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The committee met to consider the following interim charges:
 
Evaluate the status of water markets in Texas and the potential benefits and challenges of expanded markets for water. Include an evaluation of greater interconnections between water systems through both engineered and natural infrastructure. Examine opportunities for incentives from areas receiving water supplies to areas providing those supplies that could benefit each area and the state as a whole.
 
Examine regional and state water planning processes.
 
Opening remarks by Chair Jim Keffer

  • The committee will be very active this interim
  • Were given the ability to make changes to the interim charges and schedule as needed
  • A subcommittee on private property rights in water has been established; will be chaired by Rep. DeWayne Burns and include Reps. King, Larson, Kacal and Frank
    • First hearing will be in Burleson
  • The committee will be looking at a lot of sensitive subjects this interim; right now Texas is being blessed with a reprieve from the drought and are enjoying full lakes and reservoirs in many parts of Texas, however, there are still drought issues out there and the problem could return quickly
  • This interim the committee needs to set a path and a foundation for these important subjects to be tackled next session

 
Carlos Rubenstein, RSAH2O

  • Opened a consulting firm after leaving the Water Development Boards
  • Water markets in Texas are not unlike other western states
    • There must be willing buyers and sellers
  • Timely and accurate information is critical for a water market to be successful
  • The biggest issue in a water market is knowing the value of water; another big issue is comparing the cost of water resources in the future to today’s value
    • Acquiring water in the future will be much more expensive
  • There are many factors that affect reliability in the water market and many factors that affect water quality
  • Environmental flows concerns have to be taken into account
  • Area of origin affect; moving water form where it is to where it isn’t impacts the area of origin including economic impacts
  • Detailed what various other states are doing to reach proper valuations and mitigating area of origin effects in written remarks
  • Rep. Eddie Lucio asked what other states are doing to mitigate area of origin effect
    • In other states you can only target unallocated water
    • No other states have junior water right provisions
    • Many other states require quantification of impacts and benefits
  • Lucio noted there are areas that aren’t growing; how can a balance be struck between depleting a resource a community may need for future growth and supplying a community that is growing at a faster rate
    • That is the question everyone wants to know the answer to
  • Keffer asked if in other states the state owns the groundwater
    • Yes
  • Rep. Tracy King asked what unallocated water is in other states for states that allow transfer of unallocated water
    • The same thing it is in Texas; water that has not been permitted
  • King asked if allocated water can be sold by the entity it is allocated to
    • Yes; in some instances they say the diversion point cannot be changed to prevent additional or different impacts than what are already expected
  • King asked if Texas has any rivers that aren’t over-allocated already
    • TCEQ can probably answer that question best and they make those determinations on a case by case basis; reliability that the water will actually be there is a variable as well
  • Texas leads the way in being able to see impacts and amend their water plans; the ability to respond to impacts is not enjoyed by every state
  • In order to meet the needs of the state in the future water will have to be moved from where it is to where it isn’t
  • The more that a water market is facilitated and an agreed upon valuation of water is made, individuals that have water can make better decisions to invest in infrastructure to move water
  • Rep. James Frank asked if a limitation on a water right will decrease the value of personal property
    • Yes; but on the other side, giving unlimited right can increase consumptive use
  • Some people have the idea that leaving water unused is a waste of a resource but there is a benefit in leaving enough water to keep ecological systems healthy
  • The Rio Grande water market is one of the most successful in the state
    • Water rights are allocated based on priority of use; this is one of the reasons why the market works so well
    • Users are allowed to store 140% of what they are permitted to use in a given year
    • Water cannot be imported into the system mostly because of the effect of the treaty with Mexico
    • There is very timely and accurate information available
    • Diversion require prior approval by the watermaster
    • The watermaster knows when there is water available for sale which facilitates the market
    • There is the ability to change water from a lower use such as agricultural to a higher use such as municipal; this does require a conversion however
    • Paper water rights can be sold upstream or downstream
    • The system does not allow a person to speculatively purchase and hold water
  • The priority of use and closed system qualities of the market are unique but that does not mean that aspects of the market cannot be replicated around the state
  • Keffer noted it is becoming more and more evident how important watermaster are becoming
  • Lucio noted there are some very responsible water districts but there are also some that want to hold onto their water and not work with customers; would like to begin a dialogue between irrigators and municipal suppliers about movement of water; the Rio Grande market may prevent situations from coming into play because of the way the water is taken from the river and delivered to permit holders
    • Treating the valley with a regional approach may alleviate some of these issues; regionalization and diversification of water sources helps the market
  • Keffer asked what the situation with the treaty with Mexico is
    • Haven’t looked in a while; the question is how is the water being calculated
    • Lucio noted the current deficit is around 263,000 acre-feet
  • Rep. Lyle Larson asked how other states deal with excess flows; Texas loses a lot of water that ends up in the ocean; there need to be a framework to allow people to capture this water
    • In some states that water is viewed as an additional water bank that can be accessed when it is needed
  • Larson noted this could be beneficial in parts of the state and would help to relieve the pressure on groundwater; getting lots of rain in one part of the state could trigger another downstream part of the state to start pulling out water to store with ASR

