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Administratively Complete
Management Plans:
By The Numbers
Robert G. Bradley, P.G., C.T.C.M
Groundwater Technical Assistance
Texas Alliance of Groundwater Districts
Leadership Training
Fort Stockton, Texas
November 6, 2017
1
*The following
presentation is based upon
professional research and
analysis within the scope of
the Texas Water
Development Board’s
statutory responsibilities
and priorities but, unless
specifically noted, does not
necessarily reflect official
Board positions or
decisions.
Robert G. Bradley, P.G., C.T.C.M
Groundwater Technical Assistance
Texas Alliance of Groundwater Districts
Leadership Training
Fort Stockton, Texas
November 6, 2017
Administratively Complete
Management Plans:
By The Numbers*The following presentation
is based upon professional
research and analysis within
the scope of the Texas Water
Development Board’s
statutory responsibilities and
priorities but, unless
specifically noted, does not
necessarily reflect official
Board positions or decisions.
2
The Basics
• Goals
– Performance standards
– Management objectives
• Estimates of groundwater conditions
• Water planning estimates
• Consideration of water supply needs and water
management strategies
• Must consider plan when making rules
• Plan is for 5 year period
• Need to update 2 years after DFC adoption
3
Nothing new under the sun.
• “to develop comprehensive plans for the
most efficient use of the underground water
of the underground water reservoir or subdivision
thereof and for the control and prevention of waste of
such underground water, which plans shall specify in
such detail as may be practicable the acts, procedure,
performance and avoidance which are or may be
necessary to effect such plans,
including specifications…”
4
HB 162 (1949)
1996
5
Background
• 1997 – Senate Bill 1
• 2001 – Senate Bill 2
• 2005 – House Bill 1763
6
2017
7
Management
plans must be
fun, just look at
all the districts!!
A few districts have left the game:
Harris-Galveston Subsidence District
Fort Bend Subsidence District
Edwards Aquifer Authority
Relax
• TWDB and TCEQ provide notice of plan due
• We provide data
• We offer pre-reviews to all GCDs
(sometimes several)
• We provide a
recommendation report
for pre-reviewed plans
– Required items
– Optional items
8
Timeline
• Nine months out
– Notification of plan due from TCEQ
• Six to nine months out
– notification of plan due and data packet
sent from TWDB
• Three months out
– Adopt plan at public hearing
• Two months
– Submit final adopted plan
• TWDB sends approval letter within 60 days
9
Goals
• providing the most efficient use of groundwater
• controlling and preventing waste of groundwater
• controlling and preventing subsidence
• addressing conjunctive surface water
management issues
• addressing natural resource issues
– that affect the use and availability of groundwater
– are affected by the use of groundwater
• addressing drought conditions
10
Shameless Plug
The vulnerability of each major and minor aquifer
in Texas to subsidence
• Research contract with LRE Water, LLC,
TWDB Contract No. 1648302062
• Provide tool to assess risk and monitoring
suggestions for groundwater conservation
districts with high risk
• Covers the entire state
– Except subsidence districts
• Final report due March 30, 2018
11
Goals
• addressing
– conservation
– recharge enhancement
– rainwater harvesting
– precipitation enhancement
– brush control
where appropriate and cost effective
12
Goals
• addressing desired future conditions
of aquifers
13
Note: All goals except
addressing desired future
conditions are as applicable.
Please clearly state if any goal is
not-applicable to your district.
Management Objectives
• Management objectives are specific and
time-based statements of future outcomes,
each linked to a management goal. Each
future outcome must be the result of actions
that can be taken by the district during the
five years following the effective date of the
adopted management plan
14
Performance standards
• Performance standards are indicators or
measures used to evaluate the effectiveness
and efficiency of district activities. Evaluation
of the effectiveness of district activities
measures the performance of the district.
Evaluation of the efficiency of district activities
measures how well district resources are used
to produce an output, such as the amount of
resources devoted for each management
action
15
Management Details
• Details of how the district will manage
groundwater supplies in the district, including
a methodology by which the district will track
its progress in achieving its management
goals.
16
Note: Annual reports are one
way to track and report
progress in achieving your
management goals.
Goal Example
Controlling and Preventing Waste of
Groundwater
• Objective:
The District will establish a monitoring well
network of 10 wells and will sample at least
five wells annually.
• Performance Standard:
The number of wells sampled on an
annual basis.
