Important NEW! Water Alerts (updated June 19, 2021) ~~Go here to our NEWS blog and here at Environmental Stewardship for continuing updates on all scheduled hearings on the proposed DFC and helpful info for submitting comments.
Good News! WaterDefenders will sponsor an evening of "fun and water games" at the Paige Roadhouse, 147 Old Hwy 20 E, Paige, TX 78659, on July 18, 4-8 p.m. ~~ stay tuned for details, but please volunteer to help, we have things you can do! "Contact Us" below. Go here for details.
Water Defenders Coalition
Sustainable Water for Texas
Uniting Land, Water and Community
A coalition of organizations that bring together the strengths of land, water, and community to advocate for a sustainable future by protecting the life force that unites us all — WATER!
Please reach out and volunteer to help us for the WaterDefenders July 18 event,
and encourage a friend to help us!
As always, we invite you to contribute to our cause by volunteering and/or making a donation to Environmental Stewardshiphereor SAWDFhere.
Please consider making a tax-deductible donation today!
The mission of the Simsboro Aquifer Water Defense Fund (SAWDF) is to take action to protect and conserve the Carrizo-Wilcox Aquifer in central Texas, as well as the rivers, streams, and springs that are nurtured by it, and to defend the rights of those who live over the aquifer and who seek to leave a legacy of sustainable water resources for future Texans.
SAWDF brings landowners together to advocate for the sustainable management of the groundwater they own beneath their soil ~~they look to their groundwater conservation districts for this management, as a part of groundwater districts' mission to protect local water supply.
Environmental Stewardship (ES) works to protect and preserve the Texas Colorado River, associated aquifers, and the bays and estuaries of the Texas
Gulf Coast by combining its first-hand knowledge of the waterway with an unwavering commitment to the rights of the community, to the ecological health of waterways and aquifers, and to the rule of law.
Environmental Stewardship is a Waterkeeper Affiliate of the Waterkeeper Alliance. ES brings together the sciences of surface water, groundwater, and ecology to advocate for the sustainable co-management of our surface and groundwater that, together, provide the water for our life-supporting ecosystem.
Both coalition members are Texas nonprofit corporations and qualified 501c3 organizations.
The Water Defenders' current campaign:
Groundwater Management Area 12 (GMA-12) has proposed Desired Future Conditions that unreasonably impact you, your land, your property rights, your community, and your environment.
The Water Defenders ask you to ask every groundwater district in GMA-12 to reject the proposed DFC and instead adoptDFCs that achieve the required balance between the conservation and protection of our aquifers, versus the development (pumping) of our aquifers.
Two-thirds of the five districts --- three districts --- must vote in order to reject the proposed DFCs to keep them from becoming final DFCs for the next five years. If districts "kick the can" and say they can always "fix" them five years from now, don't count on that! That has not been the track record in prior 5-year periods -- drawdowns have become
worse, not better.
GMA-12 Member Districts are pictured above and include:
Brazos Valley Groundwater Conservation District
(Brazos and Robertson counties; brazos )
Post Oak Savannah Groundwater Conservation District
(Milam and Burleson counties)
Lost Pines Groundwater Conservation District
(Lee and Bastrop counties)
Fayette County Groundwater Conservation District
Mid-East Groundwater Conservation District
(Freestone, Leon, and Madison counties)
These five districts are in the process of setting the "desired future conditions" (DFCs) -- defined as "how much drawdown in our aquifers we will tolerate over the next fifty years", in the ten counties over which they have regulatory authority.
GMA-12 districts set their DFCs every five years, in each aquifer, and in each formation within the aquifers underlying their counties. For example, separate DFCs are set for each formation of the Carrizo-Wilcox Aquifer, including the Carrizo, Calvert Bluff, Simsboro, and Hooper formations.
Go here to see a summary of the DFC process, and how we will be affected by it from SAWDF's point of view.
Go here to read Environmental Stewardship's description of the process.
The districts of GMA-12 have now proposed what they intend to adopt as the DFCs that will be in effect from 2022 until 2027 when the DFCs will be updated again. All districts must act to adopt final DFCs no later than January 5, 2022.
The proposed DFCs will give big pumpers 100% protection, and 0% protection to our aquifers, our domestic and livestock wells, and to our rivers, streams, and springs.
