October 28, 2010:
Proposed Environmental Flow Standards for Galveston
Bay and Associated River Basins Need Strengthening
The Texas Commission on Environmental Quality (TCEQ) staff has drafted and released a set of proposed environmental flow standards for Galveston Bay and the Trinity and San Jacinto Rivers that flow into the Bay. Unfortunately those standards, developed under the environmental flows process set up by the passage of SB 3 in 2007, are inadequate to maintain a sound ecological environment in the rivers and in the bay. Environmental and recreational groups that have been involved in this process – for example,
Galveston Bay Foundation, National Wildlife Federation, and the Lone Star Chapter of the Sierra Club – are pushing for truly protective flow standards. The groups are urging the TCEQ Commissioners to provide Texans the opportunity during the public review and comment period to weigh in on an alternative set of environmental flow standards developed by those groups that would provide protection for Galveston Bay and its associated river basins.
Article 1 of SB 3 created a process to determine how much water is needed to sustain a sound ecological environment in the state’s coastal bays and estuaries and associated river basins. The law established a process for setting up expert science teams and stakeholder committees for each region of the state who would develop and propose instream flow standards and freshwater inflow standards for the respective waters in their areas. That process has now been completed for the Trinity and San Jacinto River Basins and Galveston Bay. The ball is now in the court of the TCEQ, which is charged by the statute with the ultimate authority and directive to set these “environmental flow standards.” But this is a ball game in which all members of the public may play, and they need to do so if they want to protect the water resources in this part of the state.
In the case of the Trinity/San Jacinto Basins and
Galveston Bay neither the expert science team nor
the stakeholder committee was able to reach a consensus
on the recommendations for environmental flow standards.
The majority of the expert science team called for
a full range of flow protections, covering a variety
of flow conditions, at multiple locations up and
down the long river basins. A competing recommendation,
primarily from the members of the science team most
closely aligned with entities that sell water, called
for lower levels of flows in a limited number of
locations in the basins.
Unfortunately the TCEQ staff has leaned heavily
on this inadequate set of flow recommendations in
its drafting of proposed environmental flow standards
for this region. The staff’s draft proposes extremely
low flow levels for the Trinity and San Jacinto
Rivers and sets out a vague and hard-to-implement
guideline for inflows to Galveston Bay. If
these inadequate recommendations are adopted as
standards, the Trinity and San Jacinto Rivers would
be allowed to slow to a trickle in dry times, harming
water quality as well as threatening fish and wildlife
habitat in an already compromised system. Galveston
Bay would be very vulnerable to increased salinity,
particularly during times of drought.
TCEQ needs to give the public a meaningful opportunity
to comment on flow protections by simultaneously
publishing for public review and comment an alternate
standard with higher flow levels and more variability
to more closely mirror natural flow patterns. Environmental
and recreational groups are asking the three TCEQ
Commissioners to put out for public review and comment
the “Recommended Environmental
Flow Standards and Strategies for the Trinity and
San Jacinto Rivers and Galveston Bay” that environmental, recreational,
and public interest representatives on the stakeholder
committee for the region developed and submitted
to TCEQ earlier this year.
The Sierra Club is urging concerned citizens to
communicate that message to the three TCEQ Commissioners
by sending a letter as an attachment to an email
firstname.lastname@example.org. In the body of
the email, senders should specify that the email
is intended for all three Commissioners: Chairman
Bryan Shaw, Commissioner Buddy Garcia, and Commissioner
The Commissioners will decide
on Wednesday, November 3 at that day’s Commission
meeting whether or not to publish the TCEQ staff’s
proposal for a 30-day public review and comment
period. It is at that
decision point where the alternate proposal could
also be included in the call for comments. Therefore,
people who want to take decisive action to push
for stronger environmental flow standards for the
Trinity and San Jacinto River Basins and Galveston
Bay need to do so immediately.
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