saws bed and banks application -...
TRANSCRIPT
Gregg Eckhardt Senior Analyst, Production and Treatment Operations
AWWA/WEAT Summer Seminar
SAWS Bed and Banks Application
July 25, 2014
July 25, 2014
SAWS Bed and Banks Permit Application Page 2
July 25, 2014
SAWS Bed and Banks Permit Application Page 3
• SAWS recycled water system
• Provision of water to CPS Energy
• Downstream flows
Resource Management For:
July 25, 2014
SAWS Bed and Banks Permit Application Page 4
0
50
100
150
200
250
300
350
Jan-91 Jan-93 Jan-95 Jan-97 Jan-99 Jan-01 Jan-03 Jan-05 Jan-07 Jan-09 Jan-11 Jan-13
million gallons per day
WRC Daily Production 1991 to 2013
Total WRC Production
July 25, 2014
SAWS Bed and Banks Permit Application Page 5
0
25
50
75
100
125
150
175
200
225
250
0
20,000
40,000
60,000
80,000
100,000
120,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Typical WRC Diurnal Discharge Curve
GPM CFS
Hour
July 25, 2014
SAWS Bed and Banks Permit Application Page 6
SAWS Recycled
Water System
July 25, 2014
SAWS Bed and Banks Permit Application Page 7
Uses of Recycled Water
landscaping golf courses
cooling towers industrial processes
July 25, 2014
SAWS Bed and Banks Permit Application Page 8
CPS Energy
July 25, 2014
SAWS Bed and Banks Permit Application Page 9
Downstream Flows • SAWS recycled water effluents are a critical contribution to the
San Antonio River during drought periods • October 1: Board of Trustees provided direction on SAWS
position toward uses of current and future discharged effluent
Conquista Crossing on the San Antonio River near Falls City
July 25, 2014
SAWS Bed and Banks Permit Application Page 10
Bed and Banks Basics • “Bed and Banks” authorization is permission to use State’s watercourses to
transport privately owned groundwater so that it may be reused downstream
• Without an authorization, discharges become the property of the State
July 25, 2014
SAWS Bed and Banks Permit Application Page 11
1980s Council Direction on Discharges
• 1988 Regional Water Resources Plan recommended a reuse program: – “must be managed to maintain a
minimum flow in the San Antonio River of 55,000 acre-feet per year as measured at the Falls City gauge.”
• Plan was adopted by City Council ordinance 67605
July 25, 2014
SAWS Bed and Banks Permit Application Page 12
1980s Council Direction on Discharges
• City Council ordinance 67605 was the basis for recycled water system design capacity:
CPS Energy
Downstream estimated needs
Recycled water system
40,000 af/yr
55,000 af/yr
35,000 af/yr
Original Recycled Water Program Balance
130,000 af/yr
• However there are currently no legal protections to ensure water remains instream
July 25, 2014
SAWS Bed and Banks Permit Application Page 13
Firm Yield Effluent Allocation
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000
acre-feet
electrical generation - 50,000 af/yr
environmental flows - 50,000 af/yr
consumptive reuse - 25,000 af/yr
July 25, 2014
SAWS Bed and Banks Permit Application Page 14
Effluent Discharge Routes
Guadalupe River at SH 35 near Tivoli
July 25, 2014
SAWS Bed and Banks Permit Application Page 15
E-Flows Overview
Program
Texas Instream Flow Program
(TIFP)
Legislation
Senate Bill 2 (2001)
Key Features
Environmental Flows Program
(E-Flows)
Senate Bill 3 (2007)
• Agencies determine flows necessary for a riverine "sound ecological environment“
• Recommendations based on field analysis • Stakeholder input is considered
• All watersheds to determine E-Flow needs for
each major basin and bay system • Science-based flow recommendations • SB 2 flow science to be incorporated into SB 3
process • Stakeholders balance environmental and
human needs
• SAWS has actively participated in two legislatively mandated programs to address flows in San Antonio and Guadalupe River basins:
July 25, 2014
SAWS Bed and Banks Permit Application Page 16
USGS
Gages
Info on
Hydrographic
Methods
Other Hydrographic
Software
HEFR
Selected
Gages
Annual/Median
Flow Patterns
Matrix Presentation
Seasons
Calendar
Seasons
Monthly Custom
Seasons
MBFIT
Pre
Development
Post
Development
Entire Period
of Record
Period of
Record Overbank and High
Pulse Flows
Flow
Data
IHA
Subsistence
Flows
Water
Quality vs.
