Posted tagged ‘edwards-aquifer’

Moving off top dead center …

December 6, 2023

Awhile back I attended a confab put on by the Save Barton Creek Association (SBCA) at which was discussed a couple of developments south of Austin, in the vicinity of the City of Hays and the City of Buda, labeled “Hays Commons” and “Persimmon”. The presenters, representing SBCA along with the Save Our Springs (SOS) Alliance and the Greater Edwards Aquifer Alliance (GEAA), asserted that the scale and nature of these developments were “incompatible” with the area and represented a threat to water quality, as they were on or adjacent to the environmentally sensitive Edwards Aquifer Recharge Zone. All of this was presented in rather general terms, as the presenters did not have any actual development plans to show, just generalities about the scale and nature of the proposed projects. And the only actual “prescription” the presenters seemed to have was “just don’t build there”.

But of course, this being a capitalist society, the folks who own that land have investments, and are no doubt responsible to investors who expect a return on their investment. So in an attempt to further the conversation and maybe get into how we might blunt or obviate the problems that the presenters asserted would be imparted by the developments they feared, I asked the obvious question, what would you have these folks do with this land instead? This seemed to have stumped them, but one of the presenters eventually said, “more of the same as what’s there, 1-acre lots on septic.” Apparently unaware of the impacts of that development concept on land fragmentation, and how unfriendly to water quality the types of “septic” systems the county will approve would be. See, for example, Averting a Crisis.

Leading me to understand, we need to have a conversation about what sort of development folks think “should” be the manner in which much of the Texas Hill Country develops. Because in the current market, develop much of it will. So I set my mind to looking at the land upon which the Hays Commons project was being planned.

Some years ago I had met with the owner of that property, Bill Walters, to talk about the manner in which he might install water and “waste” water service to develop that property. This was years before any thought of extending City of Austin water and wastewater utility lines might have been entertained that far out from the limits of their system at that time, and even back then the limited supply capacity from the aquifer was understood, so our conversation centered on what folks might term today “One Water” practices, that term having come into vogue in the interim. We talked about using building-scale rainwater harvesting (RWH) for water supply, and about distributed (decentralized concept) wastewater systems that would focus on producing a reclaimed water supply to serve non-potable demands, to reduce the draw on the “original” water supply source. Also a heavy dose of low-impact development (LID) stormwater management techniques, to greatly blunt the impacts of development on runoff water volume and quality.

I could see how these concepts might allow Walters to install water and wastewater services on Hays Commons in a manner that would save him time and money while we all saved water. You see, the working plan of Walters’ development partner Milestone is to get the City of Austin to extend water and sewer lines to the project. That would, of course, require a very significant investment up front, to install the waterlines, pump stations, and storage tanks, and to install the wastewater mains and lift stations. Note that in addition to those line extensions, the developer would still also have to install water distribution lines and sewer lines within the development. Which would all take quite a bit of time, during all of which the actual development – the thing that would produce revenue for the developer – would have to cool its heels. And because of those high up front costs and time delays, the developer would be highly motivated to go with a more intense development scheme. That too would entail costs and further time delays to the developer to deal with opposition to denser development from the likes of SBCA, SOS and GEAA, as we’ve already seen.

Enter a better plan, a “total One Water” scheme, to eliminate most of the up front costs and the delays that spending that money would entail, and to also save a whole lot of water. AND it would also greatly blunt water quality degradation. Here is that scheme, as I set it before Walters:

First, thank you for taking some of your time to talk with me about the project next to the City of Hays, about the prospects for considering a water infrastructure plan that would have rather reduced up-front costs and regulatory approvals timeline, and would be more sustainable. We need to be pursuing sustainable water strategies, of course, as that’s really a matter of long-term sustainability, including having the water supplies to continue to develop in this region. A current series of articles in the New York Times is highlighting how America is draining away a “legacy” groundwater supply, overdrawing aquifers all over the country. Which of course is true around here. Indeed, one wonders, are we really acting in a manner such that we’re planning for only One More Generation, and after that, we really don’t have a plan? So maybe this development should be “saved” from becoming just one more exponent of that “one more generation” attitude?

