Protecting the Pedernales and The Dangers of Direct Discharge

The Pedernales River is one of Texas’s most cherished waterways, an ecological, recreational, and cultural treasure that defines the Hill Country. As stewards of this vital resource, the Pedernales River Alliance (PRA) has opposed the wastewater permit application (WQ0016363001) submitted by the Village at Grape Creek (now the Village at Fredericksburg) to the Texas Commission on Environmental Quality (TCEQ).

The Village -Fredericksburg is located on Hwy. 290, near Jenschke Lane and consists of 242 tiny home units with amenities, including “the largest resort-style pool in all of Fredericksburg”. If approved, this permit would allow the discharge of 20,000 gallons per day of treated wastewater into Beckmann Branch, a tributary of the Pedernales, threatening water quality, habitat integrity, and the rural character of the region.

The Village’s Wastewater Discharge permit application is making its tortuous way through TCEQ. Over 125 individuals and groups submitted comments, all in opposition to the permit and a contentious public hearing was held on June 13, 2024 at the Inn at Baron’s Creek.

On February 27, 2025, the TCEQ Commissioners will decide three main issues:

    • if a contested case hearing will be held by the State Office of Administrative Hearings (SOAH)
    • if a hearing is granted, who has “standing” to participate in the hearing and
    • what issues can be raised at the hearing.

The Pedernales River Alliance is asking for standing to participate.  Our position is that Hill Country streams are not wastewater pipelines. Even with modern treatment technologies, direct discharge introduces nutrients like nitrogen and phosphorus into the water, and which can fuel algae blooms, degrade aquatic habitats, and reduce water clarity. The Pedernales is already
facing water quality challenges, and adding more pollutants could have devastating long-term effects.

Beckmann Branch is a small, sensitive stream with intermittent flow and does not have the capacity to dilute and assimilate wastewater like larger rivers do. During dry periods, effluent could make up the majority of its flow, turning a dry stream into a wastewater conduit. The result? Increased risks of contamination, reduced oxygen levels for aquatic life, and increased threats to landowners, agriculture, and wildlife.

The Pedernales watershed is home to working ranches, wildlife corridors, and families who have lived along these waters for generations. Increased wastewater discharge poses risks to groundwater recharge, drinking water wells, and livestock operations that depend on clean water.

The porous Hensel Sand Formation is located at the surface of the site and waste water discharge has the potential to influence nearby water wells. Moreover, the river supports diverse wildlife, including sensitive fish and amphibian species that require pristine conditions to survive.

Yes, there is an Alternative: Land Application, a responsible alternative to direct discharge. Beneficial land applications where treated wastewater is used for irrigation rather than being dumped into Beckmann Branch offers a sustainable approach that protects waterways while still accommodating responsible growth. The Fredericksburg Standard on January 22, 2025 told how Arch Ray Development has done a “180 on 290”, and will not be directly discharging into the Pedernales. The Village at Grape Creek should be required to do the same.

TCEQ must prioritize water quality over development. Texas law mandates that TCEQ safeguard the state’s water resources. Granting this permit would undermine that duty and set a dangerous precedent for future developments seeking to discharge into sensitive Hill Country creeks and rivers. The Pedernales River Alliance is urging TCEQ to deny this application and
require the developer to adopt a wastewater solution that does not jeopardize our water.

The Hill Country is at a crossroads. Will we allow unregulated growth to degrade the natural treasures that make this region special? Or will we demand responsible development that respects our land, water, and communities? The answer should be clear: TCEQ should protect
Beckmann Branch, protect the Pedernales, and reject this permit.
To support the efforts of Pedernales River Alliance, join and contribute at
Pedernalesriveralliance.org

Give Today!

The Pedernales River Alliance (PRA) is a member of the Greater Edwards Aquifer Alliance (GEAA).  One of the things that GEAA helps us with is the collection of donations. 

Follow this link to the  GEAA Donation Page
 
When you see “Write a Note” 
Click on it and Insert “for Pedernales River Alliance”
 
Thank you very much for helping us care for our River.
 