17
Methodology to Track Progress
• Example
– An annual report ("Annual Report") will be
created by the general manager and staff of the
District and provided to the members of the Board
of the District. The Annual Report will cover the
activities of the District including information on
the District's performance in regards to achieving
the District's management goals and objectives. A
copy of the Annual Report will be kept on file and
will be available for public inspection at the
District's offices upon adoption.
18
19
The Checklist
All required items are in the checklist
First page covers all of the required items
except management goals.
Items through
Second page covers the management goals
of the district
Located on the
TWDB Groundwater website
http://www.twdb.texas.gov/groundwater/
Tip: Include a filled in checklist as a part
of your management plan,
including page numbers.
20
The Checklist
1. Is an estimate of the modeled available
groundwater in the District based on the
desired future condition established under
Section 36.108 included?
If you decide to put a table of modeled
available groundwater in your plan text,
include all decades if the values change
through time.
Tip: Include this report as an appendix to
your management plan.
Note: Make sure if you create your own
tables, please double check the
numbers to match those we provide to
you. Proofread everything!
21
The Checklist
Items
Through
These are in groundwater conservation
district management plan model runs
provided by the TWDB.
Tip: Include this report as an appendix to
your management plan
Note: The groundwater district
management plan runs are simply
a water budget from groundwater
models, and are not based
on desired future conditions.
22
23
The Checklist
Estimated Historical Water Use
from the TWDB Historical
Water Use Survey
Projected Surface Water Supplies
Projected Water Demands
Projected Water Supply Needs
Projected Water Management Strategies
from the 2017 Texas
State Water Plan
Tip: Include this report as an appendix to
your management plan
24
The Checklist
Did the District consider and include
the water supply needs from the adopted
state water plan?
Did the District consider and include
the water management strategies from the
adopted state water plan?
These need a bit more discussion.
If you have groundwater strategies, consider
the impact they have on your groundwater
resource or district operations.
Yep, we
considered ‘em.
– Anonymous
Did the district include details of how it will
manage groundwater supplies in the district?
Are the actions, procedures, performance, and
avoidance necessary to effectuate the
management plan, including specifications
and proposed rules, all specified in as much
detail as possible, included in the plan?
25
The Checklist
Tip: Include a link to your rules in the
management plan.
Was evidence that the plan was adopted, after
notice and hearing, included?
Was evidence that, following notice and
hearing, the District coordinated in the
development of its management plan with
regional surface water management entities?
26
The Checklist
Evidence includes the posted agenda,
meeting minutes, and copies of the
notice printed in the newspaper(s)
and/or copies of certified receipts from
the county courthouse(s).
Evidence of coordination can be copies
of letters or emails transmitting your
management plan to the regional
surface water management entities.
Tip: Include a link to your rules in the
management plan.
TCEQ Water Districts Map Viewer
27
https://go.usa.gov/xn4rr
Has any available site-specific information
been provided by the district to the executive
administrator for review and comment before
being used in the management plan when
developing the estimates required under…
28
The Checklist
Note: Site-specific information to be
reviewed is related to those estimates
provided by TWDB Groundwater
Availability Modeling staff.
Submission
• Documentation that the plan was adopted
after posting notice
• One hard copy of the adopted
management plan
• One electronic copy of the adopted
management plan.
• Submit to TWDB Executive
Administrator by USPS
29
So your
plan can
be logged
in.
Amendments
• Submit any proposed management plan
amendments to the TWDB EA for
determination if amendment requires
approval.
• Can be amended plan or an addendum.
• Incorporation of DFC and MAG must be
adopted as an amendment.
30
Things to remember
• Communicate with TWDB staff
• Add TWDB supplied data as appendices
• Submit for pre-reviews approximately 4 to 5
months prior to expiration
• Be sure to share any TWDB management plan
communications with your consultant
31
Things to remember
• Adopt at a public hearing 90 days prior
to expiration
• Submit final management plan 60 days prior
to plan expiration
• TWDB has 60 days to approve plans
• After approval send copy of plan to regional
water planning group chair
32
Questions?
Stephen Allen
Management Plan Coordinator
512-463-7317
stephen.allen@twdb.texas.gov
Robert G. Bradley
Groundwater Management Area Liaison
512-936-0870
robert.bradley@twdb.texas.gov
33

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Fort Stockton MLT_ Administratively Complete Management Plans_Robert Bradley

  • 1. Administratively Complete Management Plans: By The Numbers Robert G. Bradley, P.G., C.T.C.M Groundwater Technical Assistance Texas Alliance of Groundwater Districts Leadership Training Fort Stockton, Texas November 6, 2017 1 *The following presentation is based upon professional research and analysis within the scope of the Texas Water Development Board’s statutory responsibilities and priorities but, unless specifically noted, does not necessarily reflect official Board positions or decisions.