For water supply, you noted that you’ve drilled 3 wells on this property, each of which was found to yield enough flow to support at least some of the desired development. Given the drought-induced issues with declining aquifers around here, one must wonder just how sustainable those yields may be. So maybe consider greatly “extending” that supply with a “conjunctive management” scheme, entailing:

  • Create a PWSS [public water supply system] using one or more of the wells as its water supply source. Determine which buildings would have a level of service that would rise to the level needing the water supply to be a PWSS, and install a limited distribution system to those buildings only. That, along with the permitting of the PWSS, and of course one or more ground storage tanks, would be all of the water supply facilities that would need to be “papered”, financed and installed prior to being able to start selling those lots to builders, and to start building on them.
  • The rest of the development – be they commercial or residential properties – would employ building-scale RWH as the water supply strategy. This would entail no up-front costs, as the whole water supply system would be built as the building is built. And with building-scale RWH at a level of service that does not rise to being classified as a PWSS, there would be very little regulatory burden.
  • Of course, the building-scale RWH systems should be designed and installed so as to be as sustainable “as practical”. This would dictate that building roofprints may need to be larger than would “normally” be the case for the sorts of buildings being considered. And that of course would have impacts on building styles, so the developer, and builders, would have to be willing to consider all that.
  • As for how to accommodate the “large” roofprints, please consider what I call the “veranda strategy” for adding relatively less expensive roofprint, by adding “verandas” around the building. By this means, expanded roofprints that would render RWH systems sustainable through worse drought periods can be provided relatively cost efficiently. So we’d want to look at the sorts of spaces the developer wants to be able to market, and consider if buildings housing those spaces could be practically built, and marketed, to provide the needed roofprint.
  • Of course, there would be a cost for the cisterns required for each building-scale RWH system, but perhaps this cost could be blunted – if not “relieved” altogether? – by lower lot prices availed by there being very little up-front costs to create an overall water supply system.
  • The PWSS drawing from the well would also be the source of backup water supply for the building-scale RWH systems, if drought became too severe and the building-scale RWH systems’ cisterns became depleted. This would put control of backup supply availability within the development, so that all owners of RWH-served properties would be assured of having a backup supply whenever needed. The backup supply would be delivered from a ground storage tank via tanker truck, so that a backup water distribution system would not have to be installed.
  • Because a very large fraction of the total water supply needed in the development would be provided by the building-scale RWH systems, so “relieving” the aquifer of that routine demand, the aquifer level could be somewhat “preserved”, so that the water would indeed be there if needed as supplemental supply during prolonged drought periods.
  • Note that buildings to be served by building-scale RWH may be started, and marketed, without having to wait for the several month (minimum) permitting process for the PWSS, and for getting those facilities designed, bid and installed, so likely imparting a “time value of money” benefit.

I trust you can see the “charm” of such a scheme, in particular from the developer’s standpoint due to the low up-front cost of water supply infrastructure, and the minimization of regulatory lead time in order to begin selling lots and building on them. Again, this could be so without regard to the overall intensity of development proposed on this property … within limits, of course; there’d have to be room for the larger roofprints and such, but the overall development intensity would have to become rather “extreme” for that to functionally come into play, seems to me.

For the “waste” water system, the idea would be to creatively plat lots for “condo” development, with the total amount of development on any given lot imparting a design flow rate <5,000 gallons/day (gpd), so that the “waste” water systems could all be “septic” systems, or On-Site Sewage Facilities (OSSFs) in rules-speak, permitted at Hays County – nominally a 30-day permitting time – rather than TCEQ-permitted “municipal” systems, entailing a year or more to permit and a whole lot more paperwork, thus more cost for technical and legal services. This scheme would entail:

