To the good people of New Braunfels,

 I implore the citizens of New Braunfels to petition your city council to upgrade the water quality standard of the effluent of your sewage plants without waiting for the TNRCC to wade through the permit process.  There are three good reasons why you should proceed now:

Preserving The River Is The Right Thing To Do

 When you dump chemicals into the Guadalupe River you are using the river as an extension of your sewer system.  The concept of using American Rivers to dispose of sewage and industrial waste has been soundly rejected by the American people in the past few decades.  There are nationwide efforts to clean up our rivers.  At the same time, New Braunfels is bucking this trend by polluting the Guadalupe River and its lakes below your city.

 At the April 9, 2002, TNRCC hearing on the NBU water quality permit, the strongest testimony I have ever heard was presented that leaves no doubt that NBU is the culprit messing up the lakes.  While the NBU and TNRCC representatives squirmed in their seats and claimed they just were not sure that the NBU facility was at fault, over a dozen studies performed from 1981 to present were cited that pointed to NBU as the polluting culprit. All agree that your sewage effluent meets a minimum TNRCC effluent standard but consider that that standard also applies to the Houston Ship Channel. 

 In an attempt to put this problem in perspective, I asked the NBU representatives if they would have any objection if 4 million gallons of sewage effluent meeting the NBU water quality standard were dumped into Landa Lake each day.  The question was diverted to the TNRCC as though it were a technical question.  The real intent of course was to ask a citizen of New Braunfels if they would treat your pristine Comal River in the same manner you are treating the Guadalupe and its lakes downstream of your city.

 I firmly believe that once the citizens of New Braunfels have all the facts they will want to do the right thing by their neighbors.

Preserving The River Is In Best Interest Of New Braunfels’ Economic Future

 At the TNRCC hearing a NBU representative stated that the rated capacity of the sewage plants was good for another 4 years at the projected population growth.   Having seen the results of an overloaded sewage plant in Lubbock, TX in 1960,.  When a plant is overloaded it simply acts as a big filter.   The water coming out is clear but deadly.  

 I can assure you that the only way to prevent NBU from adding pathogens to the Guadalupe River, along with the phosphorus you are now dumping, will be to stop adding connections to the sewage plants when they are at full capacity. That means zero growth – which personally I find appealing but I doubt your business community feels the same.  It takes time to design, build and finance such a project and you should start now.

The reason I mention this is that I gave testimony in a hearing on a sewage plant permit in June of 2001 and the TNRCC has not responded.  That was a second hearing, six months after the first hearing.  At the April 9 hearing on the NBU permit, the moderator indicated there would be a second hearing.  If a contested case hearing (a court trial on the issue) is granted the plaintiffs, it becomes a long drawn out process.  Any application for a new plant or plant expansion would meet the same opposition from downstream residents, and friends of the Guadalupe River like myself, unless they designed to have a proper water quality standard.  It may easily take four years to resolve this issue.  Win or lose on the permit, your city could lose economically. 

If NBU were to agree to reduce the phosphorus in the effluent as the cities of Kerrville and San Marcos have done, then the permit problems go away.  This is not blackmail it is just the way the permit process works and I am pointing out the possible problems it can cause your city in this case.  Cleaning up your effluent will be quite painless and will have far reaching beneficial effects.  If you do not, those of us that believe in clean rivers are going to continue to protest.

Another point to consider is that New Braunfels is about to become a city downstream of considerable sewage effluent flow.   There are several sewage plants around Canyon Lake dumping effluent into the lake now using the same water quality standard as NBU.  

 GBRA is in the sewage plant business and wants to expand it big time.  At a GBRA “Canyon Reservoir Water Quality and Regionalization Study Stakeholder Committee Meeting” (read generate propaganda to support the GBRA sewage plant business) one suggestion to avoid polluting the lake with effluent was to dump it downstream of the lake.  In summer of 2000 the flow out of Canyon Lake was 50 cfs.  At that flow rate, between 5% and 10% of the water could eventually be sewage effluent if that proposal were implemented.  Also in summer of 2000, thanks to an additional 150 cfs from Comal Springs, only 3% of flow into Lake Dunlap was NBU sewage effluent – and that lake is a disaster area. 

I encourage New Braunfels to join Kerrville and San Marcos in preserving the pristine rivers God has given the hill country  - for the sake of your neighbors downstream.  Short of that, do it to make it easy for us to propose a similar clean water standard for the TNRCC to apply to GBRA sewage plants and all the small substandard plants planned for developments along the upper Guadalupe,  like Rebecca Lake and River Crossing. 

If you feel that a heavy concentration of phosphorus in the river flowing through New Braunfels is ok, then forget it.   However, if you can imagine the Guadalupe between Canyon Lake and New Braunfels loaded with algae and smelling like Lake Dunlap in summer, and if you can imagine what that will do to water recreation, then I suggest that you join the cities of Kerrville and San Marcos in preserving our rivers.

Preserving The River Is Economically Feasible for New Braunfels

There was testimony at the April 9, TNRCC hearing that NBU had released to the press cost estimates on retrofitting the existing NBU sewage plants for phosphorus reduction that stated that construction would cost between $5 million and $10 million and operations would cost $1 million a year. (These numbers are from memory.) There was very creditable counter testimony that such construction would be less than $3 million and the total cost would result in about a $1 increase in the monthly bill for each connection. 

Further, NBU admitted that their estimates were very preliminary and that they had not considered the operating and construction experience of Kerrville and San Marcos.  While Kerrville constructed a new plant, San Marcos retrofitted an existing plant.  Operational costs would be similar in both cases.

Demand of the city council that NBU produce a sound economic study of plant construction and operation before allowing any more public rhetoric on the cost of reducing phosphorus in the effluent your city is dumping into the Guadalupe River.

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