l Page 2 February 20, 2005
J. F. Trungale
Engineering & Science
Joe Trungale
2006 Ann Arbor Ave.
Austin, TX 78704
February 20, 2005
Ed Lowe
Texas River Protection Association
Dear Mr. Lowe:
In response to your email of January 4th regarding the need for an assessment of river flows on the Brazos River between Lake Granbury and Lake Whitney, I have made inquiries to try to understand flow needs for the river and the processes by which these needs could be meet.
It does not appear that evaluations to determine the instream flow needs have been undertaken in this stretch of river. I contacted Kevin Mayes (TPWD River Studies Team Leader), John Tips (TPWD Inland Fisheries District Biologist in Waco), Mark Fisher (TCEQ Water Quality Assessment Section Manager) and Tim Bonner (Texas State University Assistant Professor of Biology). There was concern expressed that the native fish community has been seriously impacted and may not be recoverable due to in part to the fact that the dams trap the sediments needed to provide the types of habitats necessary for the native communities. Rather than being concerned with providing more flow, the concern has focused on limiting the spread of Golden Algae from upstream to down, although since Granbury is a constant storage reservoir there may not be many operational options available. I still have to search TCEQ database to determine if there they have data that may be useful.
Although it appears that little work has been performed thus far, this may be a particularly opportune time to influence future studies and management of the Brazos River. As I mentioned in my response to your original email, there are currently instream flow activities being conducted on the Brazos River and there is a permit application at TCEQ related to the systems operations of the reservoirs on the Brazos. While the stretch between Granbury and Whitney is not part of the instream flow studies being undertaken by the state agencies, the gage on the Brazos River at Glen Rose, which is in this stretch, is one of the three monitoring points used in the systems operation permit application. Furthermore there is a longer term plan underway to develop a basin wide water management plan for the entire Brazos River basin.
It is my understanding that notice of the systems operation permit may be come within the next few months. At that time interested parties will have a limited time period to raise their concerns before the permit can be granted; I believe it is 30 days. It is also my understanding that flow recommendations in the permit application are based on a statistical analysis of historical gage flows and that these flow requirements will only apply to “new” water made available by the change in operations. I have contacted TCEQ water rights permitting staff to request a copy of this permit application and will review it when I receive it.
I spoke briefly will David Wheelock with the Brazos River Authority about the longer term water management plan. Although the BRA has only just begun thinking about the basin wide water management plan, the anticipation is that once the instream flow studies are completed, they will use what they learn from the studies to develop the water management plans.
Based on what I have learned thus far I believe there are three areas in which we should focus our efforts.
1. Continue to collect available data to better understand the flow needs. The Clean Rivers program and the TCEQ may have useful information that may support more informed determinations of instream flow needs.
2. Review and assess the adequacy of the flow recommendations in the systems operation permit application. If we determine that the instream flow targets contained therein could be improved, we should consider working through the permit process, perhaps with the advice of a water rights attorney and/or in consultation with TPWD.
3. Participate in the stakeholder process for the instream flow studies and eventual water management plan development. After we have a better idea what is lacking from the status quo recommendations, we should look to tailor studies and develop partnerships to address shortcomings.
Thus far I have spent approximately 6 hours researching these issues. Over the next month I would like spend another 8-16 hours collecting any other available data and reviewing the permit application. My billing rate is $95 per hour. I think it would also make sense to meet yourself and Dr. Slattery to discuss my findings and develop a more detailed strategy.
Sincerely,
Joseph F. Trungale, Jr. P.E.