Serving Kerr County with a Conscience

​An Unsafe Septic System

The septic system under construction for Old River Road RV Resort bypasses safeguards for public health and safety. An onsite septic facility (OSSF) is being installed with tanks and drain-fields designated for servicing 25 people or less. OSSF’s are the usual residential systems.

The RV park’s septic system lies over the Guadalupe River’s recharge zone. Installing a septic system on the RV park site is not contraindicated. However, the Texas Commission on Environmental Quality (TCEQ) has specific rules and precautions for RV septic systems, they are more expensive than an OSSF. The Environmental Protection Agency refers to such systems as large capacity septic systems (LCSS). The TCEQ standards are based on the 5000-gallon rule—any project producing 5000 gallons of sewage per day requires a large capacity septic system application and oversight by the TCEQ. The RV developers evade this rule and TCEQ oversight by dividing the 240 unit development into three sections, each needing less disposal capacity than 5000 gallons.

RV parks present specific problems for septic systems. In addition to the higher volume produced by the convergence of people within a small area, the waste is more concentrated because less water is used in RVs. Toilet contents are made more caustic by strong chemicals and deodorants used to control tank odors. These conditions accelerate corrosion and septic system failures. The LCSS rules are designed to extend the life of a septic system from the usual 15 years to 30 years. Still, RV septic systems often fail prematurely.

The septic permit issued to the RV park compromises the health of the Guadalupe. The riverbank, adjoining terrain and fields serve as a sponge, absorbing water during wet weather. Referred to as riparian, its water continually migrates through the soil toward the river. Seeps and springs from riparian zones replenish the river during drought and are essential to its continuous flow and health.

The RV park’s septic tanks and drain-fields are embedded in this riparian sponge. We can expect the heavier than normal bacterial count and untreated caustic chemicals percolating from the septic system to mix with the naturally migrating water and seep into the adjacent Guadalupe. The predictability of early tank corrosion and system failure presents the risk of surface pollution draining directly into the river. The health and safety of RV park occupants is in immediate danger with such surface contamination.

Survival of the adjacent public recreation area, Brinks Crossing, is questionable. This Guadalupe swimming hole named the third best in the state in a 2008 edition of Texas Monthly and again hyped in 2012, receives the runoff, seeps and migrating water directly from the RV park’s septic system. Additionally, the river will carry any fecal and chemical contaminants the short distance downstream to Lions Park Dam, a busy swimming destination for children. Is it possible river contamination at this site could sacrifice the Guadalupe as a statewide recreational attraction?

There are no public safeguards such as inspections for breakdowns, measuring river contamination or ensuring repairs when failures occur. Kerr County’s Environmental Health Department who issued the OSSF permit is not staffed for such monitoring. The department depends upon the public and owners to self-report failures. Can we expect this owner who is avoiding the safety of an LCSS system and TCEQ oversight to self-report?

Many Texas counties have specific rules for construction of RV park septic systems. Kerr County has no guidelines, nor do we have a licensed sanitarian available to counsel our county employees tasked with issuing the RV park’s OSSF permit. Of course, the accepted path of following the 5000 gallon rule would assure TCEQ oversight of planning, construction and maintenance through an LCSS permit.

Our county officials spent untold time and energy plus $3 million on the Kerrville South Wastewater Project designed to replace failing residential septic systems polluting a Guadalupe tributary. A similar plan, the Center Point Wastewater Project, will cost an estimated $44 million to replace deteriorating OSSF’s threatening the river. Now county officials ignore the RV park’s immediate source of contamination—drain fields leeching into the riparian’s recharge. The septic tanks and connecting systems are at high risk for failure long before their 15-year lifespan is reached.

Elected officials are aware of the project’s health and safety issues. They also know that TCEQ oversight of this septic system could prevent much of the damage. Does it seem reasonable for authorities to ignore or perhaps support the creation of another site, sure to require taxpayer funding for cleanup, while the Center Point project is still in the planning stage? Is it possible the RV park site will need cleanup before the Center Point project is completed?

Frances Lovett

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OVERHEARD

Hill Country Alliance Discussion Session, Oct. 20, 2011, in response to comments by various Kerr County community leaders that downstream metropolitan water usage is the cause of Kerr County's water crisis:

"We in Kerr County can negatively affect downstream by overpumping our groundwater and the river--but, in general, we are not affected by what downstream users do [there may be rare exceptions]. Poor watershed management in our region affects our groundwater and springflows. The effects of overpumping groundwater and/or droughts, depletes our springs, which are the main sources of our creeks and the Guadalupe River."

