•
-Life's
better
outside.'"
Commissioners
Ralph
H.
Duggins
Chairman
Fort Worth
S.
Reed
Morian
Vice-Chairman
Houston
T.
Dan
Friedkin
Houston
Anna
B.
Galo
Laredo
Bill Jones
Austin
Jeanne
W.
Latimer
San
Antonio
James
H.
Lee
Houston
Dick Scott
Wimberley
Kelcy L. Warren
Dallas
Lee
M.
Bass
Chairman-Emeritus
Fort Worth
Carter P. Smith
Executive Director
4200
SMITH
SCHOOL
ROAD
AUSTIN, TEXAS 78744-3291
512.389.4800
www.tpwd.texas.gov
September 7, 2018
Ms. Bridget C. Bohac, Chief Clerk
Office
of
the
Chief
Clerk (MC 105)
REVIEWED
SEP
1 1
2018
BY.,V
Texas Commission on Environmental Quality
PO
Box 13087
Austin, Texas 78711-3087
V1
I'.)
Re:
TCEQ Municipal Wastewater Discharge Draft Permit Number WQ0015688001
Dear Ms. Bohac:
The Texas Parks and Wildlife Department (TPWD) appreciates the opportunity to provide
comment on the proposed new municipal wastewater discharge permit for the Silesia
Properties, LLC' s proposed new wastewater treatment plant (Permit No.
WQOO
15688001
).
TPWD is the agency with primary responsibility for protecting the state's fish and wildlife
resources (Texas Parks and Wildlife Code §12.001 l(a)). Furthermore, we are charged with
providing information on fish and wildlife resources to any local, state, and federal
agencies
or
private organizations that make decisions affecting those resources (Texas
Parks and Wildlife Code §12.001 l(b)(3)).
Please be aware that a written response to a TPWD recommendation or informational
comment received by a state governmental agency may be required by state law. For further
guidance, please see Texas Parks and Wildlife Code Section 12.0011.
TPWD
has reviewed the pending Texas Pollutant Discharge Elimination System (TPDES)
wastewater discharge permit application for Silesia Properties, LLC to discharge treated
wastewater
at
a volume not to exceed an annual average flow
of
500,000 gallons per day
via a pipe from the plant site to a dry tributary, thence to Honey Creek (Segment 1427).
TPWD has several interests very closely tied to this proposed discharge. First, Honey Creek
is a unique, pristine waterbody with exceptional aquatic life use, and the proposed increase
in nutrients to a nutrient-sensitive watershed could alter the trophic nature
of
the creek,
which in turn could impact aquatic life and the broader ecosystem
of
the watershed.
Second, the proposed discharge could adversely affect state-threatened and federally-
petitioned endangered species present in the watershed. Last, and certainly not least,
TPWD owns and manages the adjacent Honey Creek State Natural Area, through which
the proposed discharge would flow.
Background on Honey Creek State Natural Area
Honey Creek State Natural Area (HCSNA) is 2,293.7 acres located on the northern border
and topographically down gradient
of
the proposed Honey Creek Ranch development. The
area, once a ranch, was acquired by The Nature Conservancy (TNC) in 1980. TPWD
purchased the property in 1985 from TNC to conserve its biologically unique and distinct
ecological features. Since that time the HCSNA has been managed to preserve those
intrinsic natural features and has been open for limited access for the sole purpose
of
science, education, nature, and aesthetic appreciation.
To
manage
and
conserve the natural
and
cultural resources of Texas
and
to
provide hunting, fishing
and
outdoor recreation opportunities for the use
and
enjoyment of present
and
future generations.