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Texas Water Conservation Association October 2012
 

Texas Water Conservation Association October 2012

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Texas Water Conservation Association October 2012 newsletter - www.twca.org

Texas Water Conservation Association October 2012 newsletter - www.twca.org

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    Texas Water Conservation Association October 2012 Texas Water Conservation Association October 2012 Document Transcript

    • OCTOBER 2012 TWCA Fall Meeting Returns to San Antonio The city famous for its Spanish missions, the Alamo, the River Walk, SeaWorld, Six Flags Fiesta Texas, and the San Antonio Spurs, is visited by approximately 26 million tourists per year. In October, the Crowne Plaza Texas Water Riverwalk Hotel will welcome TWCA members for the Association’s FallConservation Association Meeting. As usual, the agenda is packed with interesting and informative 221 E. 9th Street, Ste. 206 presentations and there will be ample time for catching up with attendees Austin, Texas 78701-2510 from around the state. 512-472-7216 Golfers tee off at noon on Wednesday for the 5th Annual Fall Fax: 512-472-0537 Classic Golf Tournament at The Quarry Golf Club, with an 11:30 check http://www.twca.org in for the 4 person scramble. A free Risk Management Seminar will start at 1 pm (see website for additional details). Wednesday evening, plan to Officers attend the Membership and Services Committee Reception, hosted by Luana Buckner, Brown & Gay Engineers, Inc. from 6-7 pm in the Grand Foyer. President Thursday morning, the TWCA Panels and Committees will convene in various locations between 9 and 11:30 a.m. Several of the Panels will Phillip J. Ford, feature special guest speakers with presentations on critical topics, so be President-Elect sure to check the program agenda for current location information. The TWCA Board of Directors Meeting will be held at 10:30 a.m. in Texas James M. Parks, Ballroom B on the second floor. Immediate Past President The Thursday afternoon General Session kicks off at 1 p.m. Highlights include Texas Land Commissioner Jerry Patterson, State Association Staff Senator Robert Duncan, and Zack Covar, the Executive Director Leroy Goodson of the Texas Commission on Environmental Quality. The afternoon session General Manager will include important presentations on water conservation, identity theft, e-mail: lgoodson@twca.org and restoration of the San Antonio River. State Representative Brandon Creighton will address the attendees at the Thursday Dean Robbins evening reception. Continued on page 4 Assistant General Manager drobbins@twca.org Opinions expressed in Confluence are those of the writer and not necessarily those of TWCA, its officers, directors or staff. © 2012, TWCA Covar Duncan Patterson Creighton 1
    • President’s Message… Texas Needs Bold Leaders Now is the time for to fund water projects. He told the viewers to bold leadership in Texas. hold their elected officials accountable – not Our vision must be bold by pledging against raising taxes – but by enough to withstand do the right thing for the needs of the state. Luana Buckner the temptations of our Representative Larson is currently touringpolitical motivations. And our actions must the state visiting groundwater districts, rivermatch our vision. As Texans lean further to the authorities and other water providers to gainpolitical “right”, we risk losing sight of our core firsthand knowledge of what these agencies areneeds as a state. In so doing we put the well doing and to learn more about water needs. being of our economy, our natural resources Senator Jeff Wentworth made a similarand our future in jeopardy. We can not continue bold statement recently saying what an importantto ignore the needs that are fundamental to and critical issue water is and the need for fundingour continued sustainability as a society. We it.must find a way to fund education, repair and Representative Harvey Hilderbran isbuild our infrastructure and more importantly, calling for wide spread reforms to our propertysecure and ensure certainty in our WATER. tax system. Reforms that could lead to increased If our political culture as voters insists on no revenues, according to the Center for Fiscal Policynew funding options for programs and projects at the Texas Public Policy Foundation. that are critical to our viability as a place to live, Land Commissioner Jerry Patterson haslearn and work, how can we expect to move a bold vision for water projects on the state’sforward and continue the growth our state has lands. Although still in a preliminary feasibilityenjoyed over the past few years. How are we phase, the project sounds promising. going to continue to grow our economy if we do As local and regional water leadersnot have adequate schools, transportation and representing all areas of state, we as memberswater to sustain that growth? Perhaps our state of Texas Water Conservation Associationwould be better served if we as voters took a more should continue to encourage these typesreasonable approach that in today’s political of bold ideas and bold leadership. We canclimate requires our leaders to be bold. and should do more to educate the decision Bold as in the step Chairman Allen Ritter makers and the voters. And, we should nottook last session to introduce legislation proposing be hindered by the constraints and prejudicesa constitutional amendment to establish a tap fee of partisan politics that threaten to stymie ouron water connections to assist the Texas Water progress as a proud and productive state. Development Board in the funding of certain If my comments today seem bold, thenprojects included in the state water plan. I’ve accomplished what I set out to do – set the There are also a few more bold members table for some truly bold discussion and debate.of the legislature emerging. State RepresentativeLyle Larson was on a San Antonio televisedtalk show just weeks ago calling for the need 2
    • Pesticide General Permit: All Pain, No Gain by Senator James M. Inhofe* Despite our efforts, as of October 31, 2011 pesticide applicationsto, over or near Waters of the United States require a Clean Water Act(CWA) National Pollutant Discharge Elimination System (NPDES) as aPesticide General Permit (PGP). This new rule inaugurates an onerousduplicative permitting process: previously pesticides were adequatelyregulated solely under the Federal Insecticide, Fungicide and RodenticideAct (FIFRA) – and for over 30 years, EPA did not require permits forpesticide application (1) if pesticides are applied directly to water tocontrol pests such as mosquito larvae and aquatic weeds; and (2) ifpesticides are applied to control pests that are present over or near water.Now compliance will no longer mean simply following instructions ona pesticide label. Pesticide users – including farmers, ranchers, forestmanagers, scientists and individuals from state agencies, city and countymunicipalities, mosquito control districts, and water districts – will have to navigate an expensive andcomplex process of identifying the relevant permit, file a valid notice of intent to comply with the permitwith the regulatory authority, and obtain a familiarity with all of the permit’s conditions and restrictions. As for the financial burden, EPA estimates the paperwork alone will cost $50 million annually;however, state estimates show the financial burden to be several magnitudes greater. Further,EPA estimates that this permit will impact 365,000 entities -- virtually doubling the number ofentities currently subject to NPDES permitting and covering 5.6 million pesticide applications eachyear. The PGP will touch 45 permitting authorities and require one million hours to implement. Unfortunately, under this new rule, it is possible for environmental activists to sue pesticideusers under the Clean Water Act, an avenue that was not available under FIFRA – and big greengroups make no secret of their intention to continue their citizen suits until all pesticide applications arepermitted if there is even a slight chance that the pesticide could come in contact with any “water,”either flowing water or seasonal drainage ditches that could be a conveyance to a water of the US. Continued on page 5* Reprinted with prermission from the March 2012 issure of Irrigation Leader magazine. 3