  • Determining the building types desired to be developed and how they may be arrayed on the property. Then gathering them into groups that would create a total design flow rate <5,000 gpd, and platting lots surrounding each such group of buildings. All of the buildings would be under “condo” ownership, with the ground being owned in common. These are the conditions required in order to use OSSFs for the “waste” water system, since TCEQ kicked “cluster systems” out of Chapter 285, the on-site wastewater rules, in 2003, and has never seen fit to formulate a “middle way”, short of the far more onerous “municipal” permitting process, in the 20 years since.
  • Presently, Hays County rules include a requirement that each lot covers an area large enough so that the total design flow rate would not exceed the equivalent of 300 gpd/acre. So for a 5,000 gpd system, the minimum lot size would have to be 5000/300 = 16.67 acres. 5,000 gpd would cover 27 2-bedroom houses or 20 3-bedroom houses, so even with this restriction, a net density of over one house per acre would be attained.
  • In working on another project that was proposing to similarly use OSSFs for the “waste” water service, it was floated to Hays County that the 300 gpd/acre requirement might be applied over the whole property, rather than imposed lot by lot. This would allow using non-lotted property – e.g., the floodplain on the property in question – as a part of the required area, and so allow denser development on the lots. Hays County had responded favorably to that proposal. (Unfortunately that project “died” due to the Dripping Springs development moratorium, so that concept was never tested and confirmed.)
  • Presuming that the 300 gpd/acre rule did not limit the total number of units that could be installed on this property “too severely”, or if that rule could be “excused”, then it’s pretty clear that this “waste” water service plan would entail no up-front costs to the overall project developer, other than what Hays County would require during the platting process to show OSSFs could provide the required level of service. This can very readily be done by posing a standard OSSF design using the High Performance Biofiltration Concept (recirculating packed-bed filter) treatment unit, which would disperse the high quality effluent this unit would consistently and reliably produce in subsurface drip irrigation fields. This is the most environmentally benign sort of system that could be practically employed in such a distributed management system.
  • Each lot owner – which may be the overall project developer, or the developer(s) who would build on each lot – would then plan, design and install the OSSF to serve the buildings on that lot. This process would entail fairly minimal lead time, after the lots had been platted and made available for building upon.
  • The drip fields would ideally be arrayed to irrigate the highest value landscaping on each lot, likely to be grounds beautification around each building, or high value common areas, like a park or “common”. Note it is not at all uncommon to import soil to create “improved” soils for landscaping around houses and other buildings in the Hill Country, so we’d be placing the drip fields in the best soils on the property. In any case, the soil depth would have to be shown to meet the rules over the whole field area, something that’s not very well “guaranteed” in land application systems under the municipal permitting process.
  • By these means, most (all?) of the grounds irrigation would be taken off the potable supply, so rather drastically conserving the overall level of water use on this property.
  • There would of course be a management system created. Formally, each OSSF would have to be covered by a maintenance contract with a TCEQ-qualified/licensed maintenance company. In practice it would be most rational to have one “master contract” that would maintain all the OSSFs on the whole development, making this essentially the “wastewater utility” covering this development. By assuring that this management system was organized and run to properly oversee the OSSFs, long-term good performance could be practically assured.
  • It may be that some buildings – like the commercial buildings that it is understood would be part of the desired development plan – could implement a flush-water recycling scheme, further saving water supply. In such buildings, only a small “residual” wastewater flow would be created by water used in lavatories, slop sinks, break room sinks, etc., and that flow could be readily dispersed over the landscaping around such buildings. Again optimally focused on maintaining the highest value landscaping, the grounds beautification. That sort of scheme was discussed in Appropriate Technology.
  • Finally, by not collecting all the “waste” water in a conventional centralized scheme, we’d avoid the environmental liabilities inherent in that configuration, due to line leaks, manhole overflows, lift station bypasses, and from the disruption inherent in installing conventional sewer lines. So this distributed scheme is inherently more environmentally benign simply by how it is arrayed.

I trust you can also appreciate the “charm” of this scheme for the project developer, as it minimizes up-front costs for the “waste” water infrastructure and time delays for dealing with regulatory processes.

Part and parcel of the overall development scheme would be a very robust LID/green infrastructure stormwater management scheme. This would be designed to retain at least as much water on the land as infiltrates, rather than runs off, on the “native” site, so as not to “desertify” the land by draining “away” the increased runoff imparted by covering the land with impervious surfaces and otherwise modifying the land surface. By this means, water quality impacts of stormwater runoff would also be practically minimized. That scheme could be rather readily designed into each lot as it is developed, so here also entailing minimal lead time to design and install. That strategy would minimize any need for end-of-pipe ponds and such, which may also pose an up-front cost and time delay that could be avoided.

By going with this sort of sustainable water infrastructure scheme, society would be saving a lot of water – that is my main interest, indeed getting society to create more sustainable water systems, to start planning beyond “one more generation” – while saving the developer time and money.

Unfortunately, when presented with this “total One Water” scheme, Walters and Milestone proved to be strangely uninterested in saving time and money, and as far as I know are still pursuing utility extensions from the City of Austin. But you can see the potential here for a development scheme that would indeed save time and money for the developer, save water for society, and would significantly blunt water quality degradation. It also avoids sprawl-inducing utility extensions, the cost of which would mitigate for more, and more intense, development, exactly the outcome we’d like to avoid on this land. This sort of win-win-win might provide a template for how the environmentally sensitive Hill Country is to be developed, again noting that in the current market in this region, a whole lot of it will be developed.

So I would urge SBCA, SOS, GEAA and their allies to consider all this, to move off top dead center, and urge developers to be a bit more creative and innovative than going with “1-acre lots on septic.”

Or so is my view on this matter. What is your view?