If adopted, here's how SAWDF represents what GMA-12 has proposed:
And here is a handy summary of the water policy at stake and how the alternative DFC's SAWDF and ES, along with the League of Independent Voters of Texas (LIV), another dedicated advocate for our aquifers, have proposed differ from GMA-12's proposed DFCs:
Get more information on these important management and policy issues here.
Check our Water Alerts at the top of this page for the most current hearing information.
***The RESOURCES section below has a great example of a written public comment.***
Check RESOURCES for links to other information, too.
The Water Defenders Coalition is asking you to get informed, get involved, and donate to our two organizations to enable us to continue asking all GMA-12 districts to reject these devastating drawdowns.
Please bookmark waterdefenders.org to come back to this page for SAWDFand ES updates on GMA-12/Desired Future Conditions.
We also thank you for going to the DONATE page on this website to donate to SAWDF, and to the CONTACT page to talk to us and sign up for our NEWS blog updates.
And we thank you for going to ES'sDONATE page, where you can donate and also subscribe for updates.
And remember that the League of Independent Voters of Texas, a Texas nonprofit and 501c4 organization, always helps us with outreach --- they make calls for us and include us in their newsletters, for example.
Water Defenders will update this page throughout the public comment period, which ends no earlier than July 23, 2021 ~~ we believe it may be extended but no assurances, so please, work on your comments and check back on this page for hearing information.
Water Defender Resources
Here are some links to SAWDF and ES Resources that will be updated during the public comment period.
Environmental Stewardship and SAWDF materials
GMA-12 Desired Future Conditions.
June 7, 2021
Our Reasons to Reject the Proposed DFCs
Both Environmental Stewardship and SAWDF laid out our reasons for asking the Board to reject the Proposed DFCs and remand them back to GMA-12 for revision at the Fayette County GCD Board meeting on Monday, June 7th. You can review what was presented by clicking on the presentation information below.
Public comment on the proposed DFCs ~~ we love this example from a supporter in Bastrop County:
May 25, 2021
Subject: Proposed DFCs Date: Tuesday, May 25, 2021 10:57:05 AM Dear Brazos Valley Groundwater Conservation District Board President,
Thank you for volunteering for this critical position as stewards of our ground water and river ecosystem health. It is so important to the health of the environment and economic viability of our communities.
I appreciate you are in a very stressful position with threats of litigation, and companies wanting to market the valuable water resources. Your challenges continue but this is your opportunity.
You must choose between what is good enough to get by and what is right to do. The proposed DFCs will ultimately deplete ground water and flowing streams. Please reject the proposed [DFCs and] re-adopt the current DFC’s until such time dependable sustainable solutions for aquifer management are agreed upon. Please find the courage to adopt DFC’s that will protect, long term, the environment and current landowners’ water access and install monitoring wells to verify the effectiveness.
SAWDF's comments to Brazos Valley Groundwater Conservation District
Michele Gangnes, June 10, 2021 (with thanks to Andy Wier, SAWDF Director)
Good afternoon, Mr. Vice President and Board Members,
My name is Michele Gangnes. I am a landowner in Lee County, an attorney, and a founding board member of the Simsboro Aquifer Water Defense Fund.
Steve Box from Environmental Stewardship covered points relevant to my comments and I will try to avoid redundancy, but some points need emphasis.
ES and SAWDF have formed a coalition under the name WaterDefenders.org, as a means of public outreach and education. For SAWDF, that also includes public advocacy.
I'm speaking to you today on behalf of SAWDF as well as on behalf of exempt well owners and landowners in Lee County, which is in the Lost Pines Groundwater Conservation District, and which is also a member of GMA-12.
Their request to you is to REJECT the proposed DFCs for the next five years, that the general managers of the five GMA-12 districts arbitrarily if not capriciously decided they had no choice but to impose.
There is clearly an emotional side to landowners’ reaction to the DFCs GMA-12 proposed, which you will of course recognize as well– there is a lot at stake for them. But the fact of the matter is, our assessment of the proposed DFCs as causing unreasonable impacts is absolutely correct, so I don’t believe you can dismiss us out of hand. You have some more work to do.
From the landowner perspective it would be wrong to ratify these proposed DFCs at the district level --- the proposed DFCs literally almost double the allowable drawdowns, without giving any defensible consideration to the legal requirements for setting any DFCs.