    • San Antonio... The General Session reconvenes on Friday morning at 8:15 a.m. and includes presentations fromContinued from page 1 Mike Turco, U.S. Geological Survey, Texas Water Development Board Chairman Billy Bradford, Grigadier General Thomas W. Kula of the U.S. Army Corps of Engineers, and State Climatologist John Nielsen-Gammon. The program will be capped off by a discussion of the new TWCA com- munications efforts on behalf of the Membership and Services Committee, and closing with a Case Law Update from the Water Laws Committee. “Once again, we’ve put together an outstand- Kula Nielsen-Gammon ing program for our members,” said Leroy Goodson, TWCA General Manager. “We all look forward to these opportunities to get together to talk about the important water issues, exchange ideas, and to the fel- lowship, as well. We will be heading into a Legislative Session and that always brings an added emphasis to our discussions.”  From the June Conference... Always delighted to have our Legislators join us and participate in TWCA meetings... Turco Bradford Representative Bill Callegari (top center) with Leroy Goodson and Dean Robbins (right). Sen. Troy Fraser (below center), Chairman, Senate Committee on Natural Resouces. 4
    • Pesticide General Permit Although this duplicative permitting process is now in effect, we have not given up the fight toContinued from page 3 stop it. On March 2, 2011, H.R. 872, the Reducing The results of this could be dire for pesticide Regulatory Burdens Act of 2011 – a bill that wouldusers: applicators not in compliance will face clarify that pesticide application used in compliancefines of up to $37,500 per day per violation, not with FIFRA do not need an additional Clean Waterincluding attorney’s fees. Given the fact that a large Act permit – was introduced. It passed overwhelm-number of applicators have never been subject to ingly in the House of Representatives by a vote ofNPDES and its permitting process, even a good 292-130 on March 31, 2011, and was passed out offaith effort to be in compliance could fall short. the Senate Agriculture committee by voice vote onMoreover, the CWA allows for private actions against June 21, 2011. Unfortunately the bill was stalled in theindividuals who may or may not have committed a Senate as environmental activist groups managed toviolation. Thus, while EPA may exercise its judgment get enough members of the Senate on their side. and refrain from prosecuting certain applicators, From global warming to water rules, mythey remain vulnerable to citizen suits. priority in my leadership role in the Senate Committee And, as with so many of EPA’s rules, the on Environment and Public Works has always beenexorbitant costs and the regulatory burden imposed to stop EPA from implementing regulations that arewill have no meaningful environmental benefits. all economic pain for no environmental gain, andAdvocates of this duplicative permitting process say the Pesticide General Permit process is very muchthat it is essential to ensure clean water, but this is a part of that fight. I will continue to work with mysimply not the case. NPDES is a permit to discharge. colleagues in the Senate to implement this much-In the case of pesticides, it’s a permit to discharge a needed legislative fix. substance that is already evaluated by EPA for impactsto water quality. No other permitted discharge subject Proudly serving communities throughout Texas for over 35 yearsto this unnecessary double regulation by EPA. Governmental Entities have always been our core business. If anything, this process will likely be detrimental Client satisfaction is our top priority.to public health, as the increased likelihood oflitigation could lead some to discontinue pesticide use Water Plantsaltogether. If this happens, control of mosquito and Water Well Rehabilitationother vector borne diseases that regulatory threaten Wastewater Treatment Plantshuman health will be significantly disrupted by the Lift StationsPGP process; this process could also create barriers to Plant Inspectionsthe control of pests such as the Gypsy Moth and Forest Geographic Information Systems (GIS)Tent Caterpillar, which could result in more cases of Water, Sanitary Sewer & Drainagetree deaths in forests and defoliated landscapes. Sanitary Sewer Rehabilitation My own state of Oklahoma does not have Hydraulics & HydrologyNPDES permitting authority for pesticides, but it Construction Managementdoes not anticipate that requiring NPDES permits Surveying Utility District Consultationfor pesticide applications will provide significant Bond Application Reportsenvironmental benefits. The stream segments inOklahoma with pesticide impairments are mostly dueto older, legacy pesticides that EPA has cancelledand/or discontinued. None of these impairments are www.jonescarter.com | 713 777 5337attributable to pesticides applied directly to waterways,but rather are the result of stormwater runoff. 5
    • Sequestration and the Fiscal Cliff FED ERAL D EVELOP M ENTS The fiscal cliff has three components: the expiration of the Bush tax cuts, the end of the An Historic Lame Duck Alternative Minimum Tax “patch”, and automatic, and Other Issues across-the-board cuts (known as “sequestration; see June 2012 CONFLUENCE, page 14 ) that will cut By Tom Ray, $110 billion per year for the next ten years equally split Lockwood, Andrews & Newnam between defense and non-defense spending. Taking together the impacts are predicted to cause double- The “lame duck” session of the 112th Congress dip inflation in 2013. Nearly all proposals to avoid thewill begin on November 13 and likely end just before fiscal cliff involve extending certain parts of the 2010Christmas. Speaker Boehner in the House and Leader Tax Relief Act or changing the 2011 Budget ControlReid in the Senate will be responsible for determining Act or both, thus making the deficit larger by reducingthe priorities of the lame duck, but both recognize the taxes and/or increasing spending.number one issue to be taking the steps necessary to The potential impacts of the draconian auto-cutsprevent the United States from going over a fiscal cliff in defense and non-defense budgets are easily recognized,by a triad of converging fiscal dictates. The upcoming but consider the impacts to individual wage earners oflame duck may be one of the most significant sessions the expiration of the Bush tax cuts. The box shows thein recent history, more so than the December 2010 lame latest report from the nonpartisan Tax Policy Center.duck session passed the extension of the Bush tax cutsfor an additional two years. Unfortunately, while “going off the fiscal cliff”may be addressed during the lame duck session inCongress, there is a huge backlog of uncontroversialyet still important legislation that will die with the 112thCongress at the stroke of midnight, December 31st. Budget deficits, projected through 2022. The “CBO Baseline” shows the effects of the fiscal cliff under current law. The “Alternative Scenario” represents what would happen if Congress extends the Bush tax cuts and repeals the Budget Control Act-mandate. 6 Continued on page 14