  • 2. Robert G. Bradley, P.G., C.T.C.M Groundwater Technical Assistance Texas Alliance of Groundwater Districts Leadership Training Fort Stockton, Texas November 6, 2017 Administratively Complete Management Plans: By The Numbers*The following presentation is based upon professional research and analysis within the scope of the Texas Water Development Board’s statutory responsibilities and priorities but, unless specifically noted, does not necessarily reflect official Board positions or decisions. 2
  • 3. The Basics • Goals – Performance standards – Management objectives • Estimates of groundwater conditions • Water planning estimates • Consideration of water supply needs and water management strategies • Must consider plan when making rules • Plan is for 5 year period • Need to update 2 years after DFC adoption 3
  • 4. Nothing new under the sun. • “to develop comprehensive plans for the most efficient use of the underground water of the underground water reservoir or subdivision thereof and for the control and prevention of waste of such underground water, which plans shall specify in such detail as may be practicable the acts, procedure, performance and avoidance which are or may be necessary to effect such plans, including specifications…” 4 HB 162 (1949)
  • 6. Background • 1997 – Senate Bill 1 • 2001 – Senate Bill 2 • 2005 – House Bill 1763 6
  • 7. 2017 7 Management plans must be fun, just look at all the districts!! A few districts have left the game: Harris-Galveston Subsidence District Fort Bend Subsidence District Edwards Aquifer Authority
  • 8. Relax • TWDB and TCEQ provide notice of plan due • We provide data • We offer pre-reviews to all GCDs (sometimes several) • We provide a recommendation report for pre-reviewed plans – Required items – Optional items 8
  • 9. Timeline • Nine months out – Notification of plan due from TCEQ • Six to nine months out – notification of plan due and data packet sent from TWDB • Three months out – Adopt plan at public hearing • Two months – Submit final adopted plan • TWDB sends approval letter within 60 days 9
  • 10. Goals • providing the most efficient use of groundwater • controlling and preventing waste of groundwater • controlling and preventing subsidence • addressing conjunctive surface water management issues • addressing natural resource issues – that affect the use and availability of groundwater – are affected by the use of groundwater • addressing drought conditions 10
  • 11. Shameless Plug The vulnerability of each major and minor aquifer in Texas to subsidence • Research contract with LRE Water, LLC, TWDB Contract No. 1648302062 • Provide tool to assess risk and monitoring suggestions for groundwater conservation districts with high risk • Covers the entire state – Except subsidence districts • Final report due March 30, 2018 11
  • 12. Goals • addressing – conservation – recharge enhancement – rainwater harvesting – precipitation enhancement – brush control where appropriate and cost effective 12
  • 13. Goals • addressing desired future conditions of aquifers 13 Note: All goals except addressing desired future conditions are as applicable. Please clearly state if any goal is not-applicable to your district.
  • 14. Management Objectives • Management objectives are specific and time-based statements of future outcomes, each linked to a management goal. Each future outcome must be the result of actions that can be taken by the district during the five years following the effective date of the adopted management plan 14
  • 15. Performance standards • Performance standards are indicators or measures used to evaluate the effectiveness and efficiency of district activities. Evaluation of the effectiveness of district activities measures the performance of the district. Evaluation of the efficiency of district activities measures how well district resources are used to produce an output, such as the amount of resources devoted for each management action 15
  • 16. Management Details • Details of how the district will manage groundwater supplies in the district, including a methodology by which the district will track its progress in achieving its management goals. 16 Note: Annual reports are one way to track and report progress in achieving your management goals.
  • 17. Goal Example Controlling and Preventing Waste of Groundwater • Objective: The District will establish a monitoring well network of 10 wells and will sample at least five wells annually. • Performance Standard: The number of wells sampled on an annual basis. 17
  • 18. Methodology to Track Progress • Example – An annual report ("Annual Report") will be created by the general manager and staff of the District and provided to the members of the Board of the District. The Annual Report will cover the activities of the District including information on the District's performance in regards to achieving the District's management goals and objectives. A copy of the Annual Report will be kept on file and will be available for public inspection at the District's offices upon adoption. 18
  • 19. 19 The Checklist All required items are in the checklist First page covers all of the required items except management goals. Items through Second page covers the management goals of the district Located on the TWDB Groundwater website http://www.twdb.texas.gov/groundwater/ Tip: Include a filled in checklist as a part of your management plan, including page numbers.
