Aug. 13, 2018
Comments on Honey Creek – Application, WQ0015688001
Dr. George Veni, hydrogeologist
I am the Executive Director of the National Cave and Karst Research Institute, which was
created by Congress as the national authority on caves and the vulnerable karst terrains
and aquifers in which they occur. I am also a karst hydrogeologist. My PhD dissertation was
focused on the proposed wastewater area. Though I currently live out-of-state, I still
maintain the database on Comal County caves and karst features for the nonprofit Texas
Speleological Survey (TSS) and continue to visit and study the area regularly.
Some people are concerned about the project because it is near Honey Creek Cave (HCC).
HCC is the longest cave known in Texas with over 32 km of mapped underground streams.
The known portions of HCC do not extend under the proposed wastewater project site or
the outfall of its effluent. Also, no caves are known to the TSS at the project site for two
possible reasons. First, the TSS has not received any reports from cavers or consultants
who may have searched the property for such features. Second, that uppermost part of the
lower Glen Rose Limestone does not form many cave entrances (most form in the lower
section of the limestone), although groundwater recharge into the Lower Glen Aquifer
(LRG) occurs readily there.
While the mapped part of HCC does not extend under the property, there is one significant
underground stream in the cave that heads toward it. It is unexplored due to dangerous
conditions. Based on the fact that there is no known spring to account for the substantial
flow in that passage, and that the geology would not allow a spring to pop-up unobserved
in the bottom of the Guadalupe River or its tributaries in that area, I speculated long ago
that the water flows southeast into the Cibolo Creek basin and then across faults into the
Edwards Aquifer. Later, in my PhD dissertation on the LGR, I plotted the surface of the
water table and geochemical parameters that showed groundwater in fact does move from
that part of HCC, under what is now the proposed wastewater site, and to the Edwards
Aquifer as I speculated. I also found the faults where that groundwater would likely cross
from the Lower Glen Rose Aquifer into the Edwards Aquifer.
I’ve long said that while my evidence is very compelling, it is not 100% proof of a
connection. More research is needed. However, since writing that 24 years ago, the State
has accepted the existence of a general connection between the LGR and Edwards Aquifer
as I proposed. It would therefore be prudent of the State to consider this wastewater site as
potentially within the boundaries of the Edwards Aquifer and subject to review under
those rules. It would also be proper for the State to review the area where the LGR and
other adjacent aquifers may contribute to the Edwards Aquifer and include them where the