    • New Lawsuit Against TWDB Highlights Physical and Legal Relationship Between Groundwater and Surface Water by Andrew S. “Drew” Miller It is an accepted canon of water law in Texas As a result of the drilling of wells and the largethat surface water and groundwater are regulated scale pumping of groundwater for irrigation onunder entirely separate legal regimes. This division nearby property, the springs ceased flowing. Theexists despite the fact that – physically speaking – water district which provided water to farmers usingground and surface waters are, in fact, part and parcel the water which had emerged from the springs filedof the same thing, namely, water moving through suit against the groundwater pumper, asking that hevarious states of the hydrologic cycle. be enjoined from interfering with the normal flow of Comanche Springs and for other relief. The Comanche Springs Case (1954) The court of civil appeals ruled against the The historical separation between the legal District, stating that under the laws of Texas,regimes governing groundwater and surface water, groundwater belongs to the landowner and mayand the dissonance that results from the application be used by him at his will. Thus, groundwaterof that separation to the physical reality of the contributing to the flow of Comanche Springsconnectedness between groundwater and surface belonged to the landowner while it was under hiswater is perhaps best illustrated through the holding land. The court refused to declare the District’sin Pecos County Water Control and Improvement correlative rights in the groundwater, explainingDistrict No. 1 v. Williams, 271 S.W.2d 503 (Tex. that the District’s rights could only extend to watersCiv. App.–El Paso 1954, writ ref’d n.r.e.). of Comanche Springs after their emergence from Comanche Springs in Pecos County were used the ground. Prior to that time, the landowner couldfrom prehistoric times by the Jumano Indians. They beneficially use any amount of water regardless ofwere likely visited in 1536 by Cabeza de Vaca and its impact on the springs.later described by Juan de Mendoza in 1684. In 1849, Since the Comanche Springs case was decided,William Whiting of the U.S. Cavalry described them scores of groundwater conservation districts (GCDs)as “a clear gush of water which burst from the plain, have been created in Texas. GCDs have theunperceived until the traveler is immediately upon responsibility and legal authority to manageit . . . abounding in fish and soft-shelled turtles.” In groundwater resources and regulate groundwater1859, the United States established Camp Stockton, production, and manage and conserve groundwaterand used the spring water as its supply. From 1875 resources.on, the springs formed the basis of an irrigationdistrict that watered thousands of acres of cropland. Environmental Stewardship v.By the 1930s, Comanche Springs became a regional Texas Water Development Board (2012)attraction, enjoyed by local residents, visitors and Almost 60 years after the Comanche Springstourists. A bathhouse, swimming pool and pavilion case, the acknowledged division between the legalwere constructed there in 1938. regimes governing surface water and groundwater, 7 Continued on page 8
    • New Lawsuit Against TWDB... were adopted by the GMA for the various aquifers in each of the groundwater conservation districts’Continued from page 7 jurisdictions. Environmental Stewardship alleges thatand potential connections between the two, have groundwater pumping resulting from the adoptedbeen brought to the fore as a result of a lawsuit DFCs would “unreasonably threaten the groundwater-by Environmental Stewardship, a non-profit surface water relationship between the Colorado andcorporation, against the Texas Water Development Brazos Rivers and the underlying aquifers governedBoard (“TWDB”) regarding TWDB’s treatment of an by the DFCs.” Environmental Stewardship alsoappeal of Desired Future Conditions (DFCs) adopted asserts that such groundwater pumping would harmby Groundwater Management Area 12 (“GMA-12”). terrestrial and surface water resources dependent Environmental Stewardship filed its lawsuit in on outflow from the aquifers into the Colorado andJuly 2012, in state district court in Travis County. Brazos Rivers. Following a hearing held on FebruaryEnvironmental Stewardship alleges that it and its 29, 2012, in Milano, Texas, which included themembers own property in Bastrop County, within presentation of evidence, and upon the considerationGMA-12. GMA-12 covers all or portions of 14 counties of the recommendation of TWDB’s staff, the TWDBin central and east Texas including Bastrop County, denied Environmental Stewardship’s petition. Theand includes all or portions of the jurisdiction of five staff recommendation stated in summary that whileGCDs, including the Lost Pines GCD. The goals of some of Environmental Stewardship’s criticismsEnvironmental Stewardship include the protection, regarding the alleged failure of the GCDs to followconservation, restoration and enhancement of the proper procedures, inappropriate methodologyecological functions of the Colorado River and the including modeling assumptions, and the failureBrazos River and the groundwater and watersheds of the GCDs to adopt evidence presented duringassociated with those streams. Environmental GMA meetings, may be valid, none of themStewardship says that its members include: a well warrants a determination that the adopted DFCs areowner who relies on groundwater for domestic unreasonable.and livestock use; a holder of permits allowing the In its lawsuit, Environmental Stewardshipwithdrawal of surface water from the Brazos river for now claims that TWDB acted contrary to its ownirrigation use; and the owners of a ranch that includes rules by determining that the GMA-12 DFCs weretwo groundwater wells and several seeps and springs. reasonable without considering the impacts of the Environmental Stewardship’s members are DFCs on surface water and on surface water rights.concerned that the pumping of groundwater that will Environmental Stewardship relies on a TWDB rulebe allowed under the adopted DFCs will negatively which states that “[t]he board shall consider theimpact their access to their water and water rights. following criteria when determining whether a desiredFor example, the ranch owners are concerned that future condition is reasonable…(3) the environmentalincreased pumping of groundwater will result in the impacts including, but not limited to, impacts to springpermanent drying of the springs on their property flow or other interaction between groundwater andand may jeopardize the continued operation of their surface water;… [and] (5) the impact on privateranch. property rights…” 31 Tex. Admin. Code § 356.45(c). At issue is the TWDBs review, in 2011, of Environmental Stewardship argues that TWDB isDFCs adopted by GMA-12 for the Sparta, Queen required to consider impacts to spring flow, surfaceCity, Carrizo-Wilcox, Calvert Bluff, Simsboro, water, and surface water rights but failed to do so.Hooper, Yegua-Jackson, and Brazos River Alluvium The Office of the Attorney General has filedaquifers, in response to a petition that was filed a general denial on behalf of TWDB – meaningby Environmental Stewardship appealing those that it has denied Environmental Stewardship’sDFCs. The GMA-12 DFCs are expressed as an claims – but has not yet responded substantively.average aquifer drawdown in feet, measured from It is likely that TWDB will seek to have the caseJanuary 2000 to December 2059. Different DFCs dismissed on the grounds that the decision by TWDB 8
