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SYSTEM OPERATION PERMIT AND WATER MANAGEMENT PLAN

This page hosts questions, answers and comments on the Water Management Plan as they are received from the public. The BRA will no longer be taking questions/comments on the Water Management Plan now that it has been submitted to the Texas Commission on Environmental Quality. To make a comment or for general or other BRA related questions, click here.

Submitted, November 16 by Diana

I was hoping to get water back. I live on cliffview [sic] and have no water in 5 months that's not why i [sic] got this house so please let me no [sic] ????? When do I get the water back ??? Right on the back side of lake no lake water view ????
Thank you


We understand your frustration. Unfortunately, lake levels are highly dependent on flows in the Brazos River created by rainfall. BRA's reservoirs (Possum Kingdom, Granbury and Limestone) were built specifically to store water to be used by municipalities, industry and agriculture. In order to continue to provide drinking water, electricity and food to the region, the water must be used for its intended purpose. The watershed that funnels rainfall into the Brazos River and consequently into our northern most reservoirs remains classified as severe to exceptional drought (click here for drought status) and has been under drought conditions for the past 24 months.

If you specifically purchased your home for a beautiful view, you should keep in mind that drought conditions will not continue indefinitely. It will rain again and the reservoirs will refill. But lake levels will continue to fluctuate as long as there is a need for drinking water, electricity and food.

Submitted, November 7 by Jim Boots

Comment
Your website says that you are "self-supporting using revenues from the customers you serve." I have a dock on open-water on lake Granbury which makes me a customer. My dock has been unusable i.e. my boat is stuck since August (for the second year in a row). The only thing I am being served is a big plate of greed and mismanagement by the BRA. Why don't you come out and say what everyone else already knows? You are a for-profit entity that is focused on the bottom line; not "serving customers".

I do like how you selectively choose to serve some customers so they can replace water lost due to evaporation (isn't replacing water due to evaporation redundant and wasteful?).

Come on guys! We know that you are proud of being the "first State agency" of your kind but you can't live in the past forever. Did you know that the year the BRA was created was the same year that the car radio was invented? And, have you heard about satellite radio? It is music from outer space! Change is good!

All we are asking is that you sincerely consider the needs and financial interests of ALL of your customers and not just the ones that sign big water contracts like, I don't know, Luminant!?

I have more to write but my Brother-in-law asked me to come over and help him mow the grass in his canal (no joke).

Submitted, October 16 by Steve Fortner

I read that 5.9 million acre feet of water flows from the Brazos River into the Gulf every year. Why can't you capture it downstream before it flows into the Gulf and pump it back upstream? It seems like BRA has mismanaged the water to let that much water go to waste. Why does BRA deserve to manage even more water?

Capturing water before it flows into the Gulf is exactly what BRA is trying to do by applying for this permit; obtain the right to capture and use some of that water. Transporting water is possible with pipelines and pumping stations, but to transport it from the Gulf at sea level back upstream would have very high pumping costs. One project currently in the works to capture some of that water is the Allens Creek Reservoir. Along with our partners, the BRA is hoping to start construction on the reservoir in the next 10 years. Allenís Creek Reservoir will capture approximately 150,000 acre feet of water.

Submitted, October 16 by Frank Williamson

There is no way BRA's numbers are right, particularly the figure that the lake is 98% full. 2012 has been a normal rainfall year, and the lake is nowhere near being 98% full. How can BRA sell more water when there's not enough now? It seems like revenue generation is your primary concern, not water management. There are 3,800 docks at $30,000-40,000 per dock, but no water.

Lake Granbury has not been 98 percent full since May 2012 and BRA has made no representation otherwise. To view levels, click here. While the lake is not full, it does contain sufficient water to continue to meet the water supply needs for which it was originally constructed.

You are correct that there has been rain in this area, but there hasn't been much rain north of here (in the upper part of the basin) which affects lake levels here, too.

BRA's mission is to develop, manage and protect the water resources of the Brazos River to meet the needs of Texas, and the revenue we generate is used to accomplish that mission.

Submitted, October 16 by Jack Cathy

Comment
My concern is the environmental aspect. I don't need constant flow all the time, but the environment does. The environmental studies appear to have been done without anybody actually coming to the river to study it. I would encourage you to send someone to study it.

Submitted, October 16 by Joe Williams

1) How much water is available to be released out of PK?
2) Will the additional 70,000 acre feet sold come out of PK?
3) In a worst case scenario, how much lower will PK be? Will Lake Granbury be 4-5 feet lower than PK?
4) When will the pipe through PK be complete?
5) Will BRA release the same amount of water that it was releasing when the hydroelectric facilities were in operation?

1) The TCEQ model shows that about 280,000 acre feet/year is currently available from PK. BRA's existing water right permit for PK is for approximately 230,000 acre feet/year.
2) This question refers to the additional net amount needed to meet the expected future needs at Comanche Peak Nuclear Power Plant. BRA will follow the adopted PK-Granbury-Whitney Water Management Study drawdown protocol for making releases from PK. To view this study, click here.
3) Assuming the Comanche Peak expansion occurs in the 2020-2030 decade, in a worst case scenario the BRA expects that PK would be 3-4 feet lower than it would be in the absence of the expansion. No, Lake Granbury will not be lower than PK.
4) November 2012.
5) No, BRA will release water in accordance with the adopted 2011 PK-Granbury-Whitney Water Management Study. These releases would be as needed to meet downstream water supply requirements, environmental flow needs, and to pass flood water.

Submitted, October 16 by Raymond Haynes

Who controls the BRA? What can be done to change BRA? Do BRA revenues go back to the State?

There are several layers of accountability. The BRA is accountable to a 21-member Board of Directors that is appointed by the governor; to the legislature who codified enabling statutes into the law and can change those statutes as they see fit; to customers and bond holders; and to the TCEQ which has regulatory authority over the use of water right permits. BRA does not remit funds to the State of Texas other than fees related to regulatory requirements.

Submitted, October 16 by Grady Handcock

BRA needs to create a chart showing lake levels now compared to what they will be under BRA's proposal. When Lake Granbury filled up early this year, BRA released so much water that the level got low again. Why did BRA keep releasing water? In the slide regarding financial impact, I did not see the impact on a city like Granbury that is based around the lake. If there is no water, property values will decline and there will be no Granbury.

BRA has produced various charts of this type. You may find a sample in the PK-Granbury-Whitney Water Management Plan here (page 16).

Lake Granbury filled in January 2012, and remained full into May 2012. For a chart, click here. The elevation began to slowly decline in June 2012 due to reduced inflows, local customer water use, evaporation, and environmental flow releases.

BRA has not performed detailed local financial impact analysis on any individual community within the basin, as BRA provides water from all its water supply reservoirs to meet municipal, industrial, and agricultural needs to the entire basin. BRA's presentation on financial impact dealt with the losses due to not meeting the needs identified in the State Water Plan.

Submitted, October 16 by Paul Parker

Why is BRA taking water out of Lake Granbury and sending it to Lake Whitney? Does BRA release water out of Granbury just because PK is lower?

BRA is not taking water out of Granbury to send it to Lake Whitney. The only releases out of Lake Granbury for the past several months have been to meet downstream environmental flow requirements. No, BRA does not release water out of Granbury just because PK is lower.

Submitted, October 16 by Neil Carroll

Comment
I am concerned about the aquifers not being replenished as much as expected and concerned how we are going to sustain the population of Texas if we don't have water for agriculture to produce the food we need. It is frustrating for BRA to tell us we cannot pump water from our own property for irrigation, and then just watch the water evaporate.

Submitted, October 16 by Michele Mulloy

I am concerned about the level of the river. What little water that is being released is not making it down to me, despite what you say the gauges read. Have the water studies been completed?

The water studies are long term to monitor fish, mussels, aquatic plants, etc., and will take up to five years to complete. Water quality monitoring is ongoing by the BRA through the Texas Clean Rivers Program with monthly samples taken and results made available through regular reports on our website. Click here. The sampling thus far has shown no impairment to water quality.

Regarding the river level, the BRA checks the gauges periodically to make sure they are working properly. Lately, instead of releasing a low flow all day, a much higher flow has been released for only an hour and a half a day.

Submitted, October 16 by Rick Kenle

1) Is the goal of the SysOps permit to sell more water
2) To whom?
3) What is the lowest the reservoirs could be under the worst case scenario models?
4) Is there more water than BRA is currently permitted to sell?
5) What percentage of BRA's water rights are senior?
6) Where is the 100,000 acre feet from this region going to go?


1) The end result of the System Operation permit is to have the ability to provide water in accordance with the State Water Plan.
2) There is a waiting list of customers both within this region as well as downstream, including Luminant and other municipalities, as documented in the State Water Plan.
3) The slides from the October presentation provide information on worst case scenarios. Click here (see page 12).
4) Yes, according to the TCEQ Water Availability Model, there is more water in the Brazos basin than currently permitted.
5) The seniority of BRA's water rights is based on the date on which they were issued. BRA has multiple water rights that may be senior to other water rights in the basin, as well as those that may be junior to other water rights in the basin.
6) According to the State Water Plan, the water would be committed primarily to the Luminant expansion at Comanche Peak.

Submitted, October 16 by Charles Peoples

In Austin, the BRA said it would take 2 years to do a proper WMP. How have you done it in about 9 months?

When BRA applied for the permit in 2004, it was understood that a WMP would be necessary before a drop of water was used. The BRA was also aware that the WMP would only be useful if the parameters of the permit were known. It was expected a longer time period would be allotted; however, in January the TCEQ set a ten month deadline. The BRA staff and consultants have been working extremely hard to complete the WMP in that timeframe.

Submitted, October 16 by Mark Grella

Will the PK/Lake Granbury balancing protocol be a part of the formal WMP? How do I challenge the assumptions made by BRA in the study to determine that drawdown ratio? Perhaps it would be better if an impartial judge or jury decided what definition of "fair" to use.

The drawdown ratio will be documented and discussed in the technical report in support of the Water Management Plan.

When the study was done, the BRA discussed what is "fair" and what assumptions should be made at public meetings at PK and Granbury. If you disagree with those assumptions, the issues may be raised with TCEQ and at SOAH.

Submitted, October 16 by Lisa Easterling

We are required to pay dock fees even when our dock are unusable on dry land. Would the BRA consider prorating the dock fees when the docks are unusable?

Your contract probably states that lake levels will fluctuate up to 18 feet. BRA has considered prorating dock fees and has chosen not to do so at this time; however, this does not preclude the issue from being considered in the future.

Submitted, October 22 by Frank Rembert

How will this revised water plan affect lake levels in existing reservoirs? Many Texas residents and taxpayers have invested significant financial assets in both recreational and residential properties on BRA Reservoirs, if this new WMP changes water levels in these reservoirs and negatively affects the values of these properties, is the BRA prepared to financially compensate these property owners?

Lake level impacts have been discussed extensively at each of the Stakeholder Meetings, especially those at Granbury, Possum Kingdom, and Glen Rose. With or without approval of the pending permit, BRA's water supply reservoirs are expected to fluctuate to a greater degree with increased water use in the future. Links to the videos of those meetings may be found here.

The BRA has no plans to compensate lakeside property owners as a result of legally permitted lake management and water supply operations. The reservoirs operated by BRA have never been nor will they ever be constant level and the BRA has attempted to make that clear on multiple occasions over the years. Likely the most readily available proof of our efforts to inform lakeside property owners exists in our standard dock and on-water facility permit. If you have a dock, your permit contains a section indicating that the lake is used for water supply and therefore lake levels will fluctuate. Our hope is that individuals purchasing lakefront property educate themselves as to the true operational nature of the lake before making their decision to buy and that local realtors properly inform them of the same.

Submitted, October 21 by Paul Garraway

Does the BRA currently (or in the past) contribute to Political Action Committees or campaign funds of local or State representatives? If yes please name recipients.

No, BRA does not contribute to Political Action Committees or campaign funds of local or state representatives.

Submitted, October 20 by James M. Moore

1) how much money does BRA collect for selling water?
2) Where does that money go? Who? Where? Why?
3) how much money does BRA collect from boat lifts/houses? and where does that money go, Who, Where? Why? and
4) Why did our property lines come to water's edge for this lake and not PK or Whitney if it wasn't intended to be a constant level lake!

COMMENT: I own waterfront on a canal in Indian Harbor. For two years, I haven't been able to use my boat due to low water level. Additionally, I've lost $50,000 of home value due to the lake's low level. I'm a member of LGWOA, and I pray they get this lake filled back up permanently.


In answer to questions one - three, in Fiscal Year 2012 the BRA generated $32.8 million in total water sales and $852,000 in dock and on-water facility fees. All income generated by the BRA goes toward operations (water supply, water and wastewater treatment, and environmental monitoring programs) and the creation of new water supplies to meet future needs in the basin.

BRA produces an annual budget which is reviewed and adopted by the Board of Directors in open session. A copy of the FY 2013 Budget may be reviewed here. BRA is also audited annually by an outside auditor. A copy of the audit of FY 2011 may be reviewed here.

4. Property lines do not come to the lake's edge at Possum Kingdom due to the restrictions in BRA's license to produce hydroelectric power issued by the Federal Energy Regulatory Commission (FERC). Lake Whitney is owned and operated by the US Army Corps of Engineers (USACE) for flood control, hydroelectric, and water supply purposes. Since an area around the normal pool elevation of Lake Whitney is reserved for inundation by flood waters, USACE does not allow permanent structures in that area. Lake Granbury is neither subject to FERC regulation since there is not a hydroelectric generating plant at the dam, nor does it have a flood pool; therefore, neither restriction applies to Lake Granbury.

With regard to Lake Granbury, the lake has never been nor will it ever be a constant level lake (although this rumor has existed around the lake for decades despite BRA's continual objections). This lake is a water supply lake and is used to catch water when it rains so it may be used during dry times. The fact that property lines come to the water's edge is not relevant to the lake's intended purpose.

Submitted, October 16 by Mark Grella

I have reviewed in some detail the BRA study May 2011 generalPdf/Water-Management-CompletedStudy.pdf that is the basis of the current 1.75:1 reservoir draw down rate. I give the BRA credit for a thorough analysis on potential shoreline facility impacts at various drawdown rates for PK and LG. As is the case in any of these type analyses, the devil is in the details.

They make a couple very important assumptions that I would challenge and I suggest the LGWOA, City of Granbury and the County should challenge. If changed the potential impact to the draw down rates are significant. By my rough calculations we would have an additional 1.5 feet of water today using a 3.2:1 draw down rate.

