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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 sent to 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 Carlos Rubinstein.

    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.

  • The State Capitol E-Report is a monthly electronic update from the Lone Star Chapter of the Sierra Club reporting on Texas environmental policy issues of statewide interest. Contact us at: ...Header photo copyright Susan Heller
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