    • on an appeal of a DFC is not a final agency action interactions between groundwater and surfacecapable of judicial review because it is ultimately not water;” before voting on the DFCs (Tex. Water Codebinding on the GCDs. (The 2011 Legislation has § 36.108(d)(4));changed the law so that individual GCDs are now  GCDs’ management plans must include estimatesrequired to adopt relevant DFCs.) A similar request of the annual volume of water that discharges fromfor dismissal was granted by the district court in each aquifer to springs and any surface water bodiesanother lawsuit in which Mesa Water had appealed (Tex. Water Code Ann. § 36.1071(e)(3)(D)); 31 Tex.the determination of TWDB that the DFCs adopted Admin. Code § 356.5(a)(5)(D)); andfor GMA 1 were reasonable, a case that was later  The Edwards Aquifer Authority Act expresslyvoluntarily dismissed. It is likely that Environmental recognizes “the extent of the hydro-geologicStewardship will argue that its lawsuit is different from connection and interaction between surface waterMesa Water’s such that the courts have jurisdiction and groundwater” (EAA Act § 1.14(a)(5)), and aover Environmental Stewardship’s claims. However, central purpose of that legislation is to protect andeven if Environmental Stewardship’s lawsuit is maintain springflows at San Marcos and Comalultimately successful, the appropriate remedy may Springs (EAA Act § 1.14(a), (h)).be for TWDB to go back and consider impacts tospring flow, surface water, and surface water rights, Conclusionin determining the reasonableness of the GMA-12 Although a divide between the legal regimesDFCs, and that upon doing so, TWDB will again governing groundwater and surface water remains,determine that those DFCs are reasonable. the enactment of statutes including those governing groundwater districts, and the adoption of rules by Connections between groundwater agencies since the Comanche Springs, case have and surface water under existing law established connections and some overlap between Current law is not devoid of connections between those regimes. It remains to be seen whether and howgroundwater and surface water. Environmental the Texas Legislature will add to those connectionsStewardship’s lawsuit relies on the fact that under its and how the courts will apply and interpret thosecurrent rules, TWDB is to consider impacts to spring connections in situations such as the Environmentalflow, and other interactions between groundwater Stewardship case.and surface water, when determining whether a DFCis reasonable. Some of the other connections betweengroundwater and surface water under existing law Drew Miller is the 2012-are listed below: 2013 TWCA Water Laws GCDs are required to consider – prior to granting Committee Chair and aor denying a permit – whether the proposed use of partner at the Austin officewater unreasonably affects existing surface water of Kemp Smith LLP whereresources or existing permit holders prior to granting he serves as the chair ofor denying a permit (Tex. Water Code § 36.113(d) his firm’s Environmental,(2)); Administrative and Public Likewise, the Texas Commission on Environmental Law Department. Drew represents public andQuality is required to consider the effects, if any, on private entity clients across Texas in the areasgroundwater or groundwater recharge, in considering of water and environmental law, specializingan application for a permit to store, take, or divert in groundwater regulation and issues involvingsurface water (Tex. Water Code § 11.151); contaminated property. If you would like TWDB rules may it clear that DFCs may be based additional information or have questions relatedon spring flows (31 Tex. Admin. Code § 356.2(8); to this article or other matters, please contact Drew GCDs are required to consider “environmental at 512-320-5466 or dmiller@kempsmith.com.impacts, including impacts on spring flow and other 9
    • Water Conservation on the Golf Course... Horseshoe Bay Resort Sets an Excellent Example For those among us who scoff at the practice only 14% of golf courses utilize water from municipalof using large quantities of potable water in dry systems. And golf courses account for only 0.5% ofclimes or during droughts to irrigate broad sweeps all water use annually and just 1½% of all irrigatedof well-manicured links, scoff no more. Golf course water applied. Recycled water is used by 12% of golfsuperintendents across America are among the best – facilities, a number that small only because such use isif not the best – conservationists out there in this time limited by the availability of effluent water and by theof looming water shortages. If you don’t believe me, lack of water-provider infrastructure to deliver it. take it from former Georgia Governor Sonny Perdue Smart golf course superintendents utilize manywho, in 2007 during Georgia’s most severe drought in methods to conserve water. They hand water criticaldecades, applauded only one group of professionals areas, use wetting agents to deal with localized turfgrassfor their expertise in water management… dry spots, and these days, keep turf drier than in times And why wouldn’t golf course managers past to name just a few. Customers seldom complainrespect this most precious of all natural resources? about the latter practice. Golfers abhor spongyAfter all, it’s the life blood of an almost $80 billion a year fairways and delight in the added distance firm, dryindustry. If not sourced and utilized properly, a poorly fairways provide…but that’s another topic. managed water supply can be the death knell to what Research provides key information...is first and foremost a viable commercial activity, and The careful study of turf grass and soilsecond, frequently the most beautiful, environmentally conditions is an important tool for golf coursesound, recreational asset in a community. superintendents in determining when to apply But why should we use precious potable water water. And the use of evapotranspiration data –to maintain golf courses green for the enjoyment of a minimizing the return of moisture to the air throughtiny portion of our local populace? In fact, very much evaporation from the soil and transpiration bypotable water for such purposes. According to the plants – is an increasingly sophisticated practice. Golf Course Superintendents Association of America Already schooled in water conservation(GCSAA), a leading golf organization since 1926, practices, groundskeepers’ receptiveness for and 10
