_______________Austin’s water watchdog since 1992_______________
4701 Westgate Blvd, D-401, Austin, TX, 78745 • 512-477-2320 • SOSAlliance.org
August 26, 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 RR 417’s application for draft permit for
TPDES Permit No. WQ0015713001
Dear Chief Clerk:
Save Our Springs Alliance (SOS) submits these comments on the draft permit issued to RR
417, LLC (RR 417 or Applicant) for Texas Pollution Discharge Elimination System Permit
(TPDES) No. WQ0015713001. If issued, this permit would authorize the construction of a
new wastewater treatment facility and discharge of up to 49,000 gallons of treated
wastewater per day into Commissioners Creek, then Hondo Creek (in Segment No. 2114 of
the Nueces River Basin), then the Frio River, then to the Nueces River.
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. 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 RR 417’s application.
SOS also has members who recreate in Hondo Creek downstream of its confluence with
Commissioners Creek, and who enjoy recreating and observing wildlife in the Hill Country
State Natural Area, adjacent to the WWTP property.
SOS strongly objects to direct discharge of sewage effluent into Commissioners Creek and
Hondo Creek due to the high potential of negative impacts to this crystal clear water. TCEQ
should deny this permit, and applicant should pursue a Texas Land Application Permit
(TLAP) and/or alternative means to dispose of all of its wastewater.
Specifically, SOS objects to this draft permit for the reasons below.