Mike Mecke,
Native of the area (San Antonio), grew up during the Fifties Drought; a retired Water Planner, San Antonio Water System. Retired Water Specialist TX Water Resources Institute @Texas A&M - covered from Region J (Kerr Co.) and across all of West Texas. Current member of Guadalupe River Environmental Flows Committee and Advisory Board for Hill Country Alliance. Co-founder and Advisory Board, Texas Riparian Association.
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***TAXPAYER WATER ALERT***

A public hearing is scheduled for Wednesday, October 19 to gain public opinion on Headwaters Groundwater Conservation District board member Pratt's proposal to switch the cost of well sample collection and analysis from new subdivision drillers to the HGCD thus the taxpayers of Kerr County.

Attention Private Well Owners: Calls to Kerr County Conscience indicate a continuing pattern of misinformation by the usual suspects i.e. a few unscrupulous developers, realtors and investors in Kerr County. The unfortunate pattern is to convince private well owners the HGCD is trying to meter, regulate pumping or assess fees to current or new private wells. That is not the issue.

The Issue: If Mr. Pratt's proposal passes the cost of well samples and analysis for large well permits (new subdivision/commercial/industrial development) will become the responsibility of the HGCD and thus the county taxpayers. Under current rules the driller/developer pays the cost of collection and analysis.

Background: Development, whether residential or commercial needs to take place where there is an adequate well water supply. Unlike surrounding counties our Kerr County Commissioner's Court does not require new subdivision developers to establish a reliable water source before building. The HGCD is largely dependent upon well samples to determine areas of future sustainable water sources within the county. This information is currently obtained by securing well samples during the drilling of new large permitted wells which are usually for a new subdivision and public water supply for the subdivision. The information collected does not affect the well being drilled but allows for mapping of availability and future planning and wise development within the county. A fee for the collection and analysis of the well sample is $4000 to $6000 currently paid by the driller/developer. There is no such requirement for domestic well drilling only those developments/new public water systems with multiple connections or pumping huge amounts of water.

Questions: 1) Should the county taxpayers bear the expense of well samples for large water systems who will be selling the water for profit to the new subdivision residents thus making a profit from the same taxpayers main water supply--- the Trinity Aquifer?
2) Can you expect private well owners as taxpayers to bear the expense of well samples and also live with the new subdivision residents next door pumping their aquifer to the point of depletion?
3) Do county residents deserve appropriate data collection to assure reasonable growth where there is a reliable water source?

Beware: Board member Pratt has been joined by board president, Gordan Morgan, in suggesting we may not need this information at all. Just stop collecting the samples.
1) Would the absence of any absolute scientific information on groundwater stores in the county lead to the same unplanned growth and water shortages Kendall County is experiencing.
2) Is it fair to sell new county residents property without a reliable water source supported by scientific data?

Taxpayers should attend this meeting to voice their opinions. Developers, realtors, and investors will be there in force and they carry a lot of weight with some board members.

October 19th 1:30pm UGRA building

F. Lovett

Comments

​ Kerr County's Bridge to NOWHERE




Kerr County Conscience has learned of another old Kerr County bridge scheduled for replacement. This low water crossing at the Guadalupe and Ehler Lane actually goes to nowhere. The road sign on East Highway 27 warns of "no outlet". After crossing the bridge there is a turnaround in a dirt field with a closed ranch gate and a distant house in site.
DSC02767
The bridge is in Texas Department of Transportation plans and funding has been completed. Total cost of this one bridge replacement is $804,727.76. Engineers have already spent $44,881.80 on the project. Because this is a traditionally funded bridge the county pays a portion of the cost. State funded road projects originate at the local level with your elected county commissioner, in this case Jonathan Letz, Precinct 3. Do not blame TxDOT for this questionable expenditure, they will not proceed with any project not requested by the responsible commissioner and approved by the commissioner's court. TxDOT depends on elected County Commissioners to inform their constituents and hold public hearings to secure public opinion prior to beginning any project. How many voters in Precinct 3 have heard about the bridge replacement on Ehler Lane? How many county resident's had an opportunity to offer their opinion?

Yes, your county property taxes are going toward replacement of this bridge.


Ehler Lane

Is this the best use of your tax dollars? Could this bridge replacement have been delayed while Commissioner Letz was posturing over expenditures for EMS/Fire protection and opposing library funding? Who will benefit from this bridge to nowhere? You can offer your opinion to TxDOT at http://www.txdot.gov/contact_us/form/ and the Kerr County Commissioner's Court at commissioners@co.kerr.tx.us.


F. Lovett
KCC
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