    • utilization of advanced water-use techniques can only 170 or so privatebenefit golf facilities and the golf industry. Progress clubs, and as thecontinues to be made in a number of areas, including: recent director of golf1. The use of improved soil sensors to make better- course maintenanceinformed irrigation scheduling decisions. Depending on at Austin’s Bartonsoil type, slope and other environmental characteristics, Creek Club & Resort,some areas of the typical golf course simply need less Gorzycki arrived infrequent, less intensive watering than others. Horseshoe Bay well-2. Because the supply of and demand for qualified to do thewater is a matter unique to a given locality, the job. He came as acommitment of time by course managers to work certified golf coursecollaboratively with the body politic of the community superintendentis important in the development and improvement (CGCS by GCSAA) with an impressive list ofof public policy related to such issues. memberships including the United States Golf3. And an important aspect of 2. above, is that golf Association, Texas Turf Grass Association, Unitedcourses represent a potential long-term demand for States Golf Association Green Section Committeelocal water treatment facilities. Municipal effluents and the Lone Star Golf Course Superintendentsmust be treated and the resultant output needs a home. Association. Ken is a proud Texas Aggie with aOne obvious destination, given the development of Bachelor of Science degree in Agronomy.an existing infrastructure, is the local golf course. Inshort, golf course managers should strive to optimizethe use of reclaimed water, assuming that the availablesupply, water quality and costs are sustainable. 4. Proper management of turfgrass, which is aneffective biological filter to further treat water, is vital.Across the country, golf courses irrigate approximately80% of the turfgrass acreage they maintain. In thecountry’s west and southwest regions, where wateris even more precious, course managers, generallyspeaking, irrigate only the turfgrass that comes intoplay. It follows that irrigation systems should beproperly zoned to allow for such precise application. In June, TWCA members had the enviableexperience of playing golf on the beautiful andimmaculate golf courses at Horseshoe Bay. Thosecourses are neat as a new pin for a reason. In January,2009, Texas’ original lakeside resort, HorseshoeBay, appointed Kenneth Gorzycki, CGCS as itsDirector of Agronomy to manage the conditions of itthree Robert Trent Jones, Sr. golf courses: Apple Rock,Ram Rock and Slick Rock; Whitewater, an 18-holeBurmuda grass putting course; and Summit Rock,a then developing Jack Nicklaus Signature Course,which opened in October, 2011. After 30 years withDallas-based ClubCorp, an owner or operator of 11 Continued on page 12
    • Ram Rock Course you that.” With conviction, Ken went on to say, “Golf Course Superintendents are the best irrigators in the country today. They have to be. In the first place, it’s their job to keep the golf course in good condition. Secondly, irrigation is too expensive not to be done with deference to conservation. People can learn a great deal about water conservation by talking with experienced golf course superintendents.” Asked how his operation is dealing with the current drought in Central Texas, Ken said, “Prior “In addition to its natural beauty, the planning and good luck is part of the formula. TheHorseshoe Bay community is blessed with another effluent water provided by the city treatment plant isimportant commodity…water,” Ken noted in an a Godsend. It provides us most of the water neededinterview. “A primary water source for the resort golf to sustain good greens and tee areas. We minimizecourses is the City of Horseshoe Bay waste water water usage on the periphery and in the rough, buttreatment plant, which has a capacity of 800,000 even with cutbacks, things have…knock on wood…gpd.” turned out better than we had reason to expect in According to Gorzycki, the treatment plant’s light of the drought’s severity.”output currently averages around 500,000 gpd. The Ken is committed to sharing his Bestplant has two on-site, 50 acre feet storage ponds. This Management Practices (BMPs) with other golf andstored effluent water is pumped through a continuous irrigation practitioners. He’s currently working withbackwash, filtered and pressurized to irrigate the golf a Texas Water Development Board committeecourses in Horseshoe Bay West. is 100% recycled, to revise Golf Course Irrigation BMPs. Ken alsomostly on the Horseshoe Bay golf courses. None serves on the Lower Colorado River Authority’sis returned to the city’s source of water, Lake LBJ. Water Management Plan Advisory Committee andBecause Horseshoe Bay does not have a discharge chairs the Water Conservation Incentives Reviewpermit, it delivers the water to the golf courses at no Committee.charge. Asked to detail some of his Best Management “We must use it or store it. It can’t be dumped,” Practices for water conservation, Ken replied, “There’sKen explained. “On those occasions when we have nothing unique about my list. It’s mostly commontoo much supply coming from the treatment plant – sense. With regard to the natural environment, Iand the storage ponds are full – the water is delivered would suggest starting with the selection of low-water-to nearby hay fields. Generally speaking, however, use turfgrasses – new grasses are constantly beingwe could use more water, particularly during the heat developed – groundcovers, shrubs and trees. Be sureof summer.” to use mulches in shrub and flower beds to reduce Ken, who is in his fourth year at Horseshoe water evaporation. And provide adequate levels ofBay, has a strong water conservation philosophy. nutrients to the turf.”“It’s simply the right thing to do, particularly in a “From a turf maintenance perspective, I woulddry climate like Central Texas,” he said. “Water suggest mowing heights that fit the given species ofconservation is critical to the operation of golf courses turfgrass and for its seasonal water-use characteristics.today. It makes business sense and it makes course To improve water infiltration and minimize watermanagement sense.” Underscoring an earlier point, runoff during rains or irrigation, I employ soil andGorzycki maintained that the best course condition turfgrass cultivation techniques such as verticutting,is firm and dry. “Our members will be the first to tell spiking, slicing and aerification. It’s also important 12
    • to locate trouble spots and improve drainage as Gorzycki mentioned just a few environmentalneeded to produce healthier turf and improve root considerations. He stressed that during golf coursesystems. Where possible, cart traffic should be limited design and maintenance, the preservation and/orto hardened paths. This minimizes turf wear and creation of both wildlife and plant species habitatssoil compaction. And it makes sense to root-prune should be carefully considered. Regarding wildlife,trees in critical turf areas to minimize competition for food, water, “unmaintained” cover and animal rangemoisture and nutrients. Lastly, I would suggest that should be considered. And native and/or naturalizedgroundskeepers stay current on the latest irrigation vegetation, to the extent possible, should be retainedtechnology, and when using it, to cycle their irrigation or replanted in areas not in play.sessions to ensure proper infiltration and to minimize “It is important to respect the uniqueness ofrunoff.” the existing ecosystem(s) into which the course has “It’s important that golf course superintendents been or will be integrated,” he said. “And water reusebe good stewards of the environment,” Ken strategies are crucial, with emphasis on irrigation,continued. “I think all superintendents should drainage and retention systems that provide for theconsider creating an . One that lists what they are efficient use of effluent water and the protection of, but that also lists what they …perhaps a digitized/ water quality. Regarding the latter, proper day-to-web-based template – a checklist, if you will – to be day fertilizer and chemical use and safety (i.e., theused to perform regularly scheduled environmental safe storage, application and handling) is extremelyaudits. This self-imposed “report card” could then important.”be used to consider the options available to improve “The catalog of golf course environmentalefficiency.” considerations is long,” Ken said in summary. “That’s why an environmental resume or routinely monitored check list is so important. Every superintendent should develop one.” Asked why he gets involved in so many extracurricular conservation activities, Gorzycki replied, “It’s important that the experienced people in golf course maintenance share their BMPs with the newcomers among us so that they, too, can initiate proven-to-work practices. And despite 35 years of experience, I continue to learn from my interaction with others. Besides, it’s the right thing to do. My philosophy, to the extent that I can, is to do well by doing good.”  MARK YOUR CALENDARS... TWCA FALL MEETING October 24-26, 2012 The Crowne Plaza Riverwalk Hotel San Antonio, TX 13
