8/06/2024
We had a great information meeting yesterday. It was good to have so many folks present and you all asked some really great questions.
We spent a lot of time talking about how to make comments and ask questions of ArchRay and TCEQ. It is important for us to have our comments and questions ready before the meeting on August 19th. Can’t remember how to upload? Here is the link to the Public Meeting Participation Guide.
Start working on those now and have them uploaded to TCEQ prior to the meeting. Be sure to bring your questions to the Public Meeting so that you can directly ask either ArchRay or TCEQ. Stay at the meeting and re-ask your your questions so they can be recorded for the record.
Here is a handy template to help you format your questions:
Mark your calendars, The Public Meeting with TCEQ and ArchRay Developers will be held on
Monday, August 19, 2024 at 7:00p
Rockbox Theater
109N. Llano Street
Fredericksburg, Texas 78624
7/24/2024
Have you submitted your comments to TCEQ on the ArchRay permit to dump 35,000 gal/day of effluent into the Pedernales River? If not here are few things to keep in mind:
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- Water flow in the Pedernales River is not consistent enough to support an increase of effluent.
- Residents of Gillespie County and the PRA do not want any effluent discharged into the River.
- The Pedernales River is a recharge zone for the Ellenburger aquifer which provides most of the drinking water in Gillespie County.
- The Pedernales has been declared a critical habitat for endangered fatmuckets, a species of freshwater mussels.
- ArchRay plans to discharge by way of an open ditch that will drain to the river. Because it is an open ditch, it will collect stormwater as well.
- ArchRay has plenty of room to employ TLAP or reuse but has resisted both.
- ArchRay will be discharging a short distance upriver from their own housing development which advertises “access to the Pedernales River.”
- The city of Fredericksburg has a permit to dump 2.5 million gallons/day into the River. Fortunately, they have a strong reuse program that helps them to not dump effluent during the summer but, during rainy times or the winter, they tend to dump.
- Currently, there are no other permits allowing discharge of effluent.
Go to https://www.pedernalesriveralliance.org/tceq-template/ to find how to submit your comments.
7/10/2024
Mark your calendars, The Public Meeting with TCEQ and ArchRay Developers will be held on
Monday, August 19, 2024 at 7:00p
Rockbox Theater
109N. Llano Street
Fredericksburg, Texas 78624
After introductions, you may ask the developers or TCEQ any question. Please note, if you have already asked your questions in your online comments, it is not necessary to ask them again as all online questions will be answered offline via USPS. However, if you feel that your question(s) is important enough to ask it in this public forum, do so. During this part of the meeting you may also make comments to describe what the Pedernales River means to you. Please limit your questions and comments to this permit. This is an open discussion time with the developers and TCEQ. Note: comments or questions made during this first period are not for the record.
Please plan to stay for the second half of the meeting, which is very important. Any questions or comments you have not submitted online can be asked for the record during this time. It is vital that we get your unasked questions and comments recorded. If you are unable to stay, please consider writing your comments and questions down and submitting them for the record.
The Pedernales River is a direct recharge zone for the aquifer that provides drinking water to most of Gillespie County. No treated wastewater is fit to drink. Help us protect our drinking water and our river — make your comments and plan to attend this meeting.
4/02/2024
Four members of the Pedernales River Alliance Steering Committee met with the Baxter Family, owners of Arch Ray, 3 personnel from OVIVO, the manufacturer of the OSSF to be installed, and several of the Arch Ray management team members.
The Baxter Family did provide a copy of the wastewater permit for onsite analysis. They have not yet posted a copy of the draft permit) at either the courthouse or public library in Fredericksburg. The engineer from OVIVO provided us with a link to the package for download.
Maria, from OVIVO, presented a thorough presentation about the OSSF.
We listened and asked pertinent questions to ensure we understood how the facility will work. We were impressed by the membrane technology. While the system appears effective it may not be able to clean wastewater to the standards our River needs in order to avoid additional algae build up.
We listened carefully to everything that was said but we were most surprised when we suggested getting a TLAP (land application permit instead of a permit to pollute the Pedernales River (TPDES), Shane Baxter pushed back and seemed concerned about stormwater flushing effluent from the soil if used for drip irrigation. The only way that this might be an issue is if the irrigation system is not build in accordance with standards set by TCEQ.