Katherine Peake
830 998-1778
kbfpeake@gmail.com

 

Contested Case Hearing

Some of you may have received a ton of paper from TCEQ this past week. You are receiving it because you made comments concerning The Village at Fredericksburg’s (used to be Grape Creek) permit to dump 20,000 gallons of Type 1 effluent into Beckmann Branch.

The Branch is actually a recharge zone for the Hensel Aquifer. The Ellenburber lies just below the Hensel. Dumping Type 1 into the Branch is not a good idea if we want to preserve and protect our aquifers. But the Village does not really care about that. They think they should be allowed to dump into the Branch regardless of what we want. Because we have asked for this permit to go before a Contested Case Hearing, a lot of paper has been generated.

Read it all. You need to know what we are up against. Our opponents are high powered attorneys from Houston who do not care at all about our aquifers. We also know that there are some legitmate disposal methods for Type 1 effluent which is what The Village will be producing. With a little purple piping they could send their effluent over to water the lawns at some of the facilities around them. They do plan to use some for their own irrigation. Why not install storage tanks for fire fighting? There are lots of ways to use Type 1 effluent that we do not need to go into here. Just be aware that the Village refuses to entertain any of those ideas.

Anyway, back to all that paper. No one needs to attend the Feb 27 meeting. The Commission will not take oral argument or comments on the hearing requests. One of the Commissioners will likely walk through a prepared analysis and make a recommendation. The other two will likely agree with that analysis. They will make a motion, vote, and it will probably be over in about 5 minutes. That being said, if people want to attend, they are certainly welcome, though I think because the ED has recommended granting PRA and GEAA’s hearing requests, it is less important that people attend but Pedernales River Alliance members Will be present along with our lawyers.

It is what happens after the Feb 27 hearing when we will need your help. We know that we will need help identifying locations where there are Fatmuckets (fresh water mussel that are endangered). We will likely have to hire a biologist for this effort. We will likely have to hire others who can provide expert testimony about other issues. How can you help?

Tell your friends and neighbors about the Village and their plans to dump effluent into your drinking water. Tell your friends that the Pedernales River Alliance is fighting back. Donate to help us continue the fight — no donation is too large! https://www.pedernalesriveralliance.org/donate-to-the-pedernales-river-alliance-gillespie-county/

 

Let’s “Save it, Don’t Pave it!”

Recently, I saw a phrase on a t-shirt: Save it, Don’t Pave it! (https://aquiferalliance.org). The Aquifer Alliance is attempting to raise awareness of how detrimental concrete can be to the Edwards Aquifer.

We here in Gillespie County need your help with our own aquifer, the Ellenburger Aquifer,  which provides most of the drinking water for Gillespie County. It is in trouble. Recently, a Hill Country Critical Groundwater Depletion Area 1 was declared for the Ellenburger. The drought and normal usage of water has reduced the aquifer’s levels to a point where we must all take efforts to cutback our water usage.

But it rained! And we expect more!! But if there is one thing we all know, the weather is not consistent. Just when you think rain is coming, it doesn’t. Just when you think it will be cooler, it won’t be. The only thing we know with certainty about the weather seems to be that it seems to have a mind of its own. This means we should all consider how best to make cutbacks to our water usage permanent.

One way is to not put down concrete. For years, we have been paving parking lots, walkways and driveways using caliche topped with crushed granite. This construction allows for rainwater to soak into the ground. When water soaks into the ground, it has a much better chance of recharging our aquifer. Concrete, on the other hand, just helps to create runoff which is, by definition, pollution.

Water that falls on lawns tends to run off to roads carrying excess fertilizer and even dog poo. The runoff hits concrete roads and picks up oils, residue from tires, dirt, debris, trash and more. Short or light rains do not always push this runoff down to the river but a frog floater (colloquial term for a whole lot of rain at one time) will. When a lot of water from a heavy rain hits the seasonal creek beds, everything, including the now concentrated pollution, goes downstream to the Pedernales River.

I watch the river and see people fishing, wading, swimming and kayaking in it. Even when you think the River is too low for these activities, folks find a low water crossing and they play in the Pedernales…and, if we’ve had a recent frog floater, they unknowingly play in the polluted water.

