An Overview of the Region H Initially Prepared Water Plan (Released for Public Review and Comment in March 2020 / Comment Deadline: June 28, 2020) 

The Region H Water Planning Group, whose region covers all or part of 15 counties in East and Southeast Texas (including Harris and neighboring counties), has released its 2021 “Initially Prepared Plan” (Draft Plan), which covers a 50-year planning period (2020-2070). The Plan projects population and water demands, assesses existing water supplies available to meet future demands, identifies water supply needs (the difference between water supplies available and estimated water demands), and recommends water management strategies to address any projected needs. The Region H Water Plan is updated every five years. The Sierra Club has been actively monitoring Region H water planning for the last 20 years and offers the following perspective on a few key aspects of the latest revision of the Plan. The public is encouraged to review and comment on the Plan.

Positive Features of the 2021 Region H Water Plan That Merit Support:

(1) The Region H Plan identifies water loss in municipal water distribution systems as a significant problem (“real losses represent 15% of the total water input to the region”). A dramatic example of such water loss was the major water main break in Houston in February of this year. Thus, Region H recommends Water Loss Reduction as a water management strategy for all municipal WUGs with real losses of greater than 10% and calls upon those municipal water suppliers to reduce their real loss by one percent annually over the 2020-2070 planning period until they are at or below 10% real loss.

(2) The Region H Plan recommends Advanced Conservation, which includes a number of water use reduction measures, for municipal WUGs. Perhaps most important in this regard is that Region H recognizes that outdoor water use “is a major driver of overall municipal [water] demand” and thus recommends mandatory outdoor watering restrictions (no more than twice per week) for all municipal WUGs (with the exception of The Woodlands, which already has those restrictions in place). 

(3) The Region H Plan also identifies Irrigation Conservation as a major potential for saving water in the agricultural sector in the region (rice is the primary irrigated crop in Region H, produced to some extent in eight counties). If fully implemented, the recommended conservation measures could reduce rice irrigation water use to sufficiently cover all anticipated water needs from rice production over the course of the 50-year planning period. However, for a variety of reasons, the full potential is not likely to be reached and thus irrigated agriculture is one water use sector which the Region H plan identifies as having some “unmet needs” in certain areas over the 2020-2070 planning period.

(4) The Region H Plan propose no new on-channel surface water reservoirs to meet additional water supply needs. The only reservoir projects included in the Region H Plan are the long anticipated (but never quite pursued) off-channel Allens Creek Reservoir in southern Austin County and the expansion of an off-channel reservoir owned by Dow Chemical in Brazoria County. The latter project certainly warrants scrutiny in the permitting process, but some other water planning regions in Texas are calling for major on-channel water supply reservoirs with enormous negative environmental impacts. 

Concerns about the 2021 Region H Water Plan that Warrant Comment:

(1) The new Region H Water Plan recommends water management strategies that on a macro level would provide water supplies far in excess of the identified water needs of the region over the 50-year planning horizon. For example, the Plan estimates that the region will need an additional 405,433 acre-feet of water per year by the decade that begins 2030, but the Plan recommends strategies that would provide 983,283 acre-feet of additional water supply each year (granted that approximately 75,000 acre-feet of that amount would be made available as a result of advanced conservation and water loss reduction and a potential additional 93,000 acre-feet would be through irrigation conservation). The Plan projects that the region will need an additional 883,136 acre-feet of water per year by the decade beginning 2070, but it recommends strategies that would provide for 1,947,784 acre-feet of additional water supply each year (in other words, more than double the amount needed, although with roughly 278,000 acre-feet of that coming from the various conservation strategies).

To be fair, most of the water user groups in the region are not projected to have more supplies than needed by 2070, not all of the additional water supply projected will be proximate to the places needing the water or available for the types of uses in need of water, there are concerns by the Region H Planning Group that the manufacturing water use demands the Group was required to use are too low, and some proposed projects may never be built because they will not meet permitting requirements. Nevertheless, the scale of the difference between estimated needs and projected water volumes from proposed strategies is so large that ratepayers and taxpayers should ask whether all of this water is really needed in the region over the next 50 years. Moreover, where is the incentive to conserve water if the water supplies are so far in excess of need? 

(2) The Region H Water Plan continues to reject drought contingency measures as a water management strategy to reduce non-essential water uses during severe droughts until wetter periods return. Each regional water plan is predicated on meeting water needs during a period as severe as the “drought of record” (in other words, the worst drought experienced during recorded history). For Region H, the “drought of record” was the multi-year drought of the 1950s. State law requires retail water utilities above a certain size or meeting other criteria to develop contingency plans for reducing water use during droughts, and there are now requirements that such plans be implemented in counties where the Governor has declared a disaster due to drought. 

Obviously, drought contingency plans should be implemented during a drought as severe as the “drought of record,” thus reducing the volume of water needed during that period. That reduction in volume offsets the need for additional supply equivalent to that volume. Therefore, implementation of a drought contingency plan does on a temporary basis what adoption of conservation measures does on an ongoing basis, and conservation is a key water management strategy in the Region H Plan.  However, while giving lip service in Chapter 7 to the importance of drought contingency plans, the Region H Plan (unlike some other regional water plans) does not include implementation of those plans as a water management strategy.

(3) While the Region H Plan does not recommend any new on-channel surface water reservoirs, the Plan does include some other types of large water development projects as water management strategies that could have negative environmental consequences. One example is the proposed “East Texas Transfer,” which would move 250,000 acre-feet of water per year from the Toledo Bend Reservoir in the Sabine River Basin via canal and pipeline to diversion points in the Trinity and Brazos River Basins. While there are benefits to using water from an existing reservoir rather than constructing a new one, there are potential negative impacts on areas where the conveyance projects are built and possible impacts on environmental flows as a result of such a project. 

The above points address some of the broader aspects of the Region H Plan. Members of the public are encouraged to review the specific estimated needs and proposed management strategies for their community.