 
Dan Buhman, Tarrant Regional Water District
Jody Puckett, Dallas Water Utility

  • TRWD operates a system of four reservoirs that were built by the district and three additional reservoirs that the district operates
  • DWU Serve around 4.5 million people
  • Want to discuss the Integrated Pipeline Project
    • A type of grid or interconnect but on a more localized scale
  • The interconnections started with a planning project that showed the region needed more water and additional pipeline space
  • Determined over the lifetime of the project, sharing the pipeline will have saved over $1 billion
    • Also diminished impact to landowners and environmental aspects
  • Were awarded about $450 million in SWIFT funding; TRWD alone saved around $40 million by having access to the SWIFT
    • Entire project cost will be around $2 billion
  • The development of this project set the groundwork for future integrated projects
  • Keffer noted that both entities have good bond ratings and still were able to see significant savings through the SWIFT; glad to see it is working as intended
  • Larson asked if communities the pipeline runs through are asked if they would like to tap into the pipeline and partner with the metroplex
    • Many of those communities are served by TRWD or DWU but do not have the ability to treat the water; have not had any requests along those lines but would be open to it
    • Some of those entities do not have the need for water
  • Rep. Trent Ashby noted he appreciates the way the two entities have come together to work on this project and it is proof that the regional water system works

 
John Grant, General Manager, Colorado River Municipal Water District

  • Texas has had a successful water market structure for decades
  • Purpose established in enabling legislation is to provide water for municipal and industrial waters; if needed can treat and transport water as well
  • Since inception of the district it has continued to grow and bring in new service area and municipal populations
  • Now have the ability to gravity flow a substantial amount of water
  • Up to 11 municipal customer, 12 industrial customers and 300 rural areas
  • System has evolved into a sustainable water system and there are plans to continue growing
  • Water markets have been developed and expanded based on the needs of the area and what makes sense
  • Water markets are alive and well in Texas today and there are many successful examples that can be replicated
  • Frank asked if the district is a raw water supplier only
    • That is the way it was set up but not anymore
  • Larson asked how much of their total use of San Angelo, Odessa and Midland the district provides
    • 85% for San Angelo, 100% for Odessa and 75% for Midland
  • Larson asked what cost of water from lakes and cost of groundwater are
    • Contracts are structured and most pay only cost; the weighted system average cost is around $2.45

 
Mike Booth, Booth, Ahrens & Werkenthin, PC

  • Texas started actively talking about water markets in 1997 and that is when intrabasin transfers became a discussion point
  • Looking at western water markets, for the most part they are reservoirs; real wet water backed up with storage; many western states have similar situations; this must be considered when looking at taking on a western state water market model
  • In Texas, looking at sales of surface water or groundwater put into surface water, a market is developing on wastewater return flows; beginning to see sales of this on the Trinity; don’t see a lot of run of the river water market sales though there are some
  • Suspect that the functional equivalent of water rights being junior is still prevalent in other western states; don’t see other states that had area of origin protection when Texas began dealing with junior water rights
  • The basis of junior priory protection is that if there is an underallocation of water, junior protection won’t make a difference
    • A junior water right on run of the river may be a problem
  • Don’t want to have a situation where water is taken from one place to fix a problem in another place and causes a problem where the water is taken from
  • Having a reservoir where water is sold out of a basin will be reliable during a drought
  • Protections that Texas has such as a junior priority have been around since 1913
  • Don’t necessarily need to do anything to change the law; over the last few sessions notice provisions have been updated, a few exemptions have been added, etc.
  • The legislature needs to understand that when moving water around the quality of water needs to be taken into consideration because quality is not the same everywhere
  • Keffer noted the bar has to be high to ensure when water is moved problems aren’t caused
  • Frank asked how river basins were chosen as the delineating line of  “thou shall not move”
    • Texas has always used river basins as the basis for study
  • Frank asked if it should be kept that way
    • It would be hard to change because so much planning is based on that
  • Frank noted it is based on regions
    • Yes but the river basins are the underlying factor
  • Ashby noted it is easy to beat up on some areas that have available water but under current water law, there doesn’t seem to be a problem with moving water, primarily surface water, as long as one buyer and one seller are identified; it is disingenuous for anyone to say East Texas is hording water
  • Larson noted groundwater is a different issue
  • Larson asked if Grant does outreach to smaller communities to see if they need water
    • Have amended contracts with water users to allow other communities to access the water; pretty much everyone on surface water in the district is tied in to the system in some way
    • Water use in the district contracts has gone down 25% which can be attributed in part to conservation but also to the fact that many cities have gone to a tiered pricing system