More importantly, when you understand that all water in the Hill Country is connected–streams, creeks, river, springs and aquifers, then you know that any pollution anywhere in the Pedernales Watershed is too much. (See “The Journey of Groundwater” https://youtu.be/52Ln-LBr5ZU)

We all need to conserve water in any and every way that we are able for the benefit of all. If you are building a new home or business or upgrading your own property, please put in a permeable surface for your parking areas, walkways and patios. Save it, Don’t pave it!

Deborah Youngblood
Pedernales River Alliance
https://pedernalesriveralliance.org

Exceptional Drought

What does it mean for the Texas Hill Country, specifically Gillespie County, to be in “Exceptional Drought?”

First, look down. The soil has become dry and hard with large cracks. Because soil moisture is low, dust or sand storms can occur. Hard dry soil makes it difficult to plant crops. 

Look to your neighbors’ pastures and notice that forage is stunted and dry. Pasture conditions have become poor. Some are having to purchase supplemental feed for their livestock because hay production is reduced, crops are stunted. Irrigation is required but, even for irrigated crops, yields are down. Pastures become empty as producers sell off livestock. Entire herds are sold.

Reach down and touch the bits of grass that still cling to the soil. See how brittle and dry it is and know that this is now fuel for grass fires. As the afternoon winds pick up, sucking all remaining moisture from the air, wildfire danger becomes severe. Burn bans were instituted months ago but now, violators are fined and we are cautioned against fire pits and bbq’s and parking cars on grass. We know that our entire world can change with one careless flick of a cigarette.

With each passing day, our water table drops. The city of Fredericksburg restricts lawn watering. Surcharges on excessive water use begins and rationing of water begins to be considered a viable course of action. Fountains cease jetting water. Bulk sales of potable water will be prohibited next. 

This is where we are right now-we are in an “Exceptional Drought.”

For those living outside of the city limits, water rationing is self-imposed. Most of our wells are not metered. Times like these make water rationing with the use of metered wells seem like not such an unreasonable method of reducing water usage. 

In this county, we depend on our wells to see us through the summer. At the rate we are going, many wells won’t make it. Residential wells, especially the more shallow wells, are extremely vulnerable. The aquifer seems like a  mysterious water-filled place but in reality, an aquifer is not just an underground pool of water. Instead, water flows through the limestone in rivulets and channels. As the water table drops and the underground channels go dry, wells begin to dry up. The only recourse is to drill deeper but how deep is too deep? We do not know.

Pedernales River @ Jung Lane. Exceptional Drought. 7-03-2022
Pedernales River @ Jung Lane

The geology of the Texas Hill Country is limestone with lots of holes and channels. It is called karst geology and it has taken millions of years of erosion to create this underground drainage system. We know that as surface water, in rivers, creeks and lakes, dries up, groundwater-the water that flows through the karst, our only remaining source of water, is drying up, too.

We look for every person, every family, every tourist and every company to conserve water. Right. Now. What can YOU do to conserve water?

  • Fix those leaky faucets
  • Put a brick in your toilet tank
  • Water only when you are allowed to by the city
  • If outside city limits, water only once a week in the morning
  • Limit the length of showers
  • Take a bath instead of a shower – only the shortest of showers uses less water than a partially filled bathtub
  • Install low-flow shower heads
  • Don’t just let the water run while you are brushing teeth, shaving, doing dishes or anything else!
  • Wash only full loads in the dishwasher and washing machine 
  • Proudly drive your dirty car
  • Mulch trees and plants
  • Plant native plants
  • Think positive-get a rain barrel hooked up to your gutter system
  • Restaurants-only serve water on request
  • Businesses-turn on your sprinkler systems and check to see if they water the street. If they do, fix them. 
Pedernales River @ Goehmann Lane. picture taken 6-19-2022
Pedernales River @ Goehmann Lane

Sources:

National Drought Mitigation Center https://droughtmonitor.unl.edu/CurrentMap/StateDroughtMonitor.aspx?TX

NOAA
https://www.drought.gov/states/texas

Hill Country Underground Water District
https://hcuwcd.org/

Texas Water Development Board
https://www.twdb.texas.gov/newsmedia/drought/doc/weekly_drought_report.pdf

Ways to Use Water Wisely: 100+ Ways to Conserve Water
https://wateruseitwisely.com/100-ways-to-conserve-water/?view=list