The two assumptions are how to define "fair" impacts to both lakes and the depth of water used to determine if docks are usable. The BRA defined "fair" as equal % impacts to shoreline facilities at both lakes. Using their charts (appendix page c-1 and c-2) they would project approximately 500 unusable docks at PK and 1250 unusable here at Lake Granbury at today's lake levels. This is close to an equal % impact best I can tell. PK has an estimated total of 1,480 (93% floating) residential docks and Granbury has 3,007 (98% fixed, see page 10).

Their definition of "fair" works if both lakes had the same number of docks (assuming all of the docks cost about the same to build and maintain). However, the dock counts are dramatically different between the two lakes. Lake Granbury has more than twice the number of docks and twice the investment by residents in them. Based on capital investment in docks the proper definition of "fair" should be a redefined as "a dock for a dock". A dock at Granbury should be treated as equal to a dock at PK.

Furthermore, the existing definition used by the BRA doesn't pass the pressure test of the extremes. All assumptions of this nature should be tested at the extremes to see if they work and make sense. For instance, if PK had only 2 docks and we had our 3,007 then when 50% of PK docks (1 dock) were out of service you would draw down lake Granbury until 1,504 (50% of ours) docks were also out of service. That just doesn't make economic sense by any standard.

On a "dock for dock" definition basis when PK has 500 docks out of service (today's lake level) we in Granbury should have no more than 500 docks also out of service. At today's lake level at PK (992) the BRA would need to raise our lake level by about 1.5 feet to achieve that result. The resulting draw down rate would be 3.2:1 instead of 1.75:1.

Their assumption on how deep water needs to be for a dock to be useful (2 feet under the dock) works for floating docks but not always on fixed docks. When lake levels are only marginally low this assumption doesn't matter. However, in drought conditions when lake levels are 3 feet low or more (regardless of draw down rates) floating docks remain usable if they have 2 feet of water under them and fixed docks become dangerous or even impossible to use. Most fixed docks have limited lengths of cable to lower boats as well as reachable access to winch controls and dock decking. My dock runs out of cable when the lake is at 4 feet low and feels unsafe at 3 feet low. Changes should be made in their modeling to reflect these facts. As an example, "all docks are defined as useful if they have up to 2 feet of water under them for lakes levels up to 3 feet low, for levels below 3 feet low only floating docks with 2 feet of water are usable". This change would significantly change the impacts to Lake Granbury when projecting beyond 3 feet low water levels (see appendix c-1). This may also change the thinking of draw down rates when PK drops below 992. Today after PK drops below 992 the draw down rate goes to 1:1 (see last page of attached).

Combine my thinking of changing 2 assumptions with acknowledgment that PK has 4 times the water, twice the surface area and twice the depth may make a compelling argument with the BRA and other regulatory bodies. I believe these assumption changes could be incorporated into the modeling done by the consulting firm originally hired by the BRA for a nominal fee. This request, and payment for, could come from the BRA, the City of Granbury, the County or the LGWOA.

All of this may have already been discussed by all the interested parties but I wanted to share my thoughts.


This topic was thoroughly discussed in a lengthy question and answer session at the Stakeholder Meeting held in Glen Rose on Tuesday October 16, 2012. Rather than restate the full discussion, interested parties may view the dialog here. The information regarding the Lake Whitney-Granbury-Possum Kingdom Water Management Plan begins at marker 2:00:00.

Submitted, October 16 by Pauline Steavie

Why do you have contracts to provide water to a ski lake?

The Brazos River Authority's Raw Water Sales Policy defines the selling preference of the BRA and utilizes Section 11.024 of the State Water Code as a guide as shown on slide eight during the October 16th presentation. At the time of request for a water contract, the Brazos River Authority was able to meet the demand and still meet other requests for water in accordance with its policies and procedures.

The 90 acre-foot raw water agreement for the Lakes at Timber Cove is utilized for varied purposes; water is used to maintain three community parks, watering of 44 lots, and replace water lost to evaporation.

Submitted, September 28 by Lee & Cindy Shifflett

Comment
You cannot keep blaming someone else. In 2007 the BRA shut down the Morris Shepherd Hydroelectric Plant at Possum Kingdom. This plant provided 190,000 acre ft downstream to Lake Granbury. At first, the BRA said it was closed due to maintenance. After a year or so, the BRA decided to start the decommissioning process. In 2005, the BRA was issued bonds in the amount of $12 million dollars for the Morris Shepherd hydroelectric plant to perform the needed repairs and have the power plant operational again. What happened? Will we ever have our 190,000 acre ft back each year? The below article actually identifies how the flow of water from this power plant kept the water levels almost constant.

See story: http://darrenyancy.com/2010/07/03/the-brazos-river-authority-all-excuses-for-inaction-washed-away/

The BRA continually wants to blame evaporation, lawn sprinkler usage, and mother nature for all their woes. If everyone in Granbury turned on their sprinkler systems at the very same time no one would even notice a blip in the water level. Evaporation is a natural occurrence. It happens in your pools, etc if you happen to have one. The BRA is a major cause in these problems. Shutting down Morris Shepherd, selling excessive water from the Brazos River Basin, and having a ridiculous drawdown between PK and Lake Granbury has caused more trauma on our lakes and streams than any amount of evaporation would ever have.

Again, let's get on the same page and same team and stop this nonsense and make Granbury the preferred location of choice to live in and visit.

Submitted, September 28 by Joe Williams

Comment
In 2007 the BRA shut down the Morris Shepherd Hydroelectric Plant. This plant provided 190,000 acre ft downstream to Lake Granbury. At first, they said it was closed due to maintenance. After a year or so, the BRA decided to start the decommissioning process. In 2005, the BRA was issued bonds in the amount of $12 million dollars for the Morris Shepherd hydroelectric plant BUT that bond money was never fully used. According to the BRA in 2010, there was still 3.8 million dollars of the bond money still sitting in their account. Where is that money now? Why was it never fully used if it was not intended for Morris Shepherd? Will we ever have our 190,000 acre ft back each year?

Submitted, September 27 by Gary Cobb

Regarding your very evasive answer to my question on September 19, why can we not bid on the water? You stated it needed to be used for beneficial purposes. Would keeping the schools and businesses open around the lake at PK not fall under that category?

For BRA to consider a major, long-term sale of water (which we believe correctly categorizes the intent of your question), the need for that water should be recognized in the State Water Plan. There are no recommendations in the current State Water Plan for water to be sold or supplied to keep water supply reservoirs at or close to full for recreational purposes. Therefore, the basic answer to your question is no, because the needs are not recognized in the State Water Plan.

Going further, if the State Water Plan were amended to recognize this need, which would be required by BRA before entering into a long-term contract for sale, it would still have to compete with other beneficial uses for priority, as stipulated in Section 11.024 of the Texas Water Code. Note that water for recreation and pleasure ranks below other beneficial uses such as water for domestic and municipal purposes as well as agricultural and industrial uses. Lastly, if water was ultimately purchased with the intent of keeping the reservoir full, its success would be limited because other contract holders would continue to use water available to them from BRA's Water Supply System.

BRA customers do not bid on water. BRA sells water at the same rate to all of its System Rate customers. The current System Rate is $62.50/acre-foot per year. For agricultural irrigation, the rate is $43.75/acre-foot per year.

Submitted, September 21 by Lee & Cindy Shifflett

Comment
Your comments to Mr. Garraway are very troubling. You are hanging your hat on a letter from 1969 when the lake was originated. This shows very narrow vision on the part of the BRA. EVERYTHING evolves. Our great state and nation did not start out as we see it now. It appears the BRA would rather see a great city and community like Hood County stymied economically than help it prosper. Find another community on the lake that supports more population or business. Find another lake in you jurisdiction that supports 3 power plants, one of which is nuclear. Everyone knows the Lake is the major tourist attraction for Granbury and Hood County. Why make it a seasonal time. Help it become the recreational lake of choice. Help us, stop hurting us!!! Lake Granbury has the largest population to support, and the most major utilities to support with the least amount of water of all the lakes in the upper basin. You guys have rode this pony into the ground. time to give it a rest. It's time to revisit what has been done in the past and recently and add in all the factors.

Submitted, September 20 by Ann Meyer

Re: Jim Littlefield's question dated 9/13/12. Your reply didn't answer his first question which was "Is it not true that the BRA, in this upcoming TECQ meeting, will request additional water for sale for a grand total of one million acre-feet per year?" Your answer covered historical data when his real concern, and that of so many, is the intentions going forward.

The historical data did answer Mr. Littlefield's question. No, the BRA will not be requesting an additional 1 million acre-feet of water at any upcoming TCEQ meeting. The water requested in the original permit application submitted in June 2004 is the only water the BRA is currently requesting. There is not an additional request.

Submitted, September 19 by Gary Cobb

If a company was formed by the residents of PK, could we bid on the water just like the people you are planning on selling it to?

BRA has never been asked to sell water for a non-consumptive purpose. BRA traditionally has sold water in accordance with the State of Texas Water Code Section 11.024 to entities which put the water to a beneficial use.

Submitted, September 14 by Dave Rogers

Comment
The BRA was created by the Texas Legislature and can most certainly be abolished by that Legislature when enough angry voters decide to clean house and elect representatives that will pay attention to the devistation the BRA is causing to our communities. Be very careful BRA, your arrogance just may cost YOU your job.

Submitted, September 13 by Jim Littlefield

Is it not true that the BRA, in this upcoming TECQ meeting, will request additional water for sale for a grand total of one million acre-feet/year? If this is true why is The BRA asking for it if they don't intend to sell it? If the BRA does intend to sell it, no matter the time frame, I believe it is not only reasonable but necessary that the BRA provide visibility of the effects on PK & GB, for the regional communities, the TECQ, the environment and the economy. Maybe the BRA should consider scaling back their request.

BRA has not made any changes to the amount of water requested in its original permit application submitted in June 2004. The original application included a request for both firm and interruptible water. The requested amounts of water were based on hypothetical modeling assuming all the water would be diverted at the Gulf of Mexico. BRA knew at the time of the request that a Water Management Plan would be required prior to any of the water being put to beneficial use, and that diversion of the water anywhere but at the Gulf would reduce the final amount available for sale. See pages 7 through 10, particularly the bottom of page 9, of the original application's supplemental information. Click here. The State Water Plan contemplates that BRA will sell approximately 125,000 acre-feet of firm water made available from the permit.

Submitted, September 13 by Paul Garraway

I have recently purchased a "canal front" home in the Islands neighborhood on Lake Granbury. Since May, I have seen the water level drop over 4ft and the canal become unnavigable to the main Granbury lake.

What considerations are being made in the Water Management Plan to take neighborhoods like the islands into consideration? People like me moving to lake Granbury are the future life blood of the community, without a more stable Lake Level I am sure people will gradually move away impacting the local economy.

I look forward to hearing your view and solutions for a more stable and hopefully higher water level.


Since you appear to be new to the area, BRA would like to make you aware of some of the background regarding the lake.

Lake Granbury was constructed, in cooperation with TXU (predecessor to Luminant), as a water supply reservoir to meet the needs of their electric generating facilities. The BRA reserved additional capacity in this water supply reservoir for the beneficial use of the stored water for municipal, industrial, and agricultural needs throughout the Brazos basin. The BRA has always stated that Lake Granbury is a water supply reservoir and that the level of the lake would fluctuate accordingly. A letter from the BRA archives dated September 25, 1969 indicates BRA's early concerns regarding expectations for the lake. Click here.

What we have witnessed at Lake Granbury over the past 16 months is associated with dry conditions in the watershed. Even though Lake Granbury did fill earlier this year, portions of the upper Brazos basin have remained dry. Conditions far upstream of Lake Granbury do have a direct impact on the lake level. Prior to May 2011, Lake Granbury was full for approximately 18 consecutive months.

BRA attempted to address the concerns of the lakeside community by preparing and adopting a PK-Granbury-Whitney Water Management Study in 2011 to balance adverse impacts between Lakes Granbury and Possum Kingdom during dry times. To learn more about this study, click here.

Submitted, September 13 by Jimmie Hackworth

I can tell that a great deal of research and scientific study went into preparing this report (http://www.brazos.org/SysOpsWeeklyUpdate.asp). I live on Lake Granbury and of course that is my primary concern, but I completely understand that PK and the Brazos between PK and GB have been in terrible shape over the past 5 years. Obviously this is due primarily to drought conditions, but I'm sure that it has to do even more with the elimination of the hydroelectric plant allowing a much stronger flow from PK in 2007 as well as the continued need for additional water at Comanche Peak.

Why was the hydroelectric plant at PK shut down? In this age of an emphasis on green energy, it just seems to make sense and would mean more water sent to GB. If part of the reason is that there just simply isn't enough water in PK to maintain a flow this large, then it seems that something should be done about that. Obviously the answer for this is that we need more rain above PK. Secondly, I'm wondering if the changes we've seen in the levels of PK and GB are temporary or permanent? I realize that this is a question that is impossible to answer, but there sure seems to have been a trend in the past 5 years.

Should this be the time for some desperate measures? Would it make sense to raise the water level at both lakes from the bottom and sides? It seems like huge amounts of dirt could be placed in the deeper portions of the lake and maybe even a series of locks to close off certain portions of the lakes on their sides. I guess my question is - should these lakes somehow be made smaller? The economic impact to both of these surrounding areas is tremendous. I know that city of Granbury will suffer tremendously if this low level of water continues.


The hydroelectric units at PK were placed out of service in 2007 due to the need for considerable expensive maintenance and repairs which could not be justified by the revenues received by BRA through an electric supply contract with a third party. A comprehensive analysis indicated that BRA's Water Supply System customers would have to subsidize the hydroelectric units if they were repaired and kept in operation. This decision was made following careful deliberation by BRA's Board of Directors.

In response to the change in water flow characteristics caused by PK becoming a purely water supply reservoir versus a combined hydropower/water supply reservoir, BRA undertook the study you refer to in order to ensure that the effects of water supply operations would be equally distributed between PK and Lake Granbury.

A considerable amount of what is being experienced at both water supply reservoirs is due to the prolonged drought situation which began in late 2010 and has not been completely resolved even today. Lake Granbury has responded better to rain events in its watershed than PK, primarily due to the geographic location of those rain events. However the Brazos basin is still experiencing significant drought conditions in the upper portion of the basin. As you point out, the real solution is more rain.