  • 20. 20 The Checklist 1. Is an estimate of the modeled available groundwater in the District based on the desired future condition established under Section 36.108 included? If you decide to put a table of modeled available groundwater in your plan text, include all decades if the values change through time. Tip: Include this report as an appendix to your management plan. Note: Make sure if you create your own tables, please double check the numbers to match those we provide to you. Proofread everything!
  • 21. 21 The Checklist Items Through These are in groundwater conservation district management plan model runs provided by the TWDB. Tip: Include this report as an appendix to your management plan Note: The groundwater district management plan runs are simply a water budget from groundwater models, and are not based on desired future conditions.
  • 22. 22
  • 23. 23 The Checklist Estimated Historical Water Use from the TWDB Historical Water Use Survey Projected Surface Water Supplies Projected Water Demands Projected Water Supply Needs Projected Water Management Strategies from the 2017 Texas State Water Plan Tip: Include this report as an appendix to your management plan
  • 24. 24 The Checklist Did the District consider and include the water supply needs from the adopted state water plan? Did the District consider and include the water management strategies from the adopted state water plan? These need a bit more discussion. If you have groundwater strategies, consider the impact they have on your groundwater resource or district operations. Yep, we considered ‘em. – Anonymous
  • 25. Did the district include details of how it will manage groundwater supplies in the district? Are the actions, procedures, performance, and avoidance necessary to effectuate the management plan, including specifications and proposed rules, all specified in as much detail as possible, included in the plan? 25 The Checklist Tip: Include a link to your rules in the management plan.
  • 26. Was evidence that the plan was adopted, after notice and hearing, included? Was evidence that, following notice and hearing, the District coordinated in the development of its management plan with regional surface water management entities? 26 The Checklist Evidence includes the posted agenda, meeting minutes, and copies of the notice printed in the newspaper(s) and/or copies of certified receipts from the county courthouse(s). Evidence of coordination can be copies of letters or emails transmitting your management plan to the regional surface water management entities. Tip: Include a link to your rules in the management plan.
  • 27. TCEQ Water Districts Map Viewer 27 https://go.usa.gov/xn4rr
  • 28. Has any available site-specific information been provided by the district to the executive administrator for review and comment before being used in the management plan when developing the estimates required under… 28 The Checklist Note: Site-specific information to be reviewed is related to those estimates provided by TWDB Groundwater Availability Modeling staff.
  • 29. Submission • Documentation that the plan was adopted after posting notice • One hard copy of the adopted management plan • One electronic copy of the adopted management plan. • Submit to TWDB Executive Administrator by USPS 29 So your plan can be logged in.
  • 30. Amendments • Submit any proposed management plan amendments to the TWDB EA for determination if amendment requires approval. • Can be amended plan or an addendum. • Incorporation of DFC and MAG must be adopted as an amendment. 30
  • 31. Things to remember • Communicate with TWDB staff • Add TWDB supplied data as appendices • Submit for pre-reviews approximately 4 to 5 months prior to expiration • Be sure to share any TWDB management plan communications with your consultant 31
  • 32. Things to remember • Adopt at a public hearing 90 days prior to expiration • Submit final management plan 60 days prior to plan expiration • TWDB has 60 days to approve plans • After approval send copy of plan to regional water planning group chair 32
  • 33. Questions? Stephen Allen Management Plan Coordinator 512-463-7317 stephen.allen@twdb.texas.gov Robert G. Bradley Groundwater Management Area Liaison 512-936-0870 robert.bradley@twdb.texas.gov 33

Editor's Notes

  1. Plans for GCDs were required from the beginning, so there is nothing new under the sun. 1949 HB 162 (Underground Water Conservation District Act) to develop comprehensive plans for the most efficient use of the underground water of the underground water reservoir or subdivision thereof and for the control and prevention of waste of such underground water, which plans shall specify in such detail as may be practicable the acts, procedure, performance and avoidance which are or may be necessary to effect such plans, including specifications… 1971 HB 343 (codification of the Water Code) May develop comprehensive plans 1973 HB 935 Added controlling and preventing subsidence 1989 SB 1212 Changed to a comprehensive management plan and required public participation