 
James Totten, General Manager, Lost Pines Water Conservation District

  • District contains 1 million acres and just under 95,000 people who rely on groundwater for their daily needs
  • Four Star Real Estate Group was awarded water permits which resulted in multiple lawsuits; began mediation in June of last year; came up with a basic outline of  a settlement agreement but after that it took another six months before the technical details were hashed out; in December of 2015 the district voted on the settlement agreement which came with a monitoring agreement and a proposed set of new permits
    • Four Star has agreed to drill 6 new monitoring wells giving a total of 13 monitoring wells
    • Four Star is allowed to produce 12,000 acre-feet per year; when Four Star has produced 6,000 acre-feet for three calendar years, the district will evaluate the impacts that has had on the total groundwater and DFCs to evaluate whether they are on a course that will allow the DFCs to be satisfied; if it is determined the DFCs will be satisfied Four Star can increase their production to 20,000 acre-feet and the monitoring will continue; Four Star will be able to increase their production one more time if groundwater is not negatively affected
  • Keffer asked where Four Star is going with the water
    • They are providing it to Hayes, Travis and Bastrop Counties
  • The settlement has allowed the district to stay out of court and is a win situation; gives a measurable way to move forward
  • Keffer noted this is a step in the right direction
  • There is still another large permit outstanding but hopes are to move them toward a similar settlement proposal
  • Keffer noted the monitoring wells are the key factor

 
Laura Huffman, Nature Conservancy

  • Growing cities, agriculture, industry and the environment are the four big users of water
    • Want to protect all four of those users
  • SWIFT creates a wonderful opportunity to integrate conservation into water projects
  • Thinking about conservation as part of water supply projects is an important opportunity
  • Keffer asked if there are issues the legislature can look at going forward regarding conservation
    • The hard work is happening at the utilities; moving from a definition of conservation that is just about per capita water use and integrating water conservation into new projects is crucial
  • River and stream health will be the best marker for whether Texas has done a good job with water marketing in the future
  • In San Antonio for years the Edwards Aquifer was the sole source of drinking water; they began developing source protection plans; they have purchased land outright as well as purchasing conservation easements; has prevented San Antonio from having to spend a lot of money on treatment costs
  • The Nature Conservancy has established a water market in Australia in which they have purchased agricultural water rights to use them for environmental flows and to sell some back for agriculture
  • Water markets give Texas the opportunity to get new kinds of investors in the mix who are interested in achieving positive environmental outcomes while also achieving a positive return on their investment by selling some
  • Restoration funds can be used toward this purpose to augment environmental flows