Submitted, September 10 by Mike Nickolaus

Since you just posted my comment without response, I ask again, would the BRA be willing to revisit the lake level ratio study for the purpose of including economic impact to the model and modifying the ratio accordingly to lower the disproportionate impact the current ratio has on Lake Granbury? I believe that the BRA's failure to include an appropriate economic impact analysis is a major oversight which must be corrected.

One further comment regarding the BRA's assertion that Lake Granbury should be at pool elevation at least 50% of the year. What you failed to tell people was that this includes winter when the lake might be at pool elevation 80% of the time and summer when it might be at pool elevation 20% of the time. Since recreational activity primarily occurs in the summer, having the lake at pool elevation most of the time in the winter doesn't do us much good.


As previously stated, there are no immediate plans to revisit the adopted PK-Granbury-Whitney Water Management Study, which did consider summer versus year-around conditions (see Section 5.0 of the PK-Granbury-Whitney Study here).

Submitted, September 8 by Jim Littlefield

I must have been unclear on my August 30 request because the answer was not what I thought I asked. So I will try to do better:

Please provide a chart: On the Y axis "Weighted Metric Percent Out-of Service." On the X axis "Downdraw (ft)."

Heading "Percent of Features Out-of-Service"

Based on the total one million acre ft/yr requested by the BRA.

1. Assuming it is completely sold and fully in use

2. Using the 1.75:1 and the other ratio as required,

3. Using water flow, history and the same parameters use in the "Water Management Study," for PK Lake, and for 2020 and 2060


BRA has stated that it does not anticipate selling 1 million acre-feet from the pending permit. We do not see the value of performing an analysis for a situation that is unrealistic.

Submitted, September 8 by Tom Limroth

There is a meeting in Glen Rose on October 16th. Where in Glen Rose is it being held? What is the agenda for this meeting??

The meeting will be held at the Somervell County Expo Center, 202 Bo Gibbs Blvd., Glen Rose, Texas 76043 on October 16, 2012 at 5:30p.m.

The agenda will involve a presentation on development of the Water Management Plan (WMP) to date, as well as a short introduction to the entire process for those who have not attended any of the prior meetings.

Submitted, September 7 by Penny Ranft

The Lower Colorado River Authority in the past years did exactly what the BRA is doing. Look at the water levels around Lake Travis.... it's devastating to the environment, the economy and to the people. What is going to prevent your request from ending up like the disaster from the LCRA?

The levels in the LCRA's water supply reservoirs are primarily the product of two events: 1) a prolonged drought in the Colorado Basin, and 2) those reservoirs performing the function for which they were constructed, which is water supply.

Droughts are beyond anyone's control, and water supply reservoirs are designed to catch and store water during wetter times, so that water is available when it is needed during drier times.

Submitted, August 31 by Mike Nickolaus

Comment
Your answer to my question about revisiting the lake level ratio's between PK and Granbury did not address the principal issue of economic impact. This should have been a consideration in the initial establishment of the ratios but was not. Regardless of the age of the study, it should be reviewed with these economic impact considerations included.

Submitted, August 31 by Joe Williams

In 2011 the BRA developed their new drawdown between Possum Kingdom and Lake Granbury to be 1.75 to 1 and when PK is 7 ft low the drawdown is 1:1.

In 2010 the Nuclear Regulatory Commission completed their Environmental Study. In their study the NRC concluded that with the addition of Comanche Peak 3 and 4, the additional reactors would need 60,000 ac ft. that would be withdrawn from Lake Granbury Their study concluded that the 60,000 ac ft needed (evaporated and lost) would lower the levels at PK another 12.5 ft. during drought conditions (Sec. 5-18). Drought conditions would be 2011 summer conditions. According to your own drawdown (1:1 under these conditions), this would also lower Lake Granbury by another 12.5 ft.

At the Lake Granbury BRA meeting, the BRA concluded that they would need another 160,000 ac ft to be actually sold and used by 2025. Using the 60,000 ac ft as a model for lake levels, how would another 100,000 ac ft in addition to the 60,000 ac ft. affect our lake levels on PK and Lake Granbury.

If you want to answer openly and with numbers, please do so. If you do not want to answer the question directly, do not answer at all.

Thanks


Page 5-18 of the August 2010 draft Environmental Impact Statement prepared by the Nuclear Regulatory Commission (NRC) includes a section entitled "Shoreline Habitat" that contains the following:

"Consumptive water use for cooling CPNPP Units 3 and 4 would cause lower lake levels at Possum Kingdom Lake and Lake Granbury, and decreased flows in the reach of the Brazos River between Lake Granbury and Lake Whitney (Luminant 2009a). Based on modeling of water use provided by Luminant (2009d), elevations in Possum Kingdom would be 1.3 ft. lower on average, and elevations in Lake Granbury would be 0.4 ft. lower due to Units 3 and 4 water consumption (Luminant 2009a). The maximum modeled change during periods of extreme drought in Lake Granbury is 2.5 ft., and during drought at Possum Kingdom Lake is 12.6 ft (Luminant 2010b)."

BRA is unaware of what assumptions were made regarding future operation of Lakes Possum Kingdom and Granbury in the NRC study. This study predated the detailed 2011 Brazos River Authority PK - Granbury - Whitney Water Management Study upon which the current PK:Granbury drawdown ratio method of operation was adopted.

With regard to your question concerning projected 2025 water use and lake levels, slide 19 from the June 7 presentation in Granbury shows total water use from the entire BRA System in 2011 as 487,857 acre-feet. Of this, 68,420 acre-feet was diverted from Segment 4, which includes Lake Granbury. Slide 20 shows projected 2025 water use from the BRA System assuming that the System Operation permit is granted and that the Comanche Peak expansion occurs as planned. Total projected water use from the entire BRA System in this scenario is 644,663 acre-feet per year. Of this total, 165,996 acre-feet is projected to be diverted from Segment 4, which includes Lake Granbury. The projected increase in water diverted from Segment 4 when comparing 2011 to this scenario is 97,576 acre-feet (165,996 - 68,420). However, as was specifically stated in the briefing at Lake Granbury on June 7, the 97,576 acre-feet increased diversion does not account for the fact that about 40 percent of the water required for the Comanche Peak expansion is planned to be returned to Lake Granbury. If this is factored in, the net water use projected for 2025 from the entire System is about 610,000 acre-feet, and the net water use projected from Segment 4 is about 131,000 acre-feet. When compared to 2011, this represents an increase of 122,143 acre-feet for the entire System and an increase of 62,580 acre-feet from Segment 4.

The increased water use in Segment 4 (62,580 acre-feet/year) will be supplied from PK and Granbury. Releases will be made from PK in accordance with the drawdown protocol adopted by the BRA in 2011. The remaining increased water use projected for the rest of the System (59,563 acre-feet/year) will be supplied from a combination of all of the BRA reservoirs, use of naturally occurring flows downstream of the reservoirs, and potentially return flows, depending on where customers are located and hydrologic conditions across the basin. For example, some of the projected increased demand will occur at tributary reservoirs. This demand will be met from those reservoirs. Demands downstream of multiple reservoirs may be met from naturally occurring flows when they are present and/or releases from one or more upstream reservoirs.

Submitted, August 30 by Jim Littlefield

On page 57 Table 18. "Yield Simulations of the Brazos River Authority Water Management Study, May 2011 AVO 27440"

Please provide the equivalent of the "PK and GB drawdown (ft) vs Weighted Metric Percent Out-of-Service" Chart Figures ES-1, as shown on page vi of the same study using the Zone Scenarios 1.75:>992 and 1.5:1>992 for the simulations shown.

Please provide the date the data can be available.


The report you are referring to is the 2011 Brazos River Authority PK-Granbury-Whitney Water Management Study. Figure ES-1 on page vi of the report is not associated with any of the yield simulations shown in Table 18 on page 57. It simply shows the percent of features (weighted metric) that are out of service for a given drawdown at each lake. For example, the red line for Lake Granbury indicates that about 50 percent of the features at Lake Granbury are out of service when the lake is five feet low. At PK, the blue line shows that when PK is five feet low, only about 13 percent of the features are out of service. In general, a greater percentage of features remain in service at PK under larger drawdown's than is the case at Lake Granbury. The idea behind development of the drawdown ratios used for determining when releases would be made from PK was to bring these lines closer together, when possible, so that the percent of features out of service at each lake during droughts was approximately equal in terms of time.

For determining releases from PK under current water use conditions, the drawdown ratio (PK:Granbury) target is 1.75:1 when PK is above elevation 992. It changes to 1:1 when PK is below elevation 992. Figure 17 on page 39 shows the projected results of implementing this drawdown ratio. For example, the blue text box on the right side of the figure shows that about ten percent of the time, about ten percent of the features are expected to be out of service at each lake. The graph can be read similarly for other percentages. About five percent of the time, about 18 percent of the features are expected to be out of service at each lake. More than 80 percent of the time, 95 percent or more of the features at each lake are expected to be in service.

For determining releases from PK under projected 2020 water use conditions, the drawdown ratio would remain at 1.75:1 when PK is above elevation 992 but would change to 1.5:1 when PK is below elevation 992. Figure 23 on page 44 shows the projected results of implementing this drawdown ratio. For example, the blue text box on the right side of the figure shows that about ten percent of the time, about twenty percent of the features are expected to be out of service at each lake. Fifty percent of the time, all features are expected to be in service at both lakes.

Submitted, August 30 by Deborah

Comment
This seems to be a done deal. I am appalled (but not truly surprised) that one State agency agrees with the same BS from another. You are not listening to your people who allow you your job: you are convinced that you are right, and you are delivering a fait accompli to the people who matter, are affected. I am frankly furious of the disregard for the people who are asking life/property changes.

Submitted, August 29 by Grant May

I have read the application submitted to the TCEQ, but am having trouble determining how many acre feet of water you are applying for in the Upper Basin. Currently, the BRA has authority to use 230,000 acre feet from PK Lake. How much exactly are you wanting to increase this? How much per year total for PK Lake?

Due to the size of the basin and climate variability, water use under the new permit may change from year to year depending on conditions that exist at the time. In some years, additional water may be dispatched from one reservoir and not others, while the next year, circumstances may dictate a different management approach.

Contemporary modeling indicates that the firm yield of Possum Kingdom Lake, based on the Water Availability Model maintained by the Texas Commission on Environmental Quality and used by that agency to assess water right permits, is understated by approximately 50,000 acre-feet per year. This is only one component of the additional water that can be made available through System Operation.

However, BRA is not specifically asking to increase the amount of water available from any individual reservoir. The System Operation Permit will be a new authorization under which water use may be from natural flows in the river, return flows, and/or releases from any combination of any of BRA's 11 water supply reservoirs.

Submitted, August 28 by Mike Nickolaus

Would the BRA consider going back to the drawing board with respect to the establishment of the 1.75:1 ratio established for releases from PK to Granbury and increasing it substantially to avoid lowering lake levels at Granbury?

The Possum Kingdom/Granbury/Whitney study is barely a year old. The assumptions used in that study are consistent with the assumptions being used in development of the basin-wide Water Management Plan. There is no need to reconsider those assumptions over such a short period of time, especially with respect to the fact that the management protocol is functioning exactly as anticipated and balances adverse impacts between the two lakes fairly.

Submitted, August 27 by Mark Bisett

I appreciate the response to my earlier questions. I have a few more to help me understand the intent and impacts to Lake Limestone of the water allocation.

If the intent of continuing to ask questions is with respect to establishing a position as a party to the proceedings pending before the State Office of Administrative Hearings (SOAH), BRA respectfully suggests that you retain appropriate counsel and receive advice from said counsel as to how to join the proceedings. However, BRA will provide some answers to your questions.

1. In reviewing the WMP, I noticed that the BRA withdrew and provided approximately 698,759 acft/yr in 2011 (severe drought) under its 147 contracts. The BRA only had 662,901 acft/yr allocated by the state - how was the BRA able to use more than allocated?

The 698,759 value in Section III.1.1 (page 3-1) refers to the total amount of water under contract, not what was diverted (withdrew) during 2011. If you read Section III more closely, you will see that BRA has access to slightly less than 705,000 acre-feet per year, and that for 2011 slightly less than 488,000 acre-feet was actually diverted (Section III 3.3.1 pages 3-14, 3-15 (Table 3.2).

2. I understand by looking at the BRA projections for water utilization that it does not expect to use more than 50,875 acft/yr if granted the permit from the TCEQ through 2025 - is this correct?

The 50,875 acre-feet per year value is inaccurate with respect to your basis of question 1 and confuses future projected use with current contract amounts.

3. Since Lake Limestone has not had a hydrographic study conducted since 2002, how is it accurately reflecting siltation over the past 10 years and what is it using in its model?

BRA performs hydrographic surveys on all of its water supply reservoirs approximately every 10 years. The most recent survey for Lake Limestone was conducted in 2012; however, the survey data and report are not yet available from the Texas Water Development Board. BRA uses sedimentation rates derived from the survey data to estimate future reservoir storage. We will incorporate the results of the 2012 survey data when it becomes available.

4. What is Lake Limestone drainage area in acres and percentage of the Brazos River Basin that BRA controls?

Lake Limestone's contributing drainage area is 675 square miles of the approximately 36,000 square mile contributing drainage area of the Brazos Basin.

5. How does the BRA and/or the WMP account for evaporation, global warming, economic impacts and the loss of recreation and pleasure as a specified use granted to the BRA for use of Texas water in the State of Texas under Section 11.024 under Title 2, Subtitle B, Chapter 11, Subchapter A of Texas law?

This question is overly broad, crosses between hydrological, philosophical, and legal interpretations, and is impossible to answer in a forum of this nature. However, Section 11.024 lists the priority of water use within the state, as follows:
1.   domestic and municipal uses;
2.   agricultural uses and industrial uses;
3.   mining and recovery of minerals;
4.   hydroelectric power;
5.   navigation;
6.   recreation and pleasure; and
7.   other beneficial uses.

6. I also noticed that the BRA has a "draft" Drought Contingency Plan" open for public comment which ends September 10th, wherein there appears to be conflicting data (i.e. "Water Storage volumes") with the WMP - I would like to understand why and to what benefit this conflicting data may provide.

The Texas Water Code requires that Drought Contingency Plans (DCP) be updated every five years, and for that reason, the draft version of the DCP uses estimates out through 2015. The Water Management Plan (WMP) uses estimates for both 2025 and 2060. The year 2025 coincides with the first mandatory 10 year update to the WMP and the year 2060 refers to the last year of water use estimates from the State Water Plan.

