aquifers.
Depending on where a Landowner’s property is located in the outcrop, the aquifers beneath the property will be the ones listed below the location. For example, if the property is in the Carrizo outcrop, the aquifers below the property are the Wilcox/Calvert Bluff, Wilcox/Simsboro, and the Wilcox/Hooper; in that order. A landowner owns the groundwater beneath his/her property in ALL of those aquifers.
The maps below show the approximate location of the LCRA Griffith League Ranch Project over the Carrizo, Calvert Bluff, Simsboro, and Hooper Aquifers.
The LCRA Griffith League Ranch Project is likely located in the Carrizo and/or Calvert Bluff aquifer outcrops. Landowners should find the general location of their property and wells on the maps below to be able to estimate the feet of predicted drawdown under their property within the 50 year planning period.
Click on each map to see a larger view of the map.