Impact of Alcoa pumping 1990-1999 on left side of graph.

Environmental Stewardship is very concerned about actions that might be taken by the Post Oak Savannah Groundwater Conservation District Board of Directors related to the subject well permit application by Alcoa. We believe Alcoa’s wells in the Milam County portion of the Simsboro Aquifer currently impact, and the additional wells will further impact and endanger, the Colorado River and its tributaries and existing permit holders in Bastrop and Lee counties.  Based on the information available, and for the reasons stated below, we oppose issuance of the requested permits.  We further request that Environmental Stewardship be granted an opportunity to provide input at that hearing as an affected party.  Click here for ES letter to Post Oak Savannah GCD.  
Though the wells subject to this permit are not in Bastrop County where the Colorado River flows across the same aquifers, we believe we have credible evidence from our analysis of the GMA-12 DFC GAM files that these wells are having a significant impact on outflows to the Colorado River and its tributaries and the additional 25,000 ac-ft/yr of pumping requested will exacerbate these impacts. Environmental Stewardship is the owner of real property on the Colorado River and believes that issuance of the permit will adversely impact the flow of the river, especially during periods of severe drought like we have been experiencing. 
Environmental Stewardship is hereby submitting the enclosed documents as testimony to our allegation that pumping of the Alcoa wells and the requested additional wells have a direct impact on the Colorado River and likely will impact other permitted wells in both Bastrop and Lee counties. 
Exhibit 1.          ALCOA Simsboro pumping reported to RRC (1990-1999)
Exhibit 2.          GMA-12 MODFLOW Predictions of Net Groundwater Discharge to Colorado River and Tributaries (1990-2060):  Though we accept that the results of such GAM analysis are not “quantitative”, these analyses provide regional trends, and such trends need to be considered in permitting groundwater in the region. It is evident from an analysis of the MODFLOW output and the ALCOA pumping record (Exhibit 1) that there is likely a correlation between the Alcoa pumping and outflows to surface water resources. This relationship needs to be investigated and considered.
Exhibit 3.          Springs of Bastrop County:  The springs that were documented by the Bastrop County Environmental Network (BCEN) in the early 1990s were investigated by Environmental Stewardship in 2007-8.  Unfortunately, none of the springs documented in the Utley-Bastrop river segment in the vicinity of the Alcoa operations were flowing in 2007-8. 
Exhibit 4.          Colorado River Paddling Trail Aerial Photocard – Wilbarger Trail.  Colorado River Paddling Trail Aerial Photocard – El Camino Real Trail.   The Wilbarger Trail Photocard documents the location of the springs in Exhibit 3 (and additional flowing springs found in 2007).  Unfortunately, springs 1-6 on the photocard were NOT FLOWING in 2007-8. 
Exhibit 5.         Analysis of Proposed Aqua Water Supply Drilling Permits Using the Queen City/Sparta GAM. September 17, 2008.  Bob Kier, LPGCD Hydrologist.  Dr. Kier investigated the cross-boundary impacts of pumping by in the Porter’s Branch well field in Burleson County by POSGCD’s permit and concluded that the pumping “seriously affects water levels in Lee County and even Bastrop County.” ES contends that such similar pumping by the existing and requested additional Alcoa wells in Milam county has a similar impact on existing and future wells in Lee and Bastrop counties and the Colorado River. The Texas Water Code requires that these impacts be investigated and considered before new permits are allowed.
Exhibit 6.          Lost Pines GCD Agenda, September 17, 2008.  Lost Pines GCD Minutes for September 17, 2008:  These minutes document the  discussion and decisions made based on the Kier analysis presented in Exhibit 5.
 Sec. 36.113 of the Texas Water Code.  PERMITS FOR WELLS; PERMIT AMENDMENTS (d).  Before granting or denying a permit or permit amendment, the district shall consider whether: (2) the proposed use of water unreasonably affects existing groundwater and surface water resources or existing permit holders.
Based on the above cited Texas statute, Environmental Stewardship believes it is the duty of the Post Oak Savannah GCD to investigate and reasonably consider the real or potential impacts of the proposed wells and the additional 25,000 ac-ft/yr of pumped groundwater on the Colorado River, its tributaries, and the existing groundwater resources and permit holders in Bastrop and Lee counties. 
 As such, Environmental Stewardship opposes the Alcoa permit application and requests that the Post Oak Savannah GCD Board deny the application until such time as the impacts on cross-boundary groundwater and surface water resources and permit holders have been thoroughly investigated and reported to the Board and public. 

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