 
Ken Kramer, Sierra Club

  • Aiming for a balance in state water policy; recognize there is no silver bullet for addressing all of the state’s water challenges
  • Conservation
    • Texas does not have universal adoption of water conservation practices as are seen in some of the major utilities
    • Need to have a true assessment of how much potential there is in conservation
    • Recommend the legislature direct TWDB to do a comprehensive assessment of the maximum potential of conservation in Texas and what steps need to be taken to achieve that; that will give a baseline of how much water is actually needed
  • Water supply augmentation
    • Grey water systems, water harvesting systems, alternative on-site water sources, air conditioning condensation reuse
    • Would like to give TCEQ a directive to update rules and regulations for on-site sources and to promote their use
  • May want to look at giving responsibility of the water trust to TPWD which is the agency responsible for protecting fish and wildlife
  • Opposed to the idea of implementing a massive state water grid; this is too extensive in terms of potential threats to the environment and private property owners; do not believe it would be cost effective in terms of energy costs
    • Already using 13% of the state’s energy usage on moving and treating water
    • Believe energy utilities are a part of the push behind the water grid idea; just looking at the lobbying interests from last session
    • In 1969 the voters rejected a state water grid proposal
  • There is funding not only for infrastructure projects but also for conservation through SWIFT; not seeing a lot of water utilities seeking funding for conservation; may need to think of ways to encourage and promote this as a use of SWIFT funds or other funds
  • Not opposed to the use of water markets; in many situations this model does make sense but they must be done carefully so that problems are solved and not created
  • Larson noted the water grid is not only about big cities but also about the small cities that are close to running out of water; a comprehensive strategy needs to be developed; if there is no proper planning, the private sector will move water into big cities without dealing with smaller communities on the way
    • Seeing the challenges being faced in water as something that need to be faced in a comprehensive way; water supply augmentation, for example, can help small cities with their water supply; interconnections with existing pipelines and new pipelines are another option for smaller cities
  • How many of those small cities have implemented drought contingency plans and conservation efforts
  • Larson noted there are water losses happening with antiquated conveyance methods; must have the architecture to move water and much of it needs to be updated
  • The 1969 vote was on proposed $3 billion on TWDB bond authorization to allow financing of infrastructure; it was defeated by only about 6,000 votes; was opposed by environmental groups and many fiscal conservatives who thought it would cost too much;  they predicted Texas cities were going to run out of water sometime in the 1980s if the project were not completed; still using around the same amount of water now as back then; this is a testament to how much conservation has helped since then
  • King noted there are a lot of conversations surrounding water capture; does Sierra Club have a prediction for how much water must be kept in bays and estuaries to prevent a problem
    • There is no one magic number; each bay and estuary system is different; In 2011, SB 3 required a study on the amount of water bays and estuaries need and the legislature has recently provided additional money on environmental flows studies

 
Clay Landry, Managing Director of WestWater Research

  • Firm currently manages largest water acquisition program in US
  • Maintain database that contains 15k transactions about water rights sales and leases
  • Water market as they define it – a transaction or trading through temp or permanent of existing water rights or other entitlements
  • Texas has an early stage market with two active markets – once moved outside of the two established markets then trading activity becomes ecstatic
  • $58m worth of water traded and 90% of activity is in the two established markets
  • Expenditures between leases and purchases were roughly equal in 2014 – response to drought
  • A non-predictable regulatory environment makes a water market difficult – regulatory framework, consistent allows trading to occur
  • Certain water users are turning to the market as an alternative to supply which is a change they have seen in the last 10 years
  • Investor discussion on water markets – realizes this sector can be a controversial discussion
  • Municipal sector is the dominant buyer on the water market, has seen shift of ag users also turning to market

 
Wes Strickland, Jackson Walker LLP attorney 

  • There can be confusion btw water market and water transfers and don’t necessarily mean intrabasin transfers
  • Most market activity is local in nature or markets within large projects
  • Use of water market to allocate water vs planning – they are different
    • Market allows for flexibility in planning
  • Water markets provide certain benefits such as coordination of shifting supply, achieve reallocation of water entitlements that fully protects private property rights,  etc
  • There are certain features that every water market must have in order to work well such as regulatory process be well known, etc
    • A large scale project – the construction cost will be significant and regulatory costs will be built in but there is still some uncertainty
    • Really transaction costs are important for shorter transactions – these items are really impacted by transaction cost
  • There are several different types of market transactions – the lease market is an important market and if doing a one year lease it relies on existing infrastructure
    • Buyers may purchase options, futures, etc
  • Rep. Larson – how does ag market work and lease back into So Cal communities?
    • Transfer in imperial valley was long term transfer over number of years to San Diego Water Authority and it was a fairly set program
    • In Central Valley of California seeing changes every year  – outbidding example was provided
    • Larson discussed controversial project in San Antonio – private property rights being exercised by selling or leasing water to municipal government
    • Agrees most have some protections on water rights and once market set up it can allow owner to use or dispose of the right as they choose
  • Rep. Keffer asked about water markets in Texas
    • Under the current system in Texas we have a water market
  • Rep. Ashby – already have two well established markets and nothing to prevent others from joining and it seems to be working, but confused, why should they step in – this is a classic example of a solution in search of a problem
  • Larson thinks this issue will come back to haunt them if they don’t address, the Edwards was set up in statute by the legislature, they capped it
  • Ashby says in respect to Larson they have areas they agree in, regions know best how to address and wants legislature to be mindful of the current water planning process
  • Larson argues he does not have water in his region and the other regions will fight them fiercely from accessing the water and they will be stuck in Region L – they don’t have enough water for future growth where Ashby has enough in his region
    • Larson believes Ashby and himself may differ in matter of approach because one region has water vs another region does not have water
    • Larson said there needs to be planning for long term future
  • Ashby pointed to a specific example that shows collaboration and he does not see the same impediments that Larson sees
  • Ashby and Larson continue discussions until Rep. Keffer steps in and states he appreciates their passion on the ideas