7. I am also interested in learning more about the pending law suits against the BRA permit application, can you provide us details and how we may be able to join these actions?

As pointed out above, BRA suggests that you retain counsel should you wish to pursue these matters further.

Submitted, August 27 by Mike Clark

I frequently check the level of Lake Granbury on the USGS website. I have noticed that when it rains often times the level of the lake will initially rise and almost as quickly will drop. This does not happen all of the time but most. Why is the rain water not allowed to remain in the lake every time it rains?

Gages often respond to atmospheric pressure changes and wind, so when the gage rises and falls during rainfall events, it does not necessarily indicate that the lake level is rising or falling.

BRA does not arbitrarily release water from any reservoir immediately after a rainfall event unless the lake is full and a release is needed to protect the integrity of the dam.

Submitted, August 21 by Jim Littlefield

1. On your slides "PROJECTED PK LAKE LEVELS-YEAR 2025" and "LAKE LEVEL at PK SINCE 1970," could you explain in detail the methodogy used to generate the data and especially provide the History of lake level variation used? What assumptions were used to extrapolate the data to include the nuclear power unit addition?

The data presented in both of these slides originate from the May 2011 report entitled Brazos River Authority PK-Granbury-Whitney Water Management Study (2011 Study) which can be found here.

The slide "Lake Level at PK Since 1970" shows reservoir drawdown frequency statistics derived from actual daily lake levels recorded by the United States Geological Survey (USGS) gage at Morris Sheppard Dam from January 1, 1970, through December 31, 2009. This period represents the historical period when both Possum Kingdom Reservoir and Lake Granbury were in operation. Hydropower operations at Morris Sheppard Dam existed up until August 2007, thus the data in this historical period contains hydropower operations in 38 of the total 40 years.

The data supporting the "Projected PK Lake Levels - Year 2025" slide was generated with the Hydrologic Engineering Center (HEC) ResSim daily reservoir simulation computer program. A computer model was developed for the 2011 study that incorporated physical aspects of the system such as reservoir release capabilities, release rules from the reservoirs (i.e. drawdown ratios), projections of decreased reservoir capacities due to sedimentation and increased water use from the system including the expansion at Comanche Peak Nuclear Power Plant (CPNPP). Daily reservoir inflows and evaporation rates were developed from hydrologic records for the period of January 1, 1939, through December 31, 2009, which includes the 1950s drought of record. The HEC ResSim model was calibrated against actual USGS reservoir elevation data. The new units at CPNPP are assumed to utilize 90,152 acre-feet per year from Lake Granbury with approximately 40 percent of this diversion returned as blowdown to Lake Granbury, for a net demand of 54,091 acre-feet per year. In the 2011 Study the total demand of the PK-Granbury-Whitney system in the 2025 scenario with the CPNPP expansion is 184,265 acre-feet per year. The calibrated HEC-ResSim model was used to simulate how the reservoirs would have responded if this demand was placed on the system in each year of the 1939 - 2009 hydrologic period of record. The modeling used a 1.75:1 drawdown ratio between PK and Granbury when PK's elevation is above elevation 992 ft-msl and a 1.5:1 drawdown ratio when the elevation at PK is below 992 ft-msl. Output from the model included reservoir elevations for each day during the 71 year period of record. The statistics shown on the "Projected PK Lake Levels - Year 2025" slide were computed from this daily elevation data.

2. What date will you be able to provide a similar chart showing the effect on lake levels when the proposed total requested WMP is fully sold?

We are currently working on the modeling for that and hope to have it completed before the October stakeholder meetings.

Submitted, August 18 by Gary Cobb

Why have no reservoirs been completed or started above Pk. I know there have been some purposes. Why could we not use the money from sale of land to build a reservoir above Pk and don't tell me it takes 40 years to build one. Lake Allen Henry did not take near that long. Would this not solve most of our problems at Pk. And why can't we take BRA funds and invest in plants to retreat water like the city of El Paso and Big Spring?

The potential South Bend Reservoir, the next possible reservoir site immediately upstream of Possum Kingdom Lake, would inundate almost 30,000 acres, and impound approximately 770,000 acre-feet of water. The estimated stand-alone annual firm yield of the South Bend Reservoir is approximately 64,500 acre-feet (before contemporary environmental flows rules are applied), at a cost of over $420 million (of which an estimated $55 million alone, would be spent on engineering and legal costs). The BRA received approximately $50 million from the legislatively-mandated sale of residential and commercial property adjacent to Possum Kingdom Lake.

The write-up in the State Water Plan indicates that "(A) search of the Texas Historical Commission's online database indicates that one historical marker for Old Donnell Mill is located within the footprint for the proposed reservoir. At least two cemeteries, the Hill Cemetery and the Peveler Cemetery, are mapped within the proposed reservoir site."

Coupled with the extensive process of permitting the reservoir water right, along with land acquisition (including potentially costly condemnation proceedings), creation and implementation of environmental mitigation, and the actual engineering design of the reservoir and impoundment structure, it is easy to anticipate that the timeframe for completion of the South Bend Reservoir will be measured in decades.

With regard to Lake Alan Henry, this can be found on the City of Lubbock's Lake Alan Henry website: "Planning for this project began in the 1960's when City leaders realized that should the City's population growth continue as projected, the City would need another water source. Years of engineering studies, research and soil testing resulted in the recommendation of the current location of Lake Alan Henry. The current location of the John Montford Dam was the closest and best location in which to construct a dam. Application was made to the Army Corps of Engineers for a permit to dam "Water of the United States" in the Brazos River Basin. The application was granted and design work for the dam was completed in the 1980's. Construction began in 1991, and was completed in 1993."

Submitted, August 15 by Annie Davis

Comment
Why in the world would you even devastate the lame (sic - we assume this should be "lake") economy of Granbury and those all over the state who come here for our uniqueness, lake activities, shopping, etc. by selling 60% of our water? Are you as greedy as the CEO's and Congressmen all over the country seem to be? Why is it that the little unpowerful citizens are so vulnerable to the greed of companies like yours? Want a genuine, honest real life answer. Some of the companies you evidently sell our water to must surely be handing you loads of money under the table. How dare you charge us waterfronters a fee when you do absolutely nothing advantageous for us. Examples please. Dig deep and tell us something we can believe.

Submitted, August 13 by Sue Cathy

The following are questions that had been submitted to the PK Lake Association or the Chamber of Commerce prior to or after the BRA Presentation on Tuesday August 7, 2012. We would appreciate your answers and publication on the Q&A page.

1. At the PK Lake WMP meeting on the 7th, Mr. Ford stated that PK stakeholders had met previously on the WMP. Can you provide information on this meeting to include when it was held, who attended, what was on the agenda and the outcome of the meeting?


The public meeting Mr. Ford referred to, as indicated on the third slide of the Possum Kingdom presentation, was held in Granbury, Thursday, June 7, 2012. The comment was not meant to imply that a separate meeting, solely for the purpose of making a presentation to the residents of the Possum Kingdom Lake area had been held, nor that another public meeting solely for the purpose of making a presentation to the residents of the Possum Kingdom Lake area would be held. The next public meeting regarding BRA's Water Management Plan to be held in the Upper Basin will be on Tuesday, October 16, 2012 in Glen Rose.

2. Things seem to be set in stone and don't have any flexibility. Is there any negotiation with in your plan? May through August is 80% of lake usage. Is there an opportunity to maximize the lake level during this time in non-drought conditions?

BRA uses its water supply reservoirs to meet the basin-wide needs for water supply. Unfortunately, water supply deliveries from water supply reservoirs usually occur during the hottest and driest times of the year. In non-drought conditions, reservoir releases for water supply purposes are typically not necessary. As BRA has shown, for the foreseeable future, lake levels at Possum Kingdom Lake, even with the Controlled Outlet Conduit in place, and even with greater water supply demands than historically encountered, are forecast to be generally higher than they have been in the past.

3. Who are the users of the 1 million acre feet and what are they going to use it for? How do you balance the needs of people downstream with the needs of PK? What mechanism will be used to balance these requirements and who is the referee? It seems that a conflict of interest may exist.

BRA has repeatedly pointed out; it has no intention of selling 1 million acre-feet of firm water from this permit. As was presented at the meeting in Granbury (attended by representatives of the PKLA) and discussed at the meeting at Possum Kingdom, BRA anticipates that firm supply of approximately 125, 000 acre-feet will be contracted for, basin-wide, once the permit is approved, in accordance with the State Water Plan. BRA balances the needs of growing municipal and industrial demands basin-wide with its available supplies to ensure that cities have sufficient treated water to meet their needs, and industries, such as electric generation, have sufficient supplies to meet theirs. All of BRA's water supply activities are well within the terms and conditions of its water rights, which are administered by the Texas Commission on Environmental Quality (TCEQ). To view the State Water Plan, click here.

4. How many acre feet are under contract on the TCEQ application and how much wilI come from PK? How much of the 1M acre feet will be on a "firm" basis and how much on an "interruptible" basis?

None of the water being sought by BRA under the pending water rights permit application has been contracted for, and none will be until the permit has been approved. Once the permit has been approved, and BRA is able to contract for water sales, those demands will be met through the means identified in the Water Management Plan currently being developed and consistent with the demands identified for the Brazos Basin in the State Water Plan.

5. Can you sell water rights to another authority? How does that process work and what do you charge for water rights?

BRA's water rights allow it to put to beneficial use the volume of water contained in those water rights, for the purposes identified, such as municipal, industrial, agriculture, etc. BRA does have existing contracts with certain customers which could be considered to be an "authority," just as it has contracts with municipalities (cities), water supply and special utility districts, water supply corporations (quasi-governmental agencies), corporations and private individuals. BRA sells firm water on a take-or-pay basis, priced at BRA's System Rate. For FY 2013 (September 1, 2012 through August 31, 2013) the System Rate is $62.50 per acre-foot. The System Rate is adopted annually by BRA's Board of Directors at the same meeting at which the Board of Directors adopts the annual budget (usually in July).

6. We understand that Dow has the oldest senior water rights and PK Lake is the #2 holder of senior water rights. Could you explain who represents PK Senior water rights? How many acre-feet of water is does PK have in this Senior right? Is that a conflict of interest if BRA controls this?

Dow's 1929 water right is one of the oldest (but not the oldest) water right in the basin. BRA's Possum Kingdom water right has a priority date of 1938, and there are intervening water rights with priority dates between Dow's 1929 and BRA's 1938. As BRA holds the water right for Possum Kingdom Lake, it is BRA's responsibility to ensure that the rights afforded to it are protected and that junior water rights, especially those upstream of Possum Kingdom, do not compromise BRA's ability to impound and store water under the Possum Kingdom water right. The Possum Kingdom Water Right (Permit No. CA 12-5155) allows BRA to store up to 724,739 acre-feet, and to annually divert up to 230,750 acre-feet. Without the construction of Morris Sheppard Dam and the impoundment of water allowed by the 1938 water right, there would be no Possum Kingdom Lake.

7. When will the water plan between Granbury and PK be re-evaluated? There were assumptions made that now need to be validated.

The PK - Granbury - Whitney Water Management Study was completed and adopted by the BRA Board of Directors in 2011. All assumptions used in the development of the Study are still valid. The Study will be incorporated into the Water Management Plan by reference, and both documents are consistent in their treatment of the protocols established in the Study. There are currently no plans to revisit the Study, although the Water Management Plan must be revised every 10 years, based on the special conditions contained within the draft permit.

8. Refer to the "Where Does the Water Come From" slide that is included in the Granbury meeting presentation. Can you enumerate specifics for each bullet to tell us where and how much water is applied to each section: 1. Natural flow 2. Possum Kingdom 3. Return flow 4. System efficiency?

Natural Flow refers to the water that enters the basin either downstream of one of BRA's water supply reservoirs or is spilled by a reservoir during flooding situations. As has been pointed out, in a normal or average year, this volume of water is about 5.8 million acre-feet. The Water Availability Models maintained by the TCEQ for the Brazos Basin indicate that the permitted firm yield of Possum Kingdom Lake is understated by approximately 50,000 acre-feet per year. It is calculated that by the year 2060, over 275,000 acre-feet per year of Return Flows will enter the basin from treatment plants. System Efficiency refers to the fact that, with access to the storage available in eleven existing (and one permitted) water supply reservoirs, coupled with the volume of natural flows, BRA can support an additional firm supply of water within the basin without the expense of constructing another reservoir.

9. How do you define drought when it could be all through the basin or only at one area? For example, PK lake may not be in a drought zone, but the area that feeds it is drought coded. What defines drought?

Different entities and individuals define drought in different ways. For example, a farmer who goes one or two months without rain in the growing season would likely tell you that there is a drought, but a nearby reservoir may still be near full and not yet showing the effects of reduced rainfall. The US Drought Monitor is a frequently used graphic that defines and depicts drought based on multiple factors. It is updated weekly and can be found by clicking here. The August 14 version of this graphic shows "Exceptional" drought conditions in the Brazos basin upstream of Possum Kingdom Lake while the lower portion of the basin is near normal. The BRA Drought Contingency Plan (DCP) defines drought based on reservoir elevations and capacities.

The current DCP can be found by clicking here. Page 3 of the DCP summarizes drought trigger levels for individual reservoirs, reservoir sub-systems, and the BRA reservoir system as a whole.

10. What is the maximum down-take in normal non-drought time for PK Lake?

Since 1970, the elevation of Possum Kingdom Lake has been at or above elevation 996.4 half of the time. This is equal to a drawdown of about 2.6 feet when compared to the full operating elevation of 999.

11. It appears that TCEQ has asked for specifics for diversion rates and points. Do you have that information finalized?

Specific information regarding diversion rates and locations is a component of the Water Management Plan and, as indicated during the presentation at the Possum Kingdom meeting, are part of the Accounting and Modeling phase. This analysis has not been completed at this time, but the results will be consistent with the water needs identified to be met from the System Operation Permit in the State Water Plan.

12. What efforts is BRA taking to capture more water that flows into the gulf? Allen Creek seems to be part of the capture for the: future but are there efforts to capture more water and store in caverns, new water storage units, etc? It appears some communities downstream would invest in these efforts.

BRA has two projects that will take advantage of currently available flows in the basin. One is the Allens Creek Reservoir, an off-channel reservoir in the lower basin, and the other is a project to reallocate flood storage in Lake Aquilla for conservation purposes. The Region H component of the State Water Plan also includes foThe current DCP can be found by clicking here. Page 3 of the DCP summarizes drought trigger levels for individual reservoirs, reservoir sub-systems, and the BRA reservoir system as a whole.