Flow Data
Base Flow
Designations
Summer
Median 25/50/75
Divisions
Custom
Custom
7Q2
Select Estuary
Flow Matrix
Methodology
State
Methodology
Fluvial
HEFR
Matrices
USACOE
Information
Seasonal
Hydraulic
Condition
Gage Flow
Data WAM Palmer Index
Wet/Dry
25/75
Percentiles
Frequency
Based Pre
Development
Frequency
Based Post
Development
Original Entire
Period of Record
Original Pre
Development
Original Post
Development
Overbank &
High Flow
Pulse Data
Biota of Rivers
and Estuary
Salinity
Suitability
Analysis
Selected
Species
Biology
Other
Relevant
Studies
Temperature
and DO vs.
Flow
303(d) List
Water Quality
Frequency
Based POR
Matrices
Modified by
Overlays
BBEST Flow
Regime
BBEST Flow
Regime
Application
Historical
Attainment
Frequencies
Geomorphology
and Sediment
Transport
Data Decision Option
E-Flows Science Team Decision Diagram
July 25, 2014
SAWS Bed and Banks Permit Application Page 17
• Subsistence Flows
• Base Flows
• Pulse Flows
• Overbank Flows
Components of a Flow Regime
San Antonio Bay Guadalupe River San Antonio River
July 25, 2014
SAWS Bed and Banks Permit Application Page 18
The Aransas Project v. Shaw, et al
“Although SB 3 does establish a comprehensive framework for the State of Texas to determine the amount of freshwater inflows that need to remain instream…it makes no attempt to ensure that such recommended amounts remain.”
- Honorable Judge Janis Jack, United States District Court for the Southern District of Texas, Corpus Christi Division
National Geographic Magazine, 1937
July 25, 2014
SAWS Bed and Banks Permit Application Page 19
SB 3 Stakeholder Work Plan
• Outlines voluntary strategies to meet instream flow standards
July 25, 2014
SAWS Bed and Banks Permit Application Page 20
Objectives
• Support SB 3 stakeholder strategies to ensure healthy rivers, bays, and estuaries
• Add legal certainty to policy guidance
• Ensure San Antonio retains ownership and control of all current and future groundwater based discharges
July 25, 2014
SAWS Bed and Banks Permit Application Page 21
Summary and Other Considerations
• 50,000 af/yr used solely for instream flow purposes
• Remainder for any legal purpose (in the future)
• Carriage losses
• Protection of water rights issued based on use or availability of effluent
• Development of "Accounting Plan"
July 25, 2014
SAWS Bed and Banks Permit Application Page 22
Latest Develoments
• In Ex Parte lawsuit, GBRA asserts – EAA Act prohibits indirect reuse of Edwards water
– EAA Act prohibits reuse outside of EAA boundaries
– GBRA “must have the right to divert discharges of Edwards-derived wastewater effluent as part of the state-owned run-of-river flow of the Guadalupe river..."
• TAP ruling
July 25, 2014
SAWS Bed and Banks Permit Application Page 23
TCEQ Request for Information
"Staff believes that TCEQ does not have authority under statute to issue a
permit based on this application."
July 25, 2014
SAWS Bed and Banks Permit Application Page 24
TCEQ Request for Information
"...the application does not fall under [the
reuse] statute because this statute requires
that a permitee divert and reuse groundwater based return flows..."
Gregg Eckhardt Senior Analyst, Production and Treatment Operations
AWWA/WEAT Summer Seminar
SAWS Bed and Banks Application
July 25, 2014