    • FED ERAL D EVELOP M ENTS ... issues such as the sequester, tax policy, and a host of other unfinished business will likely keep the CongressContinued from page 6 in session until right before Christmas, perhaps even Some Hope from Bipartisan Talks Christmas Eve. If you look at your calendars, Charismas At least in the Senate there are bipartisan Eve is on a Monday. Our personal bet is that if thetalks expected during the current recess on potential Congress is still going on Friday, December 21, that wecomprises to deal with the fiscal cliff. A group of eight will see a “Christmas miracle” a Congress will somehowSenators (known as the “Gang of Eight”) is taking manage to complete its work on the weekend ofseriously about tax and spending issues and means December 22-23 and still make it home for Christmas.to resolve the dilemma. Another group of Senators,headed by Armed Services Chairman Carl Levin,D-Mich., and John McCain, R-Ariz., have petitionedSenate leadership to “…help forge a balancedbipartisan deficit reduction package to avoid damageto our nation security, important domestic priorities andthe nation’s economy.” According to CQ Today, HouseRepublicans, for their part, say they have no plans totalk with Democrats about budget issues before theNovember elections. Spending as Usual Anticipated for Federal Agencies With all this up in the air right now, apparentlythe Office of Management and Budget has someconfidence that the issues will be avoided. In a routine New Chief’s Remarksmemo issued by the OMB each September to provide The Corps’ leadership made a series of excellentdirection to federal agencies on how to operate under presentations at the recent National Waterwayscontinuing resolutions, the agencies were told to Conference meeting. The newly appointed Chief ofcontinue normal spending and operations. However, Engineers LTG Thomas Bostick was the keynote.OMB did recognize the threatened sequester, telling Giving an overview of the USACE focus for the future,agencies “…to ignore it, for now. If necessary, the Chief Bostick cited military preparedness and the Civilbulletin will be amended to address that sequestration.” Works transformation as critical needs. He recognized In or Out of Session and For How Long? that the nation’s water resources infrastructure has If you wanted to be involved with a successful exceeded its design life and will require more extensivewager, you might offer to bet people on whether maintenance and rehabilitation in the future. “TheCongress is in recess right now. Many would probably Corps will have to prioritize projects and programsrespond, “They are in recess and won’t go back until with rigorous analysis to ensure the greatest value forNovember 13th for the lame duck.” And you would win the taxpayer funds.”your bet. The fact is that both the House and the Senate Certainly the aging civil works infrastructureare in session several times a week. At least technically. is one of those challenges. Important to TWCA, theFor example, a Senate session earlier this week lasted Chief noted that as dams have aged and downstream13 seconds before adjournment was announced. Pretty development has increased, the number of deficienthard to do much floor business in such a time span. dams has risen to more than 4,000, including 1,819 But other than the current “pro-forma” sessions, high hazard potential dams. Over the past six years,Congress won’t really be back until November 13, for every deficient, high hazard potential dam repaired,which is the start of the “lame duck.” We have been nearly two more were declared deficient. There aretold that the opening act of the lame duck will begin more than 85,000 dams in the U.S., and the averagewith about a week’s worth of work. Then adjournment age is just over 51 years old.for Thanksgiving. And then back into session the last Civil Works Focus:week of November. Transform Civil Works There will be an attempt to wrap things up by With respect to the Civil Works, Chief Bostick providedmid-December. But we have been told that huge the overview and Steve Stockton the specifics of the Continued on page 18 14
    • Leroy Goodson to ReceiveTWCA’s Confluence Newsletter gratefully acknowledges the TGWA’s Life Member Award 2012 Sponsors who make Texas Ground Water this communication among Association Executive Secretary Leroy Goodson will receive members possible... a Life Member Award from PLATINUM the National Ground Water Association for special service in AECOM the furtherance of the ground- Angelina & Neches River Authority Freese and Nichols, Inc. water industry and NGWA. Lloyd Gosselink Rochelle & Townsend, P. C. The award will be presented North Texas Municipal Water District in Decem ber at the NGWA Gr ou n dwa ter SAIC Energy, Environment & Infrastructure LLC Expo and Annual Meeting in Las Vegas. San Antonio River Authority Goodson has been executive secretary Tarrant Regional Water District his entire 31 years at the TGWA. During that GOLD time, TGWA’s membership has grown from 400 members to about 1,600 members. Brazoria Drainage District No. 4 “Leroy was instrumental in the development Brown & Gay Engineers, Inc. of continuing education for the licensees in the Chambers-Liberty Counties Navigation District Colorado River Municipal Water District groundwater industry and has a true love for those Guadalupe-Blanco River Authority involved in this profession,” said TGWA President Gulf Coast Waste Disposal Authority Jason Cadwallader, Goodson’s nominator, noting Harlingen Irrigation District Cameron County #1 that the nomination was supported unanimously by Jefferson County Drainage District #6 the TGWA Board of Directors.  Lavaca-Navidad River Authority Lower Neches Valley Authority North Harris County Regional Water Authority Northeast Texas Municipal Water District Sabine River Authority of Texas San Jacinto River Authority Titus County Fresh Water Supply District #1 TWCA Risk Management Fund Upper Neches River Municipal Water Authority SILVER Barton Springs/Edwards Aquifer Conservation District Cameron County Drainage District #1 Canadian River Municipal Water AuthorityEvergreen Underground Water Conservation District Franklin County Water District J. Stowe & Co., LLC K. Friese & Associates, Inc. BRONZE Bell Engineers and Consulting, Inc.Brazoria County Groundwater Conservation District John E. Burke & Associates LLC Kimley-Horn and Associates, Inc. Klotz Associates, Inc. Plum Creek Conservation District Texas Water Foundation, Inc. 15