What does that mean? I think if you read Mr. Allmon’s letter for ES you will know from a legal standpoint and I don’t want to be redundant.
But what it means for landowners is that the districts in GMA-12 propose to virtually guarantee big pumpers --- pumpers with non-exempt permits -- will have carte blanche ---- no impediments at all ---to drying up hundreds of exempt domestic and livestock wells with their pumping, not to mention no impediment at all to damaging our aquifers, our communities and our rivers, springs and streams.
Why that is wrong is NOT UP TO THE PUBLIC to prove to you --- it is your duty under Texas law to adopt DFCs that will not have these unreasonable impacts and that will achieve a balance between conservation and protection of our aquifers, and development of our aquifers.
You still have time to do what the law requires you to do.
The proposed DFCs for GMA-12 protect only permit holders --- the big pumpers ---- by allowing drawdowns that allow them to pump to the limits of their permits, while local domestic and livestock wells are left high and dry --- the proposed DFCs unreasonably impact our aquifers, and they unreasonably impact exempt wells, whether wells are mitigated by a district or not; andthey unreasonably impact private property rights of landowners by diminishing a capital asset --- the water under them ---, and their agribusinesses.
You must do the work to balance the DFCs. I will just point out here that threats of litigation from Vista Ridge are not a consideration that you may lawfully use as an excuse for these DFCs.
If you require data to understand that you have not done your duty, it is available, in Lee County, because my organization SAWDF brought it to the attention of GMA-12 earlier this year and things have only gotten worse since you ignored our comments. According to the Lost Pines District’s recent projections, revealed at a public meeting in May, up to 150 Lee County Carrizo wells will be out of water at some point due to Vista Ridge’s maximum pumping in the Carrizo Aquifer.
It is also available in Burleson County, where Vista Ridge is based and the Post Oak district’s efforts to address unreasonable impacts of your proposed DFCs also fell on deaf ears at GMA-12.. As of May, Post Oak reported having mitigated 44 wells, also due to Vista Ridge’s pumping.
I will point out that dry wells in Burleson and dry wells in Lee County are occurring under CURRENT DFCs --- DFCs that Vista Ridge is not violating --- which means there’s already something wrong with this picture and now you propose to double the allowable drawdowns for Vista Ridge, and compromise even more exempt wells.
I don’t profess to have data to competently speak about Brazos Valley GCD’s pumping impacts and the DFCs. But I have some questions I wish your constituents would ask and that you would answer as directly, simply and honestly as possible:
Just how do YOU protect landowner rights to groundwater?
How do YOU know that the Carrizo-Wilcox, Sparta and Queen City aquifers can sustain the permitted pumping that you are going to allow?
What research has BVGCD or GMA-12 done to answer that question of sustainability? That is, how do you know you are not actually managing the depletion of a precious natural resource rather than figuring out, any part of the conservation and protection side of the equation, and documenting that work?
How many exempt wells will the proposed DFCs impact in this district?
How many exempt wells do the DFCs need to impact before BVGCD will modify the proposed DFCs; 50%, 75%, 100%.?
If it is more than 50%, how is that balancing production with conservation and private property rights to groundwater?
If your constituents don’t know what’s at stake, that blame is not entirely on them. There is an education and outreach component of what groundwater districts do, in our opinion. If you were to address the questions I just asked in plain English, not just with a computer run that suddenly turns into a set of DFCs without any basis for that to happen or any good explanation of why you thought this approach is adequate, I think you’d get their attention pretty darn quickly.
We will submit written comments to the district after we hear the proceedings today – I hope you give the public access to a recording of today’s hearing prior to the end of the comment period.
Thank you for letting me speak. Please vote against adoption of the proposed DFCs.
ES's presentation to Brazos Valley Groundwater Conservation District, hearing on proposed DFCs
Steve Box, ES Executive Director and Board President
Proposed DFCs Environmental Stewardship’s Concerns and Requests Presented to Brazos Valley Groundwater Conservation District Board of Directors June 10, 2021, Virtual Environmental-Stewardship.org:
We are asking the Board to manage our aquifers responsibly by rejecting the Proposed DFCs in favor of DFCs based on:
sustainable management of the aquifers,
protection of exempt landowner domestic and livestock wells, and
maintaining the resilience of the Colorado River to drought
Go here to see ES's short slideshow for this presentation.