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ENVIRONMENTAL QUALITY |
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TEXAS COMMISSION ON ENVIRONMENTAL QUALITY |
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USE OF RECLAIMED WATER |
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GENERAL REQUIREMENTS FOR THE PRODUCTION, CONVEYANCE, AND USE OF RECLAIMED WATER |
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RULE §210.24 |
Irrigation Using Reclaimed Water |
When the potential for building a holding tank for the effluent was suggested, Shane Baxter and the engineer from OVIVO were not supportive of the idea despite clear specifications and standards provided by TCEQ. None of this made much sense in light of their plan to put effluent into an open ditch where it will be subject to stormwater. evaporation and undiluted access to the effluent by wildlife as it proceeds downhill to the River. Although a TLAP would be the best solution, the Baxters are resistant.
We spoke briefly about Dark Skies and the need to darken their entire site, including remove the high density flashy electronic billboard.
We also spoke briefly about the need to landscape with native plants. They seemed supportive of this idea.
3/22/2024
Arch Ray did submit a application for wastewater discharge permit. All we know, however is the amount – 35,000 gallons per day. The application can be seen at the Hostess Desk at Arch Ray. You can go look but you they will not copy it for you and they will not let you use their copier even if you reimburse them the expense. This is legal but not really helpful. The application is large and will take some study which we cannot do standing at the Hostess Desk. So, we have not actually studied the application.
Since we cannot study the application there is no way for us to ask questions about anything in the application. Nor can we develop helpful suggestions. We can only really voice support or non-support of the application. Unfortunately, not being able to study the application also means that we are left wondering what is in the application that they do not want us to see. We will continue to try to get a copy. Hope springs eternal!
01/05/2024
Arch Ray has submitted a request for a permit to dump 35,000 gal of treated sewage into the Pedernales River every day. This is unacceptable. Further downriver the algae growth is beginning to choke the river. This has to stop. This company can surely afford to process their wastewater using Land Application methods so why dump it into the River? If you feel as strongly as we do, make your comments to TCEQ right away. Go to https://www.tceq.texas.gov/agency/decisions/cc/cc_db.html
Click on the button “Comment online about pending permit applications”
On the next page, enter WQ0005452000 into Permit Number
Click on Next
The page that opens requests your personal identification…just to make sure you are a real person. Complete entering your information.
In the Comments text box, enter your comments.
Sometimes it is difficult to know what to say in the comments. I recommend that you talk about what the river means to you. Be sure to ask for a public meeting. Also ask the permit to dump treated sewage into the Pedernales River be denied. You may suggest that they be required to process their sewage in a land application. Finally, be sure to request that the highest levels of cleaning possible be required to reduce Total Suspended Solids and Biochemical Oxygen Demand to be set at a maximum of 5 mg/l for both an E. coli testing and limits be set to protect the wildlife and public safety.
Share your comments with friends, family and neighbors. And thank-you for submitting them to TCEQ.
11/22/2023
This morning I took a phone call from long time resident of Gillespie County. It was a distressing. Arch Ray appears to be installing a very large Wastewater Treatment Facility in the tiny home community. We are very surprised at that as they have not submitted a request to TCEQ for a discharge permit into the Pedernales River. Nor have they asked for a permit to allow for discharge onto the land. We are truly hoping that this is not a case of “build it now and ask for permission later.”
11/21/2023
We have been wondering about Arch Ray, especially now that “the wall” is up. More obvious are the facilities we can see. They have wine tasting, a production room and a restaurant. To the east of these is an RV park and just east of that is a new enterprise that looks like it will be a tiny home community. Rumor mill has lots of ideas about how their wastewater will be handled for the this new tiny home community. The most concerning is that they might be planning to discharge their wastewater into the Pedernales River.
We have heard from reliable sources that Arch Ray has hired a hydrologist to do a floodwater study because they are building in or near the floodplain. and they have started pouring the slab for the wastewater treatment plant. We also checked with the county about any permits that might be required. At this time we are still a little uncertain about the need for a permit for a wastewater treatment plant. More to come on that.