    • New Outreach for TWCA By David Harkins, Ph.D., P.E., D.WRE, Vice President - RPS Espey We’ve come a very long way from the Paleo-Indians who inhabited Texas thousands of years ago.In fact, it would be a stretch to draw many comparisons between such diverse inhabitants then and now...with the possible exception of love of family and respect for the environment. We’ve evolved from usingsmoke signals to internet blasts and social media in less than ten thousand years! Yet the challenge remainsthe same -- exchanging information, ideas, and news in a timely (and actionable) manner. This was the assignment tackled by a Membership Panel task force in 2010 when they began envision-ing the kind of communications efforts appropriate forthe top membership water organization in the State.The group included Tom Michel, Deputy GeneralManager, Harris-Galveston Subsidence District; DavidHarkins, Ph.D., P.E., D.WRE, Vice President - RPS a: he imparting or exchanging of information tEspey; and chaired by Jason Hill, Lloyd Gosselink or newsRochelle & Townsend, P.C. b: he successful conveying or sharing of ideas t According to Tom Michel, “As water issues and feelingscontinued to intensify globally – and with a Texas c:  ersonnel engaged in transmitting or p exchanging informationLegislative Session on the horizon -- the Association’s d:  technique for expressing ideas effectively achallenge to provide timely and pertinent information (as in speech)had escalated correspondingly. In today’s fast-paced, e: all of the above.24/7, high-tech information arena,” Michel continued,“we are inundated by sophisticated and instantaneous communication strategies, each competing for our You’re invited! Please make plans to attend our Communications Themed Reception, sponsored on behalf of the Membership and Services Committee by Brown & Gay Engineers, Inc. -- 6 - 7 p.m. in the Grand Foyer, Wednesday, October 24th. 16
    • attention. We decided it was time to elevate the TW- Facebook and Twitter. An important feature on theCA’s ability to reach its various publics efficiently and new site is the ability to sign up for periodic electroniccost-effectively, utilizing a bolder outreach approach. messages on key topics. Other conveniences -- likeThe Task Force determined that soliciting professional the ability to register online for conferences and meet-communications assistance was appropriate, so we ings -- are progressing, with the first level of this beingdeveloped and distributed a Request For Proposal available for the October 2012 meeting. As with all(RFP).” new things, the interactive components will take some The language in the RFP was specific in time to tweak.outlining what skills the Task Force had concluded The Association’s Facebook section (ac-were necessary for a candidate to possess, including: cessible from the home page) is becoming morea working knowledge of historic and contemporary popular and as its use grows, new information willwater issues; superior writing and design skills; and be introduced. Same is true for Twitter. Social mediathe ability to employ a creative approach to develop- programs tend to peak and lag, so the objective is toing a critical outreach program. be flexible and able to maximize the programs that Ten firms submitted proposals and, after a appear to resonate with members.series of individual interviews, the Task Force se- During the Membership and Services Com-lected Barbara Payne, Payne Communications, as mittee meetings at each of the TWCA conferences,the new consultant. She began her assignment at participants have been especially helpful in advanc-the June 2011 Conference in Galveston, and laugh- ing communications strategies and ideas, and thisingly explained that she had been “thrown into the is expected to continue. Since communications isdeep end” when at their meeting, the TWCA Board always (or certainly should be) a two-way street, so-recommended taking aggressive outreach action in liciting input and ideas from all interested parties willsupport of Proposition 2 (Proposed Constitutional be important in order to incorporate key concepts ofAmendment for Water Financial Assistance Bonds). interest to the diverse TWCA membership. The same input will be useful in the production of the Associa- tion’s newsletter, as well. CONFLUENCE June 2012 The October 2012 newsletter is the Texas Water Popular Venue Draws A Crowd for TWCA June Meeting in Horseshoe Bay TWCA members will be travelling from all over the state to the third new format edition Conservation Association popular Horseshoe Bay Resort in the Texas Hill Country. There’s a full 221 E. 9th Street, Ste. 206 agenda planned for the event, kicked off by the 6th Annual Jim Adams Austin, Texas 78701-2510 Memorial Golf Tournament on the Ram Rock Course Wednesday after- 512-472-7216 noon, with a 1:00 pm tee off. The TWCA/RMF reception will begin at Fax: 512-472-0537 5:30 pm. (Visit the website--www.twca.org -- for the latest agenda.) of CONFLUENCE, now http://www.twca.org Beginning in the morning on Thursday, the panels will all meet between 9 am and noon, with the General Session kicking off at 1 pm with remarks by the Mayor of Horseshoe Bay, Robert Lambert. Par- Officers ticipants will have the opportunity to hear from the Chairman of the Luana Buckner, Senate Natural Resources Committee, Sen. Troy Fraser; from TCEQ President Chair Bryan Shaw, PhD; and from Melanie Callahan, Executive “reinvented” into digital Administrator, TWDB. Rounding out the session -- prior to the Board of Phillip J. Ford, Directors meeting -- is Carlos Peña, Principal Engineer, United States President-Elect Section of the International Boundary & Water Commission. Critical top- ics, such as a national perspective on water issues, water conservation, and the Lake Granbury study, complete the afternoon’s discussions. publishing and distri- James M. Parks, Immediate Past President Back by popular demand is a Reception and Dance, featuring Cactus Country Band that will surely set your toes a’tapping. The festivities begin at 6:30 in Salons ABCD. Association Staff Off to an early start on Friday morning with opening remarks by Leroy Goodson Burnet County Judge, Donna Klaeger. Reuse will be one of the hot bution. Special reports General Manager topics for the morning, along with remarks by Brigadier General Thomas e-mail: lgoodson@twca.org W. Kula, U.S. Army Corps of Engineers. Robert Mace will be on hand to explain that the “Drought Ain’t Over ‘til it’s Over”. Developments in Dean Robbins groundwater hydrology and a review of the endangered species act close out the program. Assistant General Manager continue to be included, According to General Manager Leroy Goodson, “We are look- drobbins@twca.org ing forward to hearing from this distinguished group of speakers and to the fellowship these meetings provide.” sharing important in- Opinions expressed in Confluence are those of the writer and not necessarily those of TWCA, its officers, directors or staff. © 2012, TWCA sight from the Federal FRASER SHAW CALLAHAN MACE 1 Affairs and Water Law New Cyber Image… committees. This edition contains the first in a series There was unanimous agreement that the of “Frequently Asked Questions” that will focus onwebsite needed priority attention, so this was the items of interest to TWCA members, but perhaps notfirst project tackled under the new agreement. Soon readily accessible. Members can use the “contact us”a new, easily navigable, esthetically pleasing website section on the website to submit their questions byappeared online and, based on the direction provided selecting “Info” from the pull down menu.by the Task Force, new sections appeared... including Continued on page 18 17
