Because several people have already asked me, if Honey Creek Cave extends under the proposed wastewater project site and related questions, below are the comments I have just submitted to TCEQ. I suggest that those of you submitting comments to not focus on groundwater as I did. I believe you will be most effective in focusing on the potential impacts to Honey Creek (the creek) and the habitat it provides.
By the way, the old-timers to Honey Creek Cave who read this may recognize the “dangerous” passage I refer to as the downstream end of the HS Passage (the upstream end of the HS has been the subject of epic tank hauls and dives). George ----------------------- I am the Executive Director of the National Cave and Karst Research Institute, which was created by Congress as the national authority on caves and the vulnerable karst terrains and aquifers in which they occur. I am also a karst hydrogeologist. My PhD dissertation was focused on the proposed wastewater area. Though I currently live out-of-state, I still maintain the database on Comal County caves and karst features for the nonprofit Texas Speleological Survey (TSS) and continue to visit and study the area regularly. Some people are concerned about the project because it is near Honey Creek Cave (HCC). HCC is the longest cave known in Texas with over 32 km of mapped underground streams. The known portions of HCC do not extend under the proposed wastewater project site or the outfall of its effluent. Also, no caves are known to the TSS at the project site for two possible reasons. First, the TSS has not received any reports from cavers or consultants who may have searched the property for such features. Second, that uppermost part of the lower Glen Rose Limestone does not form many cave entrances (most form in the lower section of the limestone), although groundwater recharge into the Lower Glen Aquifer (LRG) occurs readily there. While the mapped part of HCC does not extend under the property, there is one significant underground stream in the cave that heads toward it. It is unexplored due to dangerous conditions. Based on the fact that there is no known spring to account for the substantial flow in that passage, and that the geology would not allow a spring to pop-up unobserved in the bottom of the Guadalupe River or its tributaries in that area, I speculated long ago that the water flows southeast into the Cibolo Creek basin and then across faults into the Edwards Aquifer. Later, in my PhD dissertation on the LGR, I plotted the surface of the water table and geochemical parameters that showed groundwater in fact does move from that part of HCC, under what is now the proposed wastewater site, and to the Edwards Aquifer as I speculated. I also found the faults where that groundwater would likely cross from the Lower Glen Rose Aquifer into the Edwards Aquifer. I’ve long said that while my evidence is very compelling, it is not 100% proof of a connection. More research is needed. However, since writing that 24 years ago, the State has accepted the existence of a general connection between the LGR and Edwards Aquifer as I proposed. It would therefore be prudent of the State to consider this wastewater site as potentially within the boundaries of the Edwards Aquifer and subject to review under those rules. It would also be proper for the State to review the area where the LGR and other adjacent aquifers may contribute to the Edwards Aquifer and include them where the evidence warrants, and focus research on areas where more study is needed. Lastly, the one clear impact of the proposed project is on the surface stream called Honey Creek. It flows through a part of Guadalupe River State Park that was purchased by the State as a preserve and that preexisting purpose should be respected in the State’s decision on this proposal. I have yet to see effluent from a wastewater treatment site not result in nutrient overloading of the downstream riparian area to the detriment of its plant and animal communities. I ask this proposed project be rejected on the grounds that it is contrary to the State's prior decision and 3-decade investment to protect and preserve the Honey Creek riparian area, and for its potential adverse impacts on groundwater quality in the LGR and Edwards aquifers. ******************** George Veni, PhD Executive Director National Cave and Karst Research Institute (NCKRI) and President International Union of Speleology (UIS) Direct address at NCKRI 400-1 Cascades Avenue Carlsbad, New Mexico 88220-6215 USA Office: +1-575-887-5517 Mobile: +1-210-863-5919 Fax: +1-575-887-5523 gv...@nckri.org<mailto:gv...@nckri.org> www.nckri.org<http://www.nckri.org/> UIS address: Titov trg 2 6230 Postojna Slovenia www.uis-speleo.org<http://www.uis-speleo.org/> From: Texascavers [mailto:texascavers-boun...@texascavers.com] On Behalf Of Linda Palit Sent: Monday, August 13, 2018 20:05 To: Cavers Texas <texascavers@texascavers.com> Subject: [Texascavers] Cave Water Quality I will search for some additional information on this but it is time critical. As development continues to occur across the Hill Country some our state most precious natural resources are facing increasing pressure from the expanding population. The TCEQ is currently reviewing an application for a Waster Water Treatment Plant to discharge up to 500,000 gallons of treated sewage effluent into the upper dry portion of Honey Creek which will travel downstream to the flowing part of the creek by the cave entrance and eventually into the Guadalupe River. The TCEQ public comments period is open and this is your opportunity submit your remarks about this proposal. You can make comments at http://www14.tceq.texas.gov/epic/eComment/ and by entering permit number #WQ0015688001. Thanks everyone and I appreciate your involvement.
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