 
 
Steve Kosub, San Antonio Water System

  • SAWS supports the development of water markets and the movement of water in Texas
  • The state needs to recognize and eliminate unnecessary statutory impediments to market activity The state must exercise a strong hand to ensure common state interest are protected; an unrestricted market would not be a pretty thing
  • The state must have a guiding hand in protecting human interest, economic interest and environmental interest
  • Interests need to be balanced
  • The merits of distributing water around the state in an integrated network are substantial; similar to a power grid
  • Some argue that a grid would encourage wasteful water use but that is likely not true
  • A comprehensive strategy statewide will help to reduce wasteful situations
  • Sharing of a single source aquifer can be facilitated by transferable water rights and permits; this idea was put into statute in 1949 when groundwater districts were formed along the boundaries of aquifers
  • Hydrology based groundwater management and transferrable permits need to be revisited by the legislature

 
Gary Bradley, Self

  • Population growth in Texas is happening and will happen in between Dallas, Austin and San Antonio
  • The private sector will respond to the water need in Central Texas if the state does nothing
  • The future economic growth of Central Texas lies in the smaller cities; affordable housing is no longer available in the large cities of Central Texas
  • Small communities in Central Texas have few options aside from drilling aquifers; even if a community were successful in getting those permits to drill they will eventually hit a DFC
  • Left to their own devices, do they have the resources to put an intake structure and treatment facility in Lake Travis? Likely no
  • Proposing capping exportation of water from the Simsboro aquifer in the Post Oak Savannah at 150,000 acre-feet; would take the pressure of those boards to issue permits for exportation but allows them to continue to issue permits for local uses
    • Could also offer an economic impact analysis for those four counties
    • Need to include recharge enhancement in that legislation
  • TPWD estimates 368 million retrievable acre-feet of water in the Simsboro aquifer
  • This aquifer is an incredible resource and could be the answer for Central Texas for decades to come; it needs to be studied and it can only be studied if it is use; it can only be used if there is a bankable permit
  • Frank asked how the state restricting the water would help
    • It takes the pressure off of the districts so they do not have to accept new permits until the understand what happens when 150,000 acre-feet are produced
  • The best use of SWIFT money is when the private sector is willing to go forward and put in infrastructure and the competition comes from water sellers
  • Texas invests billions in highways for economic development purposes but there won’t be growth in small cities without water either

 
Valerie Covey, County Commissioner, Williamson County

  • A lot of people are moving into Williamson County
  • Williamson County has adopted many conservation strategies and is a proponent of the regional approach in transportation, mental health and many other areas
  • The regional aspect for water works but there are communities that don’t benefit who are well within the reach of the water that nearby communities have access to
  • It doesn’t make sense for each community to have the cost of an individual pipeline
  • Lack of water limits economic development for smaller cities and towns

 
Burt Cobb, County Judge, Hayes County

  • Entered into the contract with Four Star because the county was having a hard time buying water
  • Discussed the situation in Hayes County in which the county approved the contract but would not approve a contract extension

 
Paul Weatherby, Middle Pecos Conservation District

  • Fully support local groundwater management by conservation districts
  • There is a need to look at water markets vs water marketing – can be controversial
  • Agrees there is no need to fix what is not broke
  • Suggests clarification may be needed in Ch 36 “provide a need” language – stand-by use does not necessarily mean a need 
  • Argues most people don’t know about GCD and DFC – education needed on local groundwater conservation districts