13. At the PK meeting BRA stated it was too expensive to dredge. No new reservoirs are being built. If you don't dredge, don't build new reservoirs and current reservoirs are filling up with sedimentation, doesn't that drastically reduce the available capacity? What are BRA'S plans to sustain these reservoirs?

BRA did not declare that no new reservoirs would be built in the basin. To the contrary, it was pointed out that without additional water supply storage, future needs could not be met with current supplies. Reservoir construction is a very time and resource intensive activity. BRA is sensitive to the needs of its customers, and since current customers pay the development costs of new supply projects, the timing of new projects is always a consideration. Dredging sediment to recover reservoir capacity may become a cost effective strategy sometime into the future. BRA is constantly reviewing advancing technology in all aspects of water supply, delivery, and treatment.

14. I understand BRA is asking for an additional 1 million acre feet of water. BRA is charged with managing the Brazos Basin, but when you review BRA management processes it appears that BRA is not managing lake capacity. In the 40's when PK Lake was first built, the capacity was 700,000 acre feet so the extra 1 million acre feet from the entire basin might not have been so dramatic. The PK capacity is now 425,000 to 540,000 acre feet (I've seen several different numbers), what are BRA's plans to stop or at least slow down sedimentation? Isn't this a BRA responsibility? Will storage capacity become more of a problem for the State water needs?

The last sediment survey of Possum Kingdom Lake was conducted in 2005. The reservoir capacity estimate resulting from this survey was approximately 540,000 acre-feet. Control of sedimentation comes with cooperation of property owners in watersheds above water supply reservoirs to institute land management practices that reduce erosion. Sedimentation is also reduced by construction of upstream reservoirs that collect sediment that previously flowed downstream. Possum Kingdom Lake was impounded in 1941, prior to the greatest drought in modern times. Much of the sediment in the reservoir (approximately 154,000 acre-feet) was deposited during flood events between 1941 and 1974, when the first sediment survey was performed. Sedimentation rates have diminished in recent years. We currently estimate that approximately 2,600 acre-feet of sediment is deposited in the reservoir each year and expect to perform the next sediment survey in about three years. The firm yield of a water supply reservoir takes into consideration a certain level of sedimentation, and at the current time, the water supply available in Possum Kingdom Lake is safe and sufficient to meet the needs expected of this reservoir. Over time, sedimentation will become an issue for all water supply reservoirs Statewide, and not just in the Brazos Basin.

Submitted, August 12 by Mark Bisett

Comment
Thank you for the responses to my earlier questions. I would like to know what contracts the BRA has with any interest on Lake Limestone and what water volumes these contracts allow, and what the projected volumes and future contracts are? Thank you.


Lake Limestone was originally built under the terms of a cooperative contract between and among BRA, Luminant (successor to TXU), and NRG (successor to Houston Power and Light). When full, Lake Limestone holds approximately 208,000 acre-feet of water. The permitted firm yield of Lake Limestone is 65,074 acre-feet per year. Of the firm yield amount, BRA has long-term contracts with Luminant in the amount of 28,838 acre-feet and NRG for 21,837 acre-feet for lakeside diversions. Additionally, BRA contracts with the Texas Municipal Power Agency for 3,600 acre-feet and the Welborn Special Utility District for 4,000 acre-feet, both to be diverted downstream of Lake Limestone on the Navasota River. BRA contemplates no further contracts being written against the firm yield of Lake Limestone; however, Lake Limestone is a part of BRA's Water Supply System and may occasionally be used to meet downstream water supply needs.

Submitted, August 10 by Margaret Foster

Comment
We are full time residents, and attended the meeting at the PK Chamber of Commerce. I heard you say repeatedly at the meeting, and I just read on this site in a response from you, "the surface water belongs to the State of Texas." I would remind you that the "State of Texas" is nothing more or less than the people of Texas, living and working within its borders, using, enjoying and caring for its natural resources, raising families in their homes, voting in its elections, and abiding by its laws. WE THE PEOPLE OF TEXAS, ARE THE STATE OF TEXAS. The departments created by the legislative bodies of the State of Texas are there by the will of the people. When you stand and tell us that the "State of Texas" owns the water and our opinion of your decisions and their impact upon us are not to be addressed, we are being disenfranchised as citizens of this state we choose to live in and love. You are wrong about this. Our opinions should and do matter, and our well-being and continued success should and does matter. If you cannot see past your desires in this sales contract, and take a real look at the devastating impact it would have upon the schools and counties around the lake, to say nothing of the futures of the people who live and work in the Possum Kingdom Lake area, then you are truly blind to the rights of citizens. When we bought our house here, we were told that the BRA did not care about the residents. I did not believe that and told people so. Why would an organization charged with preserving and protecting the Brazos River Basin not care about doing exactly that? It made no sense to me at all. But now I see that they were right, and that your interest is the money that can be made, even at the cost of destroying the beauty and majesty of the area. The people of west Texas have come to PK Lake since the 1940's to relax, fish, ski, boat and enjoy the beauty of Texas. But seventy years later, a new breed of entity seeks to end that. Shame on all of you. I know your response will be that what you are doing is legal, and you are within your rights. But having a right and being right are not the same.

Submitted, August 8 by Don Blair

Comment
Brazos River Authority, I want to thank you for the efforts and hard work that you put into the meeting last night. It is not news to us that PK is a conservation lake and that it was originally designed for that purpose and I do not believe that anyone argues that. PKRM is here for you and for this community of relationships and I would only ask that you be mindful and seek wisdom in this permit request and to count the cost of the community. It is a good thing to care about the fish, vegetation, and woody areas, and the quality of the water. It is not a good thing to be holding $80 million dollars in the bank, or to make the statement that the study does not include the economic impact of the community of PK. Let me notate that the BRA stickers that you require on every boat at PK, is for the purpose of recreation, not to mention another source of income to your agency.

The BRA has been very gracious over the years to grant PKRM permission to be in the camps, that you all operate, for the purpose of building relationships and communicating with visitors and tourists of the lake since the 1970's. These campgrounds are always full of campers, which adds to the financial growth of PK.

In the event that your permit is granted and you are able to sell the additional water down the river, we ask that you count the cost and the impact to relationships at PK. You mentioned that you would be able to lower the water level to 16.3 feet with this new plan. Last year we were at 12 feet low and as I toured the lake and examined the impact, it was disheartening to see the number of docks and boats on dry ground. At 12 feet low the financial impact at PK was devastating, due to the fact that people stopped coming out here last year. When the people stopped coming the 7 or 8 eating establishments, the bars around the Peninsula and this side of the lake, had to scale back employment, and resources. The dock builders were stifled in the on going production of replacing docks, and revitalizing the dock flotation that you have required to be done. The service providers, marinas, gas stations, housekeepers, repair companies, and a/c companies were hindered because homeowners were not using their homes in 2011 as before. The four real estate companies were hindered on selling property and bringing in new property owners, and property values suffered during that time.

In addition to these issues of 2011, Palo Pinto County is high on the charts of poverty and welfare needs. PK has several streets off the beaten path that are run down poverty stricken neighborhoods with falling down homes and broken down cars. Most of these homes have children in them and single moms, or under educated dads that struggle in life to pay bills. These families work in the local business of PK to feed the family and they work hard, the work no one else wants to do. There are many people in the lower income brackets that drive out to PK from Graford, Palo Pinto, Mineral Wells and Weatherford to work. There are over 6,000 participants in Palo Pinto County for financial assistance of one kind or another in 2012.

Camp Grady Spruce YMCA mentors the lives of hundreds of children and youth during the summer months at PK and if the lake levels are too low these kids will not be here to be mentored as the future generation of our nation. I spent two years in federal prison and the common denominator there was that the inmates did not have men of courage or a support system in their lives growing up, myself included. BRA, we must unite as a community of relationships at PK and work together for the future of your families and ours.

PKRM is praying for you all and we want to be here for you to help in renewing and building relationships at PK in 2012 and beyond.

The message here is that if you lower our lake level even more than what the drought condition is doing, this could bankrupt the community of PK, and this would effect the future generations of this community. This could destroy the lives of children and families, if a balance and wisdom is not used in this decision process.

I might even encourage you to take 10% of your 80 million dollars and plant seeds at PK to heal relationships and help families in crisis. I read that the same measure we give it will be given back to us. This can be positive or negative. I would be amiss if I did not encourage you in the word of God as the Chaplain at PK and His word says when we touch the apple of His eye, He will shake His hand against us. The apple of His eye is His Kingdom of people that He loves dearly. On the flip side, if we are under His hand of blessing, He says we will prosper and be in abundance, even in times of drought and famine.

Our prayers are with you all!
Don Blair
PK Lake Chaplain

Submitted, August 8 by Mark Bisett

My question here is, is all of the questions, responses and public/stakeholder input going into the official record at TCEQ - who OWNS THE WATER?

I would also like to know what office within TCEQ is this application/WMP pending?

Who is the program/permit contact within TCEQ?

What is the TCEQ permit/reference number for this application?

What is the pending schedule for BRA's submission's on the WMP to the state, prior to November?

Is there a TCEQ web link to this application that all of us can access to submit our concerns/questions directly to the state?

The BRA is compiling and reviewing all materials collected through the Water Management Plan (WMP) Stakeholder process, including questions, responses, and public/stakeholder input, and will make all those materials available to the parties through the discovery process when the contested case proceedings before the State Office of Administrative Hearings (SOAH) resume. TCEQ is likely to conduct its own public meeting to receive public comment on the draft permit and WMP, following TCEQ staff's technical review of the WMP.

With regard to your other questions:

Surface water, that being water that flows in the streams and rivers in the state, is the property of the State of Texas. The laws of the State of Texas prescribe how an entity can acquire access to state waters via application for a water right, through a permitting process also prescribed within the laws of the State of Texas. This permitting process is exactly what BRA is following with its System Operation Permit application and the development of the related Water Management Plan.

Water rights permit applications are process by the Office of Water, Water Availability Section. The Director of the Water Availability Section at TCEQ is Ron Ellis.

BRA's System Operation Permit application has been assigned Water Right Permit No. 5851.

The schedule that BRA is following is available by viewing the PowerPoint presentation used for meetings in June at Bryan, Temple, and Granbury by clicking here, as well as the PowerPoint presentation for the meetings held in August at Possum Kingdom, Taylor, and Brenham by clicking here.

A copy of BRA's application, as well as other documents produced subsequent to the filing of the permit application, is available here. BRA is not aware of any web link used by TCEQ to acquire input (concerns/questions) regarding pending water right permit applications.

Submitted, August 8 by Jim Littlefield

1. In the presentation at PK, you presented a slide that showed the percent time of 25%, 50% and 75% of PK water level less than full would be, based on historical data, and when and if the added nuclear facility requires water. Could you post that slide in the question and answer site?

2. Also, could you show the same slide, except show how it would affect PK if all the 1.0M water contracts were fully sold and used, base on the same historical data?

3. Plus the same slide, except how that same historical data would affect PK if only the presently contracted water sales were used.

The initial slide in question was not contained in the primary presentation for the August 7, 2012 Water Management Plan Stakeholder Meeting; however it is available and can be accessed here.

Regarding your other requests, we did not have slides with this information at the meeting. In the modeling that was discussed at the meeting, we are evaluating 2060 projected conditions; however, we are not planning to sell 1.0 million acre-feet as was pointed out at the meeting. All the modeling results will be incorporated into the final draft of the Water Management Plan before it is submitted to the Texas Commission on Environmental Quality in November.

Submitted, August 8 by David Wheat

Comment
I attended the August 7th meeting and came away for the first time ever NOT feeling good about my neighbor (the Brazos River Authority). It seemed the only reason you were there was someone told you that you had to hold these meetings in order to get what you want. We are full time residents and now are very concerned with your intentions. I wish I didn't feel this way.

Submitted, August 8 by Bob Griffin

As I understand at present, BRA's considerations seem to fall short in balancing upstream supplies and their effect on property owners against downstream demand. This is especially true in drought years. Please comment.

BRA respectfully disagrees. BRA's reservoirs were built for the primary purpose of water supply, which is very important and critical to maintain the health and welfare of municipalities and industry dependent upon that water, especially during times of drought. BRA manages its reservoirs consistent with the water right permits issued for those reservoirs, as well as the contracts between BRA and downstream customers. During 2011, arguably the driest period in the last century, BRA's reservoirs served their intended purpose and BRA was able to safely deliver water to its water supply customers.

Submitted, August 7 by Russell Hall

Comment
I live on Possum Kingdom Lake. The water level does not neet [sic] to drop lower than 10ft from the 100% full level. A minimum drop at 5ft below the full level is even more preferable. Lower lake levels make using the lake difficult and hazardous. Anything lower than this is, based on my experience on the lake, dangerously low.

Submitted, August 7 by Gary Cobb

What was the money from sale of land to residents used for?

The proceeds from the legislatively mandated sale of residential and commercial leased property around Possum Kingdom Lake were deposited into BRA's Water Supply System Fund. Subsequently, these funds are accounted for as reserves to the Water Supply System and are contained within a Rate Stabilization Fund. The Rate Stabilization Fund was established by the Board of Directors in 2005 (BRA Policy No. 4.02 - Contingency Reserves). Click here to view the Board resolution.

Annually, as part of the budget development process, the BRA reviews requirements for major projects and determines the form of financing to be used to pay the costs of those projects. Currently, due to the condition of the financial markets, BRA has chosen to use the Rate Stabilization Reserve to either pay cash for project costs (instead of borrowing) or pay off outstanding debt.

Submitted, August 7 by Mark Ault

As a PK homeowner I'm very confused about the BRA's directions. We pay dock fees, yet I receive no refund when I can't use my dock. The BRA is so concerned about the colors, size and building materials for my dock, but aren't concerned about how ugly the lake appears when it is 7 feet down. I think it would be fair that if 990 is going to be the new norm, then we should be compensated to extend our docks so they are usable.

And just saying you don't have to, doesn't make it right or fair.


All BRA reservoirs were originally constructed for water supply purposes. What this means is that they catch water during wet periods so that it can be used as water supply during dry times. All reservoirs have fluctuated in the past and this will continue; however, we do not expect a "new norm" at PK to be at the 990 level.

