August 20, 2019
Office of the Chief Clerk
Texas Commission on Environmental Quality
P.O. Box 13087
Austin, Texas 78711-3087
VIA ELECTRONIC FILING
RE: Comments on Silesia Properties, LP’s draft permit for
TPDES Permit No. WQ0015688001
Dear Chief Clerk:
Save Our Springs Alliance (SOS), the Greater Edwards Aquifer Alliance (GEAA), and the
Texas Rivers Protection Association (TRPA) jointly submit these comments on the draft
permit issued to Silesia Properties, LP (Silesia or Applicant) for Texas Pollution Discharge
Elimination System Permit (TPDES) No. WQ0015688001. If issued, this permit would
authorize the construction of the Honey Creek Ranch Wastewater Facility Treatment
Facility and the discharge of up to 500,000 gallons of treated wastewater per day into a dry
tributary of Honey Creek upstream of the Honey Creek State Natural Area and Guadalupe
State Park.
SOS is a non-profit organization that works to protect the Edwards Aquifer, its springs and
contributing streams, and the natural and cultural heritage of the Hill Country region and
its watersheds, with special emphasis on Barton Springs. SOS has members who own
property downstream of the proposed discharge point and who own property adjacent to
the site of the proposed wastewater treatment facility. These members would be adversely
affected by Silesia’s application. SOS also has members who recreate in Honey Creek State
Natural Area and Guadalupe State Park.