 
Rita Ward, individual

  • Supports Texas involvement and not foreign involvement in water markets
  • Wants to take care of aquifers and believes they can be sucked dry

 
Colleen Wearing, Milam County land owner

  • In Post Oak Savanah conversation district – which she argues does not preserve and protect her resource, their policy is to permit everyone
  • Concerned she will not get her share of water 
  • Larson inquired about permits she has
    • Household permit – but for every acre she has, the district’s policy is she will be permitted for 2 acre feet of water but would need a larger well

 
Michelle Gingus, League of Independent Voters of Texas

  • Would appreciate if a rural interest individual would be appointed to some sort of stakeholder process
  • Rural areas are not water hoarders
  • Agrees with sharing resources but in a collaborative process
  • Also would like to see conservation methods enhanced/utilized/incentivized – middle ground between utilization of resource and growth/development
  • Look at groundwater and surface water development

 
Andy Hovorak, Burleson County resident former board member of Post Oak Savanah Conservation District

  • Gives background on the discussions (Post Oak and Lost Pines) and quickly reviews legislation
  • “Do not harm where source is from” – would like something in legislation that does harm people in upper areas of aquifers that will protect them – sustainability of the aquifers must be a priority
  • Rep. Paul Workman asked about supply in aquifer
    • Does not disagree with measurements given on supply abundance but there is a lack of understanding on how aquifers will react and interact with each other
  • Larson asked about any other transfers – there was another one, both transfers by Blue Water
    • Blue water does have acres leased  
  • Larson said he liked the area of origin discussion – can’t harm an area and make it whole
    • Does not have any interest in mitigation – just want protection

 
George Rice, hydrologist

  • Has been studying pumping from aquifers and using groundwater availability models (GAMs) to complete his study
  • Simsboro aquifer does contain huge amount of water but still need to be concerned with how much they pump from it
  • Pumping increase from aquifer may be 100x and will have effects on ground water and surface water
    • GAM predicts that in some portions that water levels and wells will drop by hundreds of feet – does not necessarily mean they will be de-watered some may have to make adjustment to wells
    • The more water levels are lowered, the flow released into the river will be decreased
  • Equates Simsboro similar to that of a gold rush – people think they can pump vast amounts of water out without harm but he thinks there are harms to over pumping
  • Larson – Texas does not recognize conjunctive use but there is a connectivity from groundwater to river flows; river flows will be impacted and depletion may be seen in rivers

 
James Murphy, Guadalupe-Blanco River Authority

  • Seawater desalination – starts at 25k acre feet and 10% of overall water supply
    • At minimum levels allows for trading
  • Confusion between having project listed in plan and desire to produce a plan to bring to legislature – because concern is to list projects, legislators see in plan projects that are not related
  • Tweaks needed to chapter 16 of the Water Code
  • Needs to be balance between regional, local and state
    • TWDB does not have regulatory functions

 
Judith McGarry, Farm and Ranch Freedom Alliance

  • Fundamental problem with pulling water from under a person’s property – money does not work
  • Need to take conservation methods up front and need to get serious about it now
  • Using a pure market system in agriculture use is dangerous – farms need to be able to raise foods for Texas communities
  • There are socially valuable markets that need to be protected

 
Greg Sengelmann, Gonzales County Water Conservation District

  • In 20 years Approx 87% of water will be going out of district and it will provide water to about 6 counties
  • Water is from Carrizo only but also have some water in Wilcox, mostly brackish so not many have approached them for it
  • They do have a mitigation program – have spent over $500k but it is an ongoing process and will probably cost up to $2-3million
  • Larson – looking at all cities, have they brought property out there
    • A few bought acres but others leased water rights from land owners
  • Workman – you have 87 acre feet permitted and how much is being drawn down? Is level dropping and how rapidly?
    • 1/3 of what is permitted – just Carrizo portion and the level is dropping
    • Dropping about what is expected
  • Not concerned about draw down at this point – have a long way to go and do not anticipate any problems
  • They monitor – 100 monitor wells and monitor levels three times a year will know well ahead of time if they get to DFC
  • Will be hard to cut people back so unless they see problem with draw down with impacting water quality or rivers – may end up lowering DFC in the future
  • They are pumping over the recharge so need to enhance the recharge
  • King refers to it basically as a mining operation – not really recharge in the aquifers
    • King says almost all don’t recharge