The "Application for Permit for Private Facility - Lake Possum Kingdom" contains a paragraph, in bold print, directly above the signature line, which states: "APPLICANT UNDERSTANDS THAT THE LAKE LEVEL WILL NOT BE CONSTANT AND MAY DROP AS MUCH AS 33 FEET, OR MORE, DURING DROUGHT PERIODS . . ."

Submitted, August 5 by Deborah

Why would the BRA consider the sale of water when, by its own admission, there is not enough water to meet current (and future) needs? This is insanity from a government agency using natural resources as a source of income.

When it is said that "there is not enough water to meet current (and future) needs,? this statement refers to the acquisition of the right to beneficially use water that is available, subject to the permitting process contained within the laws of the State of Texas. BRA has shown, using water availability models maintained by the Texas Commission on Environmental Quality (the state agency charged with regulating the waters of the state) that when combined with stored water in BRA's existing reservoirs, water that enters the rivers downstream of BRA's reservoirs can be made a reliable source for municipalities, industry, and agriculture.

Submitted, August 2 by Penny Ranft

Many residents and lease holders are requesting that the BRA have a means for people who cannot attend the meeting on August 7th to have a voice. People have offered their teleconferencing systems free to the BRA. I wish that you would consider this option. Just in case you do not - I will voice my opinion here. You are RUINING PK. Your water mgmt plan is devastating the economy around PK. Do what's right for the people for a change. It's almost like you sold off the land which we were thankful for so that you now can destroy it. What a shame.

BRA has no issues with other parties establishing teleconferencing capabilities for the meetings being held on the Water Management Plan.

Submitted, August 2 by Deborah

The answer to my posting was nothing but hooey. It was not germaine at all, but a double-speak from a government entity.

The BRA does not have the authority, nor does the State of Texas, to sell water rights to a private company. Our natural resources (which affect millions of people) are not negotiable. I want a better answer.

Your agency needs to provide a compelling reason to sell water, as well as a comprehensive plan to protect those who have homes along the Brazos.

I do not like "answers" such as what what provided to my previous post. The homeowners along the Brazos need answers that are clear, concise and specific.


Surface water, that being water that flows in the streams and rivers in the state, is the property of the State of Texas. The laws of the State of Texas prescribe how an entity can acquire access to state waters via application for a water right, through a permitting process also prescribed within the laws of the State of Texas. Once acquired, the holder of the water right can use it for any purpose authorized in the permit, including selling that water to a third party.

This permitting process is exactly what BRA is following with its System Operation Permit application and the development of the related Water Management Plan.

Submitted, August 1 by Larry Kilgore

Where does one get the financial information concerning the BRA? Who owns the BRA? Who are the officers and directors?

The Brazos River Authority was created by the Texas Legislature in 1929 and was the first state agency in the United States created specifically for the purpose of developing and managing the water resources of an entire river basin. Like all state agencies, the BRA answers to the Legislature. There are 21 members of the Board of Directors, appointed by the governor and approved by the Texas Senate. Information regarding the Board of Directors may be found here . Copies of current and prior audits (CAFR) and current and prior budgets can be found on BRA's on the BRA website by clicking here.

Submitted, August 1 by Keith Bauman

How do you anticipate the new water management plan impacting the amount of water that will flow into the Gulf?

The Water Management Plan contemplates that there are municipalities, industries and other agencies that may divert some of the flows downstream of BRA's reservoirs. However, the amount of water anticipated to be diverted under the proposed permit is less than 5 percent of the average annual flow into the Gulf of Mexico. Also, the permit has a number of environmental flow requirements that will limit when BRA can divert water.

Submitted, July 31 by George Gault

How does the BRA propose to gain access to "uncontrolled" flows? Will water sale contracts prevent drawdowns from reservoirs when lake levels are in marginal condition, i.e. 6 feet low?

The term "uncontrolled flows" refers to water that enters the river downstream of BRA's reservoirs or that flows out of BRA's reservoirs when they are full. This permit will allow municipalities, industries and other agencies downstream of BRA's reservoirs to access these flows by pumping them from the river when they are available rather than BRA making a release from a reservoir.

Unfortunately the answer to your second question is no. The purpose of BRA's water supply reservoirs is to capture water when it is available and store it for use during drier times. While there are flows in the river downstream of the reservoirs some of the time, drawdowns of reservoirs will be necessary when those flows are not available.

Submitted, July 31 by Ray Ashley

BRA is not using all the water you are authorized to use now. Why do you want more? Lake Granbury is down about 4 feet now. When will you people come to realize the devastating economic impact continued low lake levels have on the economy?

In the form of water supply contracting used by BRA, municipalities, industry, agriculture and other agencies are guaranteed that a certain amount of water is available to them at their discretion. This approach assures the organization of a future supply, knowing full well that they will not divert and put to beneficial use all the water they have under contract for years, if not decades, into the future. As a result, the BRA will not issue contracts without having additional supplies available; which is the primary purpose of the pending permit application. BRA has contracts for nearly all the supply it has available under its current permits from the state, yet there are municipalities, industries and other agencies that are in need of water supply now and have made requests to BRA as indicated in the State Water Plan.

Access to water is a state-wide issue, with the economies of multiple entities, such as other municipalities, electric power generators, and industries dependent upon a readily available supply. The resources of our reservoirs are needed basin-wide to meet the needs of everyone dependent on the BRA Water Supply System. As of August 1, 2012, Lake Granbury is 2.3 feet low.

Submitted, July 31 by Shane Hartman

If levels decline more than 13 feet below full at PK, will dock owners be allowed to increase the length of walkways?

The Water Management Study for PK-Granbury-Whitney anticipates that PK will be above elevation 990 over 95 percent of the time with the controlled outlet conduit and both new units operational at Comanche Peak.

Currently, dock extensions are considered pursuant to the Shoreline Management Guide adopted by the BRA Board of Directors in 2006.

Submitted, July 28 by Deborah

Why would you consider selling water from the Brazos, and especially from Possum Kingdom Lake? The lake is already low. The entire watershed, from PK to Granbury to Whitney is in trouble and you want to sell water rights to private companies?

Many communities rely on the BRA for water. Even municipal water services do so. Millions of dollars have been spent by homeowners who want to live on the lake, with WATER IN THEIR FRONT YARD! Not sand! If you begin to sell BRA waters, PK lake will possibly lose their water system, as the pumps cannot function out of water.

Further, this begs the question as to how the BRA can tax and require permits for docks out of water. The Board has overstepped its grounds in considering this. Our natural resources are a gift, not a commodity for budget problems. Corning can figure out their own issues, such as desalination of available water near the coast I would appreciate an immediate answer!


Based on the recently adopted State Water Plan, the future need for water supply in the Brazos River Basin far exceeds current supplies. New sources must be identified and developed in order to meet the requirements of a state population that will double between 2010 and 2060. BRA's proposed System Operation Permit is only one of many projects in the basin recommended to meet the needs of municipalities, business and industry, and agriculture identified in the State Water Plan.

Submitted, July 26 by Jim Nicklas

The current lake level at PK is at 993.21. What will the impact be on the lake level if the 70-80,000 af is approved? What is your anticipated average lake level for PK if approved?

We expect lake levels to be consistent with future projections from the PK - Granbury - Whitney Water Management Study that was adopted in April 2011. The projections show that generally, when compared to lake levels at PK when the hydroelectric units were operating, lake levels will be a little over one foot higher, even with the new controlled outlet conduit (COC) in place, and the two new units proposed by Luminant at Comanche Peak.

Historically, the median lake level at PK from 1970 through 2009 was 996.4 The anticipated median lake level with the COC and the additional Comanche Peak units is 997.9.

Submitted, July 25 by Judy Loftin

I have been informed that the Brazos River Authority has plans to sell one million acre feet of water from Possum Kingdom Lake.

The Brazos River Authority has a permit application pending with the Texas Commission on Environmental Quality (TCEQ) to allow the use of currently unused water available downstream of its existing reservoirs, as well as the unpermitted yield in these reservoirs (primarily an additional 70-80,000 acre-feet from Possum Kingdom).

The exact total volume of water that BRA is granted and how much of it will be put to beneficial use throughout the entire Brazos Basin is to be determined by the TCEQ Commissioners, based on the Water Management Plan (WMP) being developed at this time.

The recently adopted State Water Plan assumes that the permit will meet approximately 125-150,000 acre-feet of future needs within the Brazos Basin. Correct information relating to both the permit application and the WMP are available here.

Submitted, July 20 by Jim Littlefield

1. The BRA has constantly stated that the BRA lakes were created for flood control and water supply. However, since that time significant economic regions have developed because of the lakes. Will the study the BRA has commissioned consider the economic impact on these regions as function of lake levels? Shouldn't the Lake level study, consider among other things, Level as a duration of time, season of the year, impact on lake access, local, region, city, county and state revenues? For example, the 11 foot PK lake drop has made a significant drop in lake dock and boat ramp access. Although the BRA revenues are mostly based on water sales, since the PK land divesture, they are still a state agency, and Low lake water levels affect much more than just the BRA. Shouldn't that also be a factor in this proposed water sale?

The Water Management Plan (WMP) being prepared by BRA deals with how the organization will account for deliveries of water to customers under its various water right permits as well as the implications of those deliveries on such events as flows in the river and compliance with environmental requirements and regulations. BRA's WMP will not look at the economics of lake level fluctuations on local property values. BRA's 2011 PK - Granbury - Whitney Water Management Study did address some of the issues raised in your question such as expected lake levels, durations, and access impacts. The WMP currently in development is expected to be consistent with the results of the 2011 PK - Granbury - Whitney Water Management Study. Information pertaining to this study including presentations, public meetings, and the report remain available on BRA's website by clicking here.

2. In detail, how was the ratio of PK to Grandberry (sic) 1:1.75 established? There was, at one time, a ratio of 1:1.50 kicked around, why is that not used? Does this ratio include any consider the factors of the number of docks and ramps unusable relative to the two lake levels?

The 1:1.75 ratio was established for just the factor you indicate, that being to balance the number of facilities affected at each lake in an equitable manner. We found that the 1:1 ratio initially used by BRA had an inequitable effect between the two reservoirs and their facilities.

3. Of the $5.8M value water lost in the gulf, what amount each is from PK, Grandberry (sic) and Whitney?

We assume that your question refers to the observation that on average about 5.8 million acre-feet of water flows into the Gulf of Mexico each year. This value represents water that either cannot be stored in reservoirs because they are full or water that comes into the basin downstream of all reservoirs and therefore cannot be captured and stored.

4. If the 1.0M/acre ft./Year requested is passed, how would that affect the rate of flow out of PK relative to the inflow based on the best years of inflow, the average years and the worst years since 2001? Also how would this affect PK lake level?

The effects on Possum Kingdom Lake, assuming that BRA is successful in obtaining the System Operation Permit, were evaluated in the previously prepared PK - Granbury - Whitney Water Management Study. The results of that study may be reviewed by clicking here.

5. Since PK volume is much less than the 1.0M rate requested, what would stop the BRA from draining PK dry?

The water stored in BRA's reservoirs is a valuable resource for water customers throughout the Brazos Basin. From a regional resource management perspective, BRA releases water from its reservoirs in a carefully planned method to ensure that the resource is dispatched in the most beneficial manner practical. Essentially, BRA reviews the water available in each reservoir and where needs are being created due to requests from its customers. BRA also considers other factors such as local water needs and strives to balance adverse impacts to the 11 reservoirs in the system during droughts.

As indicated in question three above, there is a great deal of water available downstream of BRA's reservoirs much of the time. BRA expects that this water will be used first by its customers when they have needs, and will only be supplemented from BRA's stored water when those flows are insufficient to meet the needs of our customers. Much of the water requested in the permit application comes from these downstream flows.

Also, from 1942 through 2007, BRA released on average about 333,646 acre-feet of water each year through the hydropower turbines at PK. The hydropower units are being decommissioned. Downstream releases of water in the future will only be for environmental flows, water supply needs, and to pass excess floodwater.

6. Before the PK land sale, the BRA, on a number of occasions, reminded leaseholders that the lake was not a constant level lake and could vary as much as 10 ft. The same words were used on our sales contracts, but the level was now 30 ft. Was this because they were losing their leaseholder income and decided to increase water sales, although they realized 50 million dollars from the sale?

Dock and water permit documents, leases, and lease renewal agreements have all contained language regarding the potential for the lake level to fall as much as 30 feet. Regardless of the state of ownership of property adjacent to Possum Kingdom, this condition has not changed.

Submitted, July 19 by Mike Mikeska

Sounds like I should sell my lakehouse at PK ASAP as I will never be able to get my boat out of the dock after this plan is implemented..........correct?

We expect lake levels to be consistent with future projections from the PK - Granbury - Whitney Water Management Study that was adopted in April 2011. That study shows that generally, when compared to lake levels at PK when the hydroelectric units were operating, lake levels will be approximately 2-3 feet higher.

Submitted, July 18 by Todd Garner for the Granbury Chamber of Commerce Water & Environment Committee

1. Will the plan be revised as the nine public meetings are held to address issues raised at the meetings? If so, will the final plan be available for public review prior to submitting it to TCEQ?

In January, the TCEQ Commissioners gave the BRA 10 months to develop and submit the Water Management Plan (WMP). As a result of this aggressive schedule, the WMP will not be final until near the November 26 deadline for its submittal. We plan to post portions of it for review on this website as they are developed between now and then. The purpose of the stakeholder meetings and website forum is to update the public on our progress and provide the opportunity for comments and discuss issues. We will consider the comments that we receive, but our November 26 deadline is firm and we may not be able to address or resolve all issues to everyone's satisfaction by then.

2. Once the plan is submitted to TCEQ, will there be an opportunity for public comment to TCEQ?

Once the WMP has been submitted to the TCEQ staff, it is BRA's understanding that they will announce a meeting at which the public will have an opportunity to make comments for TCEQ's consideration. Since this is something that TCEQ will schedule, BRA cannot assure when or where this meeting will take place. As indicated during our presentations at the June stakeholder meetings and shown in our slide presentation, BRA assumes this public meeting will be held in July 2013, following the TCEQ staff's review of the WMP.

3. What would happen if the plan is approved and BRA gets the additional water, but CPNPP Units 3 & 4 are not built? What happens to the additional 100,000 AF identified for CPNPP-would the BRA sell it to someone else, use some of the water for environmental flows, or not use the water at all?

As discussed at the June stakeholder meetings and based on the adopted 2012 State Water Plan, two scenarios are being analyzed - with and without the Comanche Peak expansion. If the Comanche Peak expansion does not occur, it is expected that a majority of the additional water available would be offered to other entities with projected water needs identified in the State Water Plan.