  2. 1997 – Senate Bill 1 Provided the contents required for management plans Provided for the TWDB to certify management plans if administrative complete State Auditor to determine if districts were implementing management plans And TNRCC (now TCEQ) to ensure GCD compliance Required consistency with regional planning 2001 – Senate Bill 2 Added drought conditions and conservation goals Required plan to be developed using district’s best available data Forward to regional water planning group for consideration in their planning process Required use of groundwater modeling information provided by TWDB 2005 – House Bill 1763 TWDB approves management plans. Added recharge enhancement, rainwater harvesting, precipitation enhancement, or brush control, where appropriate and cost-effective; as management goals. Addressing in a quantitative manner the desired future conditions of the groundwater resources. Regional Planning to use GCD management plans
  3. Definitions from TWDB Administrative rules: Most efficient use of groundwater: Practices, techniques, and technologies that a district determines will provide the least consumption of groundwater for each type of use balanced with the benefits of using groundwater. Waste defined by Chapter 36 or district rules. Subsidence, typically thought of at the Texas Gulf Coast, but TWDB is funding a contract with LRE Water for tools to determine risk of subsidence throughout the state. Conjunctive surface management issues: Issues related to conjunctive use such as groundwater or surface water quality degradation and impacts of shifting between surface water and groundwater during shortages. Natural resources issues: Issues related to environmental and other concerns that may be affected by a district's groundwater management plan and rules, such as impacts on endangered species, soils, oil and gas production, mining, air and water quality degradation, agriculture, and plant and animal life. Drought conditions: No explanation necessary, except aridity is not the same as drought.
  4. Recharge enhancement--Increased recharge accomplished by the modification of the land surface, streams, or lakes to increase seepage or infiltration rates or by the direct injection of water into the subsurface through wells. These five items are applicable if appropriate and cost effective.
  5. Management objectives are specific and time-based statements of future outcomes, each linked to a management goal. Each future outcome must be the result of actions that can be taken by the district during the five years following the effective date of the adopted management plan;
  6. Performance standards are indicators or measures used to evaluate the effectiveness and efficiency of district activities. Evaluation of the effectiveness of district activities measures the performance of the district. Evaluation of the efficiency of district activities measures how well district resources are used to produce an output, such as the amount of resources devoted for each management action;
  7. Details of how the district will manage groundwater supplies in the district, including a methodology by which the district will track its progress in achieving its management goals. At least one goal must be tracked on an annual basis; however, other goals may be defined and tracked over a longer time period as appropriate
  8. Modeled Available Groundwater--The amount of water that the executive administrator determines may be produced on an average annual basis to achieve a desired future condition.
  9. Surface water management entities--Political subdivisions as defined by Texas Water Code Chapter 15 and identified from Texas Commission on Environmental Quality records that are granted authority under Texas Water Code Chapter 11 to store, take, divert, or supply surface water either directly or by contract for use within the boundaries of a district.
  10. The required final submission has to include: one hard copy of the adopted management plan, one electronic copy of the adopted management plan, and documentation that the plan was adopted after notice posted in accordance with Texas Government Code Chapter 551, including a copy of the posted agenda, meeting minutes, and copies of the notice printed in the newspaper or publisher's affidavit. The plan or revised plan under §356.54 of this subchapter (relating to Approval) shall be considered properly submitted to the executive administrator when all of the items specified in subsection (a) of this section are received by the executive administrator.
  11. (a) If the district proposes to amend its plan for revisions of items other than the modeled available groundwater or desired future condition, the district shall submit a written copy of the proposed amendment to the executive administrator so that the executive administrator may determine whether the amendment requires approval. (b) If the executive administrator determines that the amendment requires approval, the district shall submit all amendments to the management plan developed under §356.52 of this subchapter (relating to Required Content of Management Plan) to the executive administrator within 60 days of adoption of the amendment by the district's board. Amendments shall be submitted either in the form of an addendum to the management plan or as changes highlighted within the entire management plan. (c) If the amendments address items required by Texas Water Code §36.1071, they should be in the form of an amended plan instead of an addendum to avoid confusion and preserve the integrity of the plan. Amendments must be submitted in accordance with §356.53 of this subchapter (relating to Plan Submission). Incorporation of newly developed desired future conditions and modeled available groundwater values must be adopted as an amendment.