    • Can you hear me now? FED ERAL D EVELOP M ENTS ...Continued from page 17 Continued from page 14 Another critical area identified by participants Civil Works Transformation. It is important for TWCAat Committee meetings is the challenge of making members, particularly those that are local sponsors fornew TWCA members feel comfortable and welcome Corps projects, to be familiar with the process. The Corps is seeking input, and TWCA should organizewhen they attend their first meeting. The concept of an effort to provide it. The TWCA Federal Affairsa new member packet is under review, to include in- Committee will take up the issue.formation about the Association and how it operates, The objective of the Civil Work Transformationso that new members can make intelligent decisions is deliver the best possible products and services to theabout how they’d like to participate to get the most Nation by:from their membership.  Modernizing the project planning process (Feasibility The Membership and Services Committee is Studies – 3 years x $3 million x 3 levels of review AND less than 3" binder)once again pleased to host a Reception for all TWCA  Working with the Administration, Congress, andmembers on Wednesday October 24, 6-7 pm in the our internal team to enhance and refine the budgetGrand Foyer. The event is generously sponsored by development process through a systems-orientedBrown & Gay Engineers, Inc. on behalf of the Com- watershed approach, collaboration, and innovativemittee. financing. Please also plan to attend the Committee’s pre-  Evaluating the current and required portfolio of watersentation -- Can you Hear Me Now? -- during the resources projects through a smart infrastructure strategy.  Improving methods of delivery to produce and deliverGeneral Session on Friday morning, 10:30 a.m. We critical products and services on schedule.are interested in hearing from YOU, and how YOU  Engaging other governmental and non-governmentalthink we can continue to improve communication!  partners in working toward National, Regional and Local priorities. How these objectives will translate to local projects is not clear, at least at this point. Corps of Engineers Readies for CWA “Field Initiatives” One of the most important unresolved issues is how to define “waters of the US.” You will recall that over the past three years, this has been the focus of legislation that the Congress was never able to agree as well as Administration attempts to develop either a Rule or Guidance to resolve the issue. A detailed briefing was presented on the FY13 Corps proposed budget. A total budget of $ 4.731 Billion was broken down by business lines, which showed that for most major business item related to water resources (navigation, flood risk management, ecosystem restoration, and hydropower) there was a significant decrease in the FY13 proposed budget as compared to the FY12 budget or FY12 appropriated funds. However, two line items, recreation and regulatory, received increased in the FY13 budget: recreation and regulatory. There was $9 million increase over the FY12 budget ($12 million if compared to the FY12 appropriated amount) for “regulatory support.” Regulatory support was one item that Congress actually 18
    • cut. When questioned about this line item, it turns out Business As Usual No Longer Viablethat, in addition to rulemaking and inflation cost, this for Managing U.S. Army Corpsincrease is “…to implement new field level initiatives Water Infrastructurefor Clean Water Act jurisdictional determination….” -- National Research Council ReportWe should recognize that the regulatory programs The Corps of Engineers sponsored a NRCwere imposed on the Corps of Engineers; the report on its infrastructure; the draft version is nowbudgeting for it is a response to those mandates. available for public review. According to the NRC It is interesting; however, that while the new release, “The U.S. Army Corps of EngineersAdministration has not announced how it would faces an ‘unsustainable situation’ in maintainingapproach the “waters of the US” issue in a second term, its national water projects at acceptable levels ofit has requested funding to support increased regulatory performance.” The report is available online:http://outreach in connection with the issuing of Guidance. www.nap.edu/catalog.php?record_id=13508>TWCA through its Federal Affairs Committee will need The report suggests expanding revenues andto understand what “new field level initiatives” are strengthening partnerships among the private and publicbeing considered in the FY13 budget. sectors as options to manage the Corps’ aging water In the past, the TWCA and its Federal Affairs infrastructure, which includes levees and dams. expressed a preference for working through a rule However, the NRC may be short on watermaking process on this issue with its transparency and resources planners and managers, its Committee chairstakeholder involvement. But the issuing of Guidance remarked, “The country’s water resources infrastructurewhich has been developed almost completely out of is largely built-out, and there are limited sites to constructthe public view but still has the force of a Rule would new projects.” Obviously, the chairman was not familiarbe very different scenario. with the Texas Water Plan! Steve Stockton also disagreed Senate Interior and Environment with this statement, “We tried to make it clear that while Appropriations Bill -- Omnibus Funding many of the major river systems have been developed, In late September, the Senate issued the FY there is a huge backlog of unmet water resource needs.2013 Interior and Environmental, the only remaining As the Nation grows, this backlog will continue to increasespending bill to be released. The House has completed unless we develop a sustainable strategy.”all its appropriation bills and cleared six through the full Texas Water Day 2013House; the full Senate has yet to take up any individual Planning is underway for Texas Water Day 2013spending bill. With all twelve appropriations bills in both is set for February 6-7, 2013. Mark your calendars andhouses, the effort to resolve issues between the House consider helping us put the final plans together by joiningand Senate versions can begin and perhaps lead to an the Texas Water Day Steering Committee. omnibus spending bill for consideration in the LameDuck. However, although preserving any mark-uparrangements omnibus spending bills are complex toput together, the spending levels may be too high forconservatives, and the White House may considerwaiting for the new Congress to potentially improvechances for funding the White House priorities. President Obama did sign a six month stop-gap funding measure (H J Res 117) to extend fundingthrough March 27th. Considering that the lame duck willface debates on the Bush tax cuts and how to deal withsequestration cuts, a year-long Continuing Resolutionmay result from all this, with the funding levels tied to thoseestablished in the Budget Control Act of 2011. Tom Ray In that Senate Interior Appropriations bill, EPA of Lockwood, Andrews &would receive $ 8.5 billion or about $100 million more Newnam, has followed nationalthan the current spending level. That increase will be a water issues for more than 20problem for House appropriators. The House bill cut years. He can be reached atEPA funding by 17 percent, citing criticisms of over- j-tray@lan-inc.com.regulation by the agency. 19
    • TWCA WELCOMES NEW MEMBERS City of College Station Contact: David M. Coleman,P.E. College Station, TX Water Quest, Inc. Contact: Wendy Gordon, Ph.D. Odessa, TX Offices of Marc A. Rodriguez Contact: Marc A. Rodriguez Austin, TX Fayette County Groundwater Conservation District Contact: David VanDresar LaGrange, TX EDITORIAL SERVICES... Barbara Payne 281-893-2099 barbara@paynecom.com20