Submitted, July 5 by Anthony Lizardi

Has the BRA considered dredging the Long Creek Court Cove area to increase the volume of the Lake Granbury?

The Brazos River Authority does not consider dredging an economical means to increase or capture lost storage capacity at its reservoirs. While the volume of sediment in some localized areas may be significant, in the context of the lake as a whole it is a relatively small. Dredging these small areas would not provide significant water supply benefits.

Submitted, July 3 by Tim Jackson

Do you have a schedule of dates and times that you open the gates to release water? If so where can I find that info?

BRA posts real-time release information on the home page of its website at www.brazos.org for Possum Kingdom Lake, Lake Granbury, and Lake Limestone. Daily release information for Corps of Engineers' reservoirs is available by clicking here. Projected weekend releases from Possum Kingdom Lake and Lake Granbury are also typically posted by Thursday of each week by clicking here.

In most instances, releases are dictated by short lead time events, so there is not a regular, set schedule. Events that trigger releases are usually weather related. These include instances of excess rainfall runoff during wet conditions when the lakes are full and water must be passed downstream or instances of dry conditions when downstream customers call and request a release under their water supply contract.

Submitted, June 28 by Kert Platner

Comment
I understand the lake was not originally built for recreation but everything evolves. Jobs, businesses and the entire region flourish when the lake is used for multiple purposes. I also know that no lake is "constant level" but once again I believe a common sense approach has to be found. When people stopped coming out to PK because of the fires the business owners and Chambers cried out that they needed more traffic.

Submitted, June 27 by Johnny Will

If such a large amount of treatable water flows uncontrollably from the Brazos River into the Gulf, why release so much from Possum Kingdom dam? The lake should be kept as full as possible to prevent the loss of treatable water to the Gulf.

The flows the BRA references in its permit application occur primarily downstream of its reservoir system. Under current permits, the BRA is limited in using these flows. The System Operation Permit would provide the BRA greater access to these flows and allow downstream customers to divert them when they are present. However, during dry times such as 2011, flow in the Brazos can drop to extremely low levels and water must be released from storage in the upstream reservoirs. The reservoirs will not remain full in these instances, but the empty space created by releasing water downstream is then available to capture runoff from the next large rainfall event.

Submitted, June 24 by Kert Platner

Comment
Hello, I am a homeowner on Possum Kingdom lake and do not fully understand the repercussions of this plan, but I definitely see the economic benefit to the region of having the lake level full as well as the property values in the area. If the lake was consistently lowered then I along with many other homeowners I know would most likely sell our properties and find another place to spend our money, time and property tax dollars. I hope a common sense solution to this matter is found. Best Regards, Kert Platner

Submitted, June 14 by Mendy Neighbors

Comment
I recently attended your meeting in Granbury as part of my job. My company purchases water from the BRA. I sat and listened to the speakers until I just could not handle it any longer (about 7:00 pm). My comment is just this. I have lived in Granbury all of my life, 57 years. I remember when all we had was the river and remember when the lake was built. People that have come recently seem to think it was built for their pleasure but us old-timers know differently. My support is with you in your endeavors. BRA built and paid for that dam and the way you use the water is your own. I cringe every time I hear someone say it is a constant level lake. There is no such thing. These comments do not come from a customer but from me, someone that has a little common sense. Thank you.

Submitted, June 7 by Judy McHugh

Are there any state requirements that BRA must meet in regards to lake levels?

No, there are no state lake level requirements.

Submitted, June 7 by Larry Dunn

1. Do any of the BRA Board members have any conflict of interest with the new WMP, either financial or political?
2. Will our junior water rights be affected by the WMP?


1. All BRA Board members are required to comply with Chapter 572 of the Government Code, and Chapter 176 of the Local Government Code regarding conflicts of interest.
2. No. The priority date for the permit will be 2004, so any water right that has a priority date earlier than that will be senior and will be entitled to take water before water could be diverted under the BRA permit.

Submitted, June 7 by Cathy Kuban

1. How is the amount of water released determined with respect to Lake Granbury and Possum Kingdom?
2. Who oversees BRA? Who are you accountable to besides the Governor? How do we get on the Board if we want to be on Board?
3. Are any people from Granbury on the Board?


1. The Water Management Study adopted in April 2011 established a 1.75:1 drawdown ratio between Possum Kingdom and Granbury that is maintained down to elevation 992 at PK. At that point, the ratio goes to 1:1. For example, last year during the worst part of the drought, PK was 11 feet low and Lake Granbury was 7 feet low. That was a function of the ratio. The lake levels are measured by three gauges not maintained by the BRA and are recorded every 15 minutes, every day.
2. There are 21 members of the Board, appointed by the Governor, and approved by the Senate. Like all state agencies, the BRA answers to the Legislature.
3. Yes, there is currently one member from Granbury, and there have been previous members from Granbury as well.

Submitted, June 7 by Gary Newton

How do you reconcile the Lake Granbury Watershed Protection Plan to lower the level of pollutants in the lake with an increase in water sales, which lowers lake levels and increases the concentration of pollutants and algae?

The BRA does not see those as being in conflict. We cannot answer your specific questions regarding pollutants and algae levels due to an ongoing contested case hearing.

Submitted, June 7 by James Sims

If BRA gets the permit, what do you think the Lake Granbury average lake level would be?

We expect lake levels to be consistent with future projections from the PK - Granbury - Whitney Water Management Study that was adopted in April 2011. We expect it to be full about 50 percent of the time, even with the proposed Luminant Comanche Peak expansion. In moderate drought conditions, we would expect it to be 1-2 feet lower than levels without the expansion, and during severe drought conditions, 3-5 feet lower.

Submitted, June 7 by Jim Klein

1. Lake Granbury becomes silted very easily. Will BRA try not to lose as much water in the lake because of the silt issue?
2. When selling water, is there a sliding scale as to the rate? What rate does TXU or Luminant pay versus individual users?


1. The silt issue is not really associated with lake levels. Silt enters the lake during rainfall/runoff events regardless of the lake level. The velocity of the water flowing into the lake keeps sediments suspended in the water, and when it hits the lake, the water slows down and the sediments sink down to the bottom of the lake. The reservoirs were built in the 1950s-1970s and over time, they are filling up with sediment. Sediment surveys are conducted approximately every ten years. In the 1930s when Possum Kingdom was built, its capacity was estimated at over 700,000 acre feet. At the time of the last sediment survey in 2005, its capacity was about 550,000 acre feet. The cost of dredging is more expensive than building a new reservoir. The state will have to grapple with this issue in the future.
2. The System Rate is established by the Board every year and is currently $62.50 per acre foot of water per year for all customers except those purchasing for agricultural use. The cost for Ag-use water is 70 percent of the regular rate or $43.75 this year.

Submitted, June 7 by Michelle Mulloy

1. How does it affect the wildlife when the water is so low?
2. Does BRA release water for recreational uses?


1. In recent years, BRA has maintained a low flow release from Lake Granbury of approximately 28 cubic feet per second (cfs) which amounts to about 55 acre-feet per day or 18 million gallons per day. Recent work performed by a team of scientists, the Brazos Basin and Bay Expert Science Team (BBEST), has identified a subsistence flow level of 16 cfs at the Glen Rose gage. BBEST was formed as a result of Senate Bill 3, which was passed by the Texas Legislature in 2007, to study the environmental flow requirements of the Brazos Basin.
2. BRA does not release water solely for recreational purposes. The reservoirs were built to store water so that a supply would be available during drought. When we do release water from Lake Granbury for downstream water supply, we try to do it on a Thursday or Friday so there is water for recreation on the weekends. There are competing uses for water and we cannot satisfy every user's need all the time.

Submitted, June 7 by Mickey Parson

1. What is going to happen to the extra 400,000 acre feet of water and the $25m?
2. Will existing water right holders like Granbury be given a preferential right to those new water rights that come down the pike?
3. And if we have a preferential right to get more water, will we get the water at no cost since there is no additional fixed cost because the system already exists?
4. In the WMP, will there be any set asides for public entities for public water supplies?
5. Will we get credits for wastewater returns under the WMP in the future?
6. Will we have the right to capture our own wastewater?


1. We only anticipate selling 120,000-150,000 acre feet of water under new long-term contracts. The ultimate amount of water sold will depend on the location of customers.
2. No, there will not be a preferential right to the water.
3. The System Rate is the same for all customers. There will not be a preferential rate for additional water. Every year, the BRA determines the costs to operate its water supply system. The Board considers such items as payments to the Corps of Engineers, the costs incurred to maintain and operate reservoirs, etc., and the amount of water sold under contract. These factors allow the Board to determine how much revenue is needed to cover the costs. The System Rate is set accordingly. Further, the cost of obtaining the System Operation Permit is estimated at $20 million, so the additional water is not free. Though the original permit application was for 421,000 acre-feet, we do not contemplate selling much more than 120,000-150,000 acre-feet. You cannot factor in income from water not sold. However, if the System Operation Permit is approved, the funds received will be managed in the same manner as funds derived from current contacts. It will be used to fund future water supply and distribution projects such as the Allens Creek Reservoir.
4. As a member of three regional planning groups, the BRA is a participant in developing the State Water Plan. The plan allocates supplies and demands and BRA operates within those allocations. The allocations determined by the state plan go through a vetting process and public hearings. The water allocated in the planning process to meet projected needs is not "set aside," but is aligned with the supply and demand in the regional water plans that are a part of the State Water Plan.
5. No. Once wastewater is returned to a state waterway, it becomes the property of the state. The state then makes that water available to be permitted for use.
6. Yes, you already have that right.

Submitted, June 7 by Tony Allen

1. What was BRA's profit and loss last year?
2. How much excess money was put into the rate stabilization fund last year?
3. Are Board members paid to be on the Board?


1. BRA is revenue neutral. We do not make profits. After maintaining operations on our three reservoirs, paying the Corps of Engineers for the water stored there, and operating our other facilities, if there is excess revenue generated, it goes into a "rate stabilization fund" and is reinvested into projects to establish more sources of water.
2. Between BRA's 2010 Fiscal Year, and 2011 Fiscal Year, the value of the Rate Stabilization Fund changed from $29,956,000 to $79,649,000. This increase was due to the bulk sale of residential and commercial properties at Possum Kingdom Lake, an unusual, one-time event that netted BRA approximately $50,000,000. If not for the proceeds from this sale, BRA essentially "broke" even for the past completed Fiscal Year.
3. No. Members are appointed to the Board and volunteer their time as a public service to the state. Board members are reimbursed for travel expenses.

Submitted, June 7 by Wayne McKethan

Comment
We understand that with the severity of the drought, we all have to take our fair share of loss, but how that fair share is measured is my concern. There is $5.2 billion of ad valorem value around Lake Granbury and 128,000 acre feet of capacity. Compared to Possum Kingdom and Lake Whitney, the economic impact is much greater on Lake Granbury even though it is a smaller capacity lake. In determining how to do releases, the 1:1.75 ratio was probably calculated from a mechanical or engineering standpoint, but it does not take into consideration that human or economic impact.

Submitted, June 7 by Rafael Flores

Comment
We understand the personal economic impact and are looking for ways to use less water from Lake Granbury. We have to follow EPA rules which require us to use cooling towers, but we are committed to finding ways to decrease water use.

Submitted, June 7 by Don Brown

1. Why can't Dow take water from Gulf and purify it?
2. Where does the money go?


1. Water desalinization technology is there and available, but it is extremely expensive. Dow does use a lot of water from various sources, including seawater. In most years, no water is released from BRA reservoirs for Dow because Dow has its own water rights. BRA releases water for Dow's use about once every 10 years or so. Their water rights in the basin go back to about 1930, before the reservoirs were built, so they are entitled to get flows when they need it.
2. See answers to Tony Allen's questions above.

Submitted, June 7 by Sue Hoffman

When the gates are opened, there is a bad smell. BRA says it's the lake turning over, but I have lived by the dam since the 1980s and it has only been happening for the past 6-7 years. What is the smell?

BRA continues to believe that the source of the odor that intermittently occurs during gate operations is associated with the release of hydrogen sulfide gas (H2S). Hydrogen sulfide is a colorless gas that can be easily recognized by its "rotten egg" odor. Hydrogen sulfide forms when the concentrations of sulfates in the watershed immediately behind the dams are higher than normal. During the summer months, the sulfates are converted to hydrogen sulfide gas through microbial activity occurring in the bottom layers of the lake. As the water leaves the lake via a gate release, the hydrogen sulfide gas is released into the air.

Submitted, June 7 by Barry Akerley

When Lake Whitney is full, why is BRA releasing 459 cfs out of Lake Granbury today?

We maintain a 25 cfs low flow all the time. We are currently working on the low flow gates so instead of 25 cfs all the time; we are opening one flood gate for about an hour and half every morning. It is the same overall amount each day. You can see the releases at the Glen Rose gage downstream. The hour and half release from the dam levels out by the time it gets to Glen Rose. The flow there has been pretty steady at around 50 cfs.

Submitted, June 7 by Joe Cooper

How will the permit impact permitting for agricultural use, with respect to both the difficulty of getting a permit and cost?

Getting a permit depends on a number of factors including where you are located in the basin, the amount of storage you have available, and TCEQ's process for evaluating the application. TCEQ's policy on issuing water rights is that it will not issue a permit for agricultural use unless 75 percent of the water is there 75 percent of the time. BRA's permit will not prevent others from getting a permit. (For additional information, see answer to Richard Cortese below).

Submitted, June 7 by Sue Fredrick

If Luminant expands their facility, where will the additional water come from? We know water does not flow uphill so it has to come from an upstream source, correct?

The source for that facility will come from Lake Granbury and the watershed upstream. Under the PK - Granbury - Whitney Water Management Study adopted in April 2011, we established protocols for operating PK and Granbury to maintain set drawdown ratios. How full Lake Granbury is dictates how much we will release from Possum Kingdom upstream. In the future, if Luminant expands the Comanche Peak facility and there is more water taken out of Lake Granbury, there will be more water coming in to balance the impact. Fifty to sixty percent of the time, there is enough water that Lake Granbury is not affected at all. In moderately dry periods, it impacts the level 1-2 feet. In extreme periods of drought, it has a 3-5 foot impact.

Submitted, June 7 by Ann Meyer

In a worst case scenario, what is the lowest level Possum Kingdom Lake could be lowered?

