Brownsville Weir and Reservoir Comments
The Texas Center for Policy Studies submitted the following comments regarding permit number 21977: for the Brownsville Weir and Reservoir Project.
First, TCPS finds, after analyzing the water plan prepared by the Regional Water Planning Group (Region M), that based on the information presented in the plan the Brownsville weir is completely unnecessary to meet local water needs. The Region M plan indicates that it can meet its projected water needs over the next 50 years through other strategies, including wastewater re-use, groundwater supplies, advanced conservation, and purchase and transfer of water rights. We do not feel that a $54 million-dollar project that serves no real need is in the best interest of local residents or of the taxpayers footing the bill.
The Public Utilities Board seems to be basing its need for the weir on future, speculative, industrial growth at the Port of Brownsville. A letter dated September 11th, 2000, from John Bruciak, PUB General Manager, to Region M Chair Glenn Jarvis, confirms this in the following statements:
At the present time…the most serious proposal that is being considered by the PUB involves a large industrial complex with an associated steam-electric power plant and ancillary manufacturing facilities, (with) projected water demands on the order of 12,000 to 15,000 acre-feet per year. It does not appear that these potential additional demands for industrial water are accounted for in the RGRPG's…modest increases in the projected Manufacturing water demands for Cameron County. While these opportunities for new industrial development within the PUB's service area continue to remain somewhat speculative, the ultimate decisions as to whether or not this development actually occurs very likely will hinge on the availability of an adequate water supply.
In fact, potential additional demands for industrial water are accounted for in the Region M Draft Plan. The Plan acknowledges an increase in Brownsville's water demands for steam electric generation from 2,000 acre-feet per year currently to over 11,000 AF/yr by 2030. The Region M plan projects that these water needs can be met by using reclaimed wastewater.
Furthermore, we question whether, until recently, the true purpose of the weir has been made evident to the residents, or even to the community leaders of Brownsville. PUB should provide full disclosure to the public of exactly what water need the proposed weir is projected to supply so that citizens can make a more informed decision. Building a weir for the sole purpose of supplying scarce water in an arid region to extremely high water-using industries is (1) contrary to the primary purpose usually claimed for the weir (i.e. to meet the needs of area residents), and (2) completely contrary to sustainable development ideals. The amount of water PUB is discussing - 12,000 to 15,000 AF/yr - is an enormously high water budget for such a water poor area, only to serve one interest.
Second, because the proposed project would flood 130 acres of endangered species habitat, it should require nothing less than a full Environmental Impact Statement and Section 7 consultation with the U.S. Fish and Wildlife Service.
Third, the downstream effects of the dam have not been adequately addressed. The base of the weir is currently planned for at or below sea level. This could increase salinity in downstream waters, affecting downstream irrigators and the Sabal Palm Audubon Sanctuary, which relies on freshwater flows from the Rio Grande into its wetland each year to maintain nesting habitat for the Least grebe and Black-bellied whistling duck, as well as wintering grounds for other waterfowl species and a migratory stopover for neotropical birds. Saltwater intrusion in the sanctuary could destroy these values, ruining a unique Brownsville treasure that is home to semi-tropical species found nowhere else in the United States, and a highly-valued birding spot that provides millions in revenue to the local economy each year.
Fourth, the Brownsville PUB has a permit to capture 40,000 AF/yr of water, but only if this water is actually available for capture after no other users have claimed it and only when there is base flow of 25 cubic feet per second. Water users in the region are adjusting to diminishing supplies by increasing conservation and efficiency in diversion, and water managers by monitoring and increasing efficiency of water releases. This means that the amount of "excess" water that PUB is allotted to capture may not actually be available for capture in the near future. The PUB may not request releases from Falcon Dam to supply the 40,000 AF. Should supplies become limited, there may be pressure to "scalp" from base flows, jeopardizing the 25 cfs required for minimum maintenance of instream flows and seriously compromising the needs of downstream users, including the estuary and the Gulf of Mexico.
In conclusion, TCPS feels that the environmental and economic costs of the proposed weir project are substantially greater than the perceived benefits. We do not feel that this project serves the public interest. In any case, because of potential significant environmental impacts, consideration of this permit is a major federal action requiring a full Environmental Impact Statement under NEPA.
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