The issue expressed by Ms. Meyer relates to the concern that she and several individuals had related to the BRA's plans for the installation of a controlled outlet conduit to pass water downstream and the resulting effects on water levels in Possum Kingdom Lake. The BRA addressed this issue in a letter response to the Federal Energy Regulatory Commission (FERC). You may view the full letter response to FERC by clicking here.

Submitted, June 6 by Rory Cliett

Return flow credit and available capacity of Lake Whitney.

Once water is discharged into a state watercourse it becomes the property of the state and is subject to appropriation; thus, it is not available to the original water right holder for credit. Lake Whitney is one of the largest reservoirs in the Brazos basin. However, the BRA's water availability is limited in this reservoir as a significant amount of water is reserved for hydropower generation by the Southwest Power Administration.

Submitted, June 6 by Richard Cortese

Does this keep landowners from future permits? Does this affect livestock use of river water? Define the term "run of the river."

No, the System Operation Permit will not prohibit the issuance of future permits. However, even if BRA's permit application is denied, the reliability of flows within the basin may not be sufficient to meet the TCEQ's requirements for a future water right permit unless the organization applying for the permit has the ability to store the water. For municipal and industrial uses, the TCEQ requires that the requested water be available for use 100 percent of the time (100 percent reliability). Since river flows vary with the seasons, this may be achieved only through the ability to construct and divert water into some type of storage facility such as a tank or reservoir. For agricultural uses, the TCEQ requires a 75/75 reliability, which means that 75 percent of the volume requested must be available in the river or stream at least 75 percent of the time.

The Water Management Plan will not affect landowners with property adjacent to the Brazos River. They may continue to divert water for domestic and livestock use as part of their inherent riparian rights.

The term "run of the river" refers to flows that naturally occur from runoff and are not the result of a release of stored water from a reservoir.

Submitted, June 5 by Don Ballard

Who is in charge of authorizing/planning for construction of new reservoir?

Reservoir projects are major undertakings, requiring the coordination and cooperation of many participants. Generally, the process begins with the identification of the need for new water supplies; most likely this will occur at the regional planning level (Brazos G, Region H, or Region O). Should a new reservoir be included in a regional plan as a water supply strategy and the regional plan approved, that plan is forwarded to the Texas Water Development Board (TWDB) for inclusion in the State Water Plan.

Following adoption of the State Water Plan by TWDB, the plan is sent forward to the Texas State Legislature for their approval. Once the project sponsor is ready to proceed, a water right permit application is filed with the Texas Commission on Environmental Quality (TCEQ) for their review and the initiation of an approval process that includes public notices and meetings, hearings and testimony, and eventually a ruling on the water right by the TCEQ Commissioners. During the TCEQ permitting process, other state agencies, as well as individuals with an interest in the project will have opportunities to have their opinions heard and considered.

Concurrent with the TCEQ permitting process, it may be necessary for the project sponsor to acquire approvals from other agencies, such as the US Army Corps of Engineers (USACE). During the USACE process, other federal agencies, as well as the public, will have opportunities for input, similar to that available for the water right permitting process. When all permits have been obtained, the project sponsor may then proceed with property acquisition, the final design of the reservoir, and the eventual construction. Currently it is assumed that the process for construction of a new reservoir, given the design, permitting, acquisition, and construction phases could take as long as 30 years.

Submitted, June 5 by Ken Kramer

Who will draft the chapters and sections of the WMP and how may stakeholders provide suggestions for the drafts?

The BRA will draft most of the plan, with contributions from certain consultants such as Freese and Nichols, Inc. and Espey Consultants, Inc. We are holding this series of nine public meetings so that stakeholders can provide input. Additionally, stakeholders may make comments and suggestions through BRA's website.

Submitted, June 5 by Jordan Furnans

What are BRA's accounting procedures?

The accounting plan will consist of a series of spreadsheets. BRA will track water movement and use within the reservoirs (inflow, evaporation, customer diversions, etc.) as well as movement of water downstream (reservoir releases, travel time for water to move downstream, channel losses, wastewater discharges to the river, customer withdrawals, etc.). The accounting plan will provide a means for BRA to demonstrate compliance with use of water under its various permits.

Submitted, June 5 by Gene Fisseler

What is the priority of water rights during drought conditions?

The Texas Commission on Environmental Quality (TCEQ) is the regulatory agency responsible for the enforcement of water rights. We have seen their approach in both 2009 and 2011, especially with respect to priority calls made by senior water right holders, specifically those in the lower part of the basin. BRA's System Operation Permit and Water Management Plan will not affect the enforcement of the priority system and will be subject to the same constraints as other junior water rights in the basin.

Submitted, June 5 by Peggy Bloomer

Is water from Lake Belton to Ft. Hood considered in the Water Management Plan?

Water for Ft. Hood is supplied from surface water stored in Lake Belton under a separate water right held by the US Army. Since BRA is not involved in this water right, it is not included in BRA's Water Management Plan.

Submitted, June 5 by Dave Barkemeyer

Wanted to make BRA aware of erosion in Little River basin.

The issue Judge Barkemeyer references is the protocol used by the US Army Corps of Engineers (USACE) for management of releases from the flood pool of their reservoirs. Judge Barkemeyer is concerned that the USACE's release practices cause bank erosion downstream of the USACE reservoirs. With respect to BRA's use of water stored in USACE reservoirs, the releases requested by the BRA for downstream diversions are substantially less in volume than those made by the USACE for releasing flood water. As a result, water supply releases should not contribute to bank erosion.

Submitted, May 31 by Mike Nickolaus

1. On page 4-7 of the report you list a series of reservoirs in section 4.3 that you consider particularly valuable for recreation. Although I recognize this is just a partial listing I would feel much better, and I am sure other Lake Granbury residents would also, if Lake Granbury were included on the list.

The "report" referenced in the question above is the original System Operation Permit Application filed with the Texas Commission on Environmental Quality (TCEQ) in June 2004.

Section 4.3 deals with Instream Uses, and the paragraph referred is as follows:

"As the largest river basin in Texas, the Brazos River and its tributaries represent a significant portion of the environmental resources of the state. Also, with the basin's location close to most of the major population centers in the state, the basin contains significant recreational resources as well. The main stem segments from Morris Sheppard Dam to US 180 and from DeCordova Bend to Lake Whitney are popular with canoeists. Reservoirs located near urban areas, such as Lakes Belton, Stillhouse Hollow, Granger, Georgetown, Whitney and Somerville, are particularly valuable as recreational resources. Cultural resources are represented by Dinosaur Valley State Park near Glen Rose and historical areas at Washington-on-the-Brazos and Stephen F. Austin State Parks, just to name a few. The Authority is committed to protecting these resources."
The paragraph makes a broad statement about features within the Brazos basin, without identifying specific priorities or designations.

2. On page 4-7 under section 4.3 you say you are committed to protecting these resources. Can you explain this in more detail as it relates to recreational use and lake levels.

Based on its enabling legislation, the Brazos River Authority (BRA) is authorized "to conserve, control, and utilize to beneficial service the storm waters and floodwaters of the rivers and streams of the state ..."

In this regard, the BRA has constructed and owns three water supply reservoirs, and has contracted with the US Army Corps of Engineers (USACE) for water supply storage in eight other reservoirs throughout the basin.

While recreational use of reservoirs and rivers meets a need for a specific component of the population, the primary purpose of the BRA's reservoirs is water supply. Two of those reservoirs, Lakes Granbury and Limestone, were constructed under cooperative agreements with electric generation utilities. Construction costs for these reservoirs were fully funded by those utilities with an expectation that water stored in the reservoirs would be available to meet their needs as defined in the original agreements.

Additionally, the BRA has entered into long-term contracts with other customers for the reliable supply of water from the BRA's water supply system to meet the needs identified in those contracts.

Section 4.1 of the permit application (page 4-1) contains the following statement:

"System operation on a firm yield basis actually improves lake levels by leaving more water in storage in the Authority system much of the time when compared to the base Brazos WAM. However, during extended dry periods there is less storage in the system." (emphasis added)
The "Brazos WAM" is the water availability model (WAM) used by TCEQ for analysis of water right permit applications. It was used by the BRA consultants in the development of the permit application, and many of the analytics contained in the permit application are products of the Brazos WAM.

In layman's terms, Section 4.1 validates the need for reservoirs and the implications of those reservoirs being put to their intended use. When there are insufficient flows in the river to meet water supply needs, reservoir storage will be used to meet those needs, and reservoir levels will go down accordingly.

When the BRA indicates that it intends to be protective of resources, the term "resources" needs to be interpreted in its broadest definition and all inclusive. The resource within the BRA's water supply system is the water stored in its reservoirs which fulfills the needs established in the contractual relationships the BRA has with its customers. That stored water also means, to others, the ability to access reservoirs for recreational purposes.

Recreational opportunities are a secondary benefit provided by the presence of water supply and flood control reservoirs. The BRA has promoted recreational opportunities by providing free boat ramps, parks, picnic and camping facilities at the three BRA-owned reservoirs. In addition, recent evidence of the BRA's commitment to recreation and lake levels can be found in the Possum Kingdom-Granbury-Whitney Water Management Plan adopted by the BRA's Board of Directors in April 2011. The principal component of the study was to determine how BRA could continue to meet its water supply demands while being sensitive to recreational aspects associated within that reach of the basin. The study and its findings have been briefed numerous times to audiences at both Possum Kingdom and Lake Granbury. For additional information on the Possum Kingdom-Granbury-Whitney Water Management Plan, click here.

3. On page 4-18 you note that reservoir elevation (sic) will be a key consideration in developing the WMP. Again can you explain this in relation to water levels and recreational use.

Section 4.7 deals with Other Issues, and the paragraph referenced above is as follows:

"Reservoir elevation will be a key consideration in developing the Water Management Plan, which will balance recreational needs, instream flow needs and current system demands."
This statement follows a graph which shows the results of an analysis of projected total system storage in 2060, with and without the System Operation Permit.

Recreational use of the waters of the Brazos basin is not limited to lakeside interests. As indicated in Section 4.3:

"The main stem segments from Morris Sheppard Dam to US 180 and from De Cordova Bend to Lake Whitney are popular with canoeists."
Recreational interests compete for water and the BRA is well aware of the variety of recreational interests throughout the basin. On a given day, the BRA may field questions and comments from citizens expressing their displeasure with a lake elevation and the release of water downstream, while other citizens express their displeasure over the fact that the BRA is not releasing enough water from the reservoir to maintain their impression of adequate instream flows.

The BRA's primary mission is water supply. Reservoir elevation is a measure of the inventory the BRA has in reserve to meet the contractual needs of its water supply customers; so, naturally the BRA desires for all of the reservoirs to be full. However, reservoirs are developed to supply water, and by that very nature, reservoir elevations will decline during dry times as the supply is used. While meeting its water supply commitments, the BRA will strive to balance adverse recreational impacts within the basin.

4. In looking over Table F-1 and the associated graphs it appears to indicate that you expect the greatest amount of withdrawal from Lake Granbury to occur from April through June during the year (on a Median basis). Would this mean we can expect to see minimal drops in elevation over the summer months? If not, can you explain the meaning of the figures.

Table F-1 deals with an analysis of low flow statistics of the Brazos River near Waco. Potential withdrawals from Lake Granbury are not specifically mentioned within this particular section of the permit application.

Submitted, May 24 by Frank Foster

Will any of the 9 meetings be held at Possum Kingdom? Thanks.

Yes, a meeting is scheduled for August 7 at Possum Kingdom Lake. Location and time will be published when the venue is confirmed.

Submitted, May 22 by Roane Lacy

Will there be a meeting in Waco. When? Will the plan address adjudication of existing riparian rights?

The Brazos basin stretches from the New Mexico border to the Gulf of Mexico. Due to its central location in the Brazos basin, Waco is the home of the BRA's Central Office. However, the BRA does not have water rights in the general vicinity of Waco, nor does it have existing or potential future customers. Issues relative to the City of Waco and its water rights were settled through negotiation during the development process for BRA's pending permit.

The Water Management Plan addresses only the operation of the Brazos River Authority's water rights. All water rights in the Brazos River Basin were adjudicated in the 1980s. Any questions concerning water rights in the Brazos basin generally should be directed to the Texas Commission on Environmental Quality.

Submitted, May 21 by the City of Clifton

1. Does the "available flow" the BRA intends to "appropriate" exclude or include current water rights holders' permitted diversions?

The "available flow" BRA is seeking excludes current water rights holders' permitted diversions. BRA's System Operation Permit only seeks to appropriate flows that are not currently dedicated to any other use (via permit or right).

2. Will the intended "appropriated flow rights" have superior rights over all existing rights holders? I.e. Permit 5551 permits the City of Clifton to divert up to 2,004 acre-ft per year to our off-channel reservoir, subject to monthly minimum flow rates?

No, the System Operation Permit will not have superior rights over any other perpetual water rights that were issued prior to October 15, 2004. The City of Clifton's Permit 5551 has a priority date of April 3, 1996, which makes it "senior" to the BRA System Operation Permit.

3. How does the BRA's plan relate to the TCEQ's intent to set up a "Watermaster" organization for what reads like the same purpose?

BRA is seeking a new water right permit. The purpose of a Watermaster is to enforce water rights within the priority system, especially in times of drought or shortages. BRA's new permit, just as its existing permits and permits belonging to others, are subject to the TCEQ's jurisdiction, and the Watermaster would be an arm of TCEQ. The two activities compliment, rather than duplicate.

4. Where does the BRA see "convergence" of state organizations independently managing groundwater and surface water resources?

BRA does not have the legal authority to enforce or regulate. BRA manages its surface water resources just as the City of Clifton does under the TCEQ's jurisdiction. BRA's policy is to operate within the requirements and standards imposed by entities and agencies with regulatory authority to manage water resources, whether they be groundwater or surface water.

Submitted, May 21 by the cities of Simonton and Wallis

The cities of Simonton (and Wallis) would like to know the locations of the other six meeting in order to plan to attend the one closest to the city.

Nine public stakeholder meetings will be held throughout the Brazos basin for public comments on the Water Management Plan They are:

June 5

Bryan

June 6

Temple

June 7

Granbury

   

August 7

Possum Kingdom Lake

August 8

Taylor

August 9

Brenham

   

October 16

Glen Rose

October 17

Temple

October 18

Lake Jackson

Specific locations for the August and October meetings will be published as they become available. For a printable version of the public meeting dates, click here.

 



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