Lost Pines Board is set to take FINAL action on End Op's 
Permits & Well Monitoring Agreement

August 10, 2016 at 6:00 PM
Bastrop City Hall
1311 Chestnut, Bastrop, TX 78602
Permit conditions are inadequate to protect Colorado River
and shallow domestic wells

BE THERE ... and let your voice be heard.   

Lost Pines Groundwater Conservation District's  (District) Board of Directors will hear consider  approval  of End Op's Application for Operating and Export Permits  and Well Monitoring Agreement  at the August 10 Special Called Board Meeting (Items 3 & 4 on
Agenda ).  Public comments will be heard at the the "Final Hearing" on the application. 
Final action to approve the Permit and Agreement 
will likely be taken at  this  meeting.  

A final decision by the Board will trigger activation of the Landowners'
 appeal to Bastrop District Court regarding the Boards' denial of our petition
 for party status  at the End Op Contested Case Hearing 

We urge that you attend and make oral comments 
and/or let your presence be your comment.    

At the time of this writing, we are waiting to hear from the District on whether or not comment made over the last several months are being taken seriously and have been incorporated into the Permits and Well Monitoring Agreement.  
As of our last analysis of the Permit and Well Monitoring Agreement, Environmental Stewardship believes the permit is premature and that the Special Conditions in the Operating Permit are inadequate to protect surface features like a) the Colorado River and its tributaries,  b) the trees and terrestrial vegetation, and c) the shallow domestic wells in the Simsboro and related aquifers (Calvert Bluff, Hooper and Carrizo aquifers).   The amount of pumping requested further jeopardizes the desired future conditions (DFCs). 
1.    The permit is premature because the District and the Applicant (End Op) have not yet complied with the Texas Water Code law that is designed to protect surface features, shallow wells, and guide permit decisions.  
  • Section 36.113(d)(2) requires that "before granting or denying a permit ...the district shall consider whether the proposed use of water ... unreasonably affects existing groundwater and surface water resources or existing permit holders". This law has been on the books for over 18 years, yet groundwater districts continue to ignore this law in making final permit decisions.          
    • Existing groundwater resources includes other aquifers such as the Carrizo, Calvert Bluff, and Hooper aquifers.
    • Existing surface water resources includes rivers, streams and springs (which would include springs and seeps that hydrate near surface soils that support terrestrial vegetation.
    • Existing permit holders include exempt domestic wells that are registered with the District. 
  • Neither the District nor the Applicant have done such analyses as are required by this section of the Texas Water Code.  If such analyses have been done, they have not been made public during these administrative proceedings.

2.    The permit is inadequate because it does not contain Special Conditions that a) allow future adjustments to the permit based on the impacts listed in 1 above as better information become available, and b) provide mitigation for wells in aquifers other than the Simsboro aquifer.   Furthermore, the draft Operating Permit ignores groundwater availability modeling (GAM) that predicts that:

  • End Op pumping in the quantities requested in the Simsboro Aquifer will draw water from other aquifers thereby causing significant drawdown in the Carrizo, Calvert Bluff and Hooper aquifers.
    • These drawdowns will extend into other adjacent counties and adjacent groundwater districts as far away as Gonzales, Lavaca, Colorado, Austin, Grimes and Walker counties (see sidebar below).
  • End Op pumping in the quantities requested will decrease the amount of groundwater that currently flows from the aquifers and into the Colorado River, streams and springs, thereby reducing their flow - especially during drought conditions - in Bastrop and Lee counties ( see sidebar below).
  • Contrary to what groundwater hydrologists claim, the model predicts that the groundwater pumped will come from the sources listed below.  The impact is to cause irreversible damage to surface waters and shallow wells with little or no recourse provided in the Special Conditions. The sources, in order listed, are:
    • First, the reduction in outflows to surface waters and features
    • Second, from leakage into the Simsboro from the other aquifers and from other counties,
    • Third, and last, from storage that is in the deep sections of the aquifers.
  • Special Condition (4) that defines the terms used in the calculation to determine whether or not End Op can advance to the next level of pumping does not include a factor that considers future changes in the "rate of change" that are predicted by the groundwater model.  
    • ES modeling predicts that this factor could be off by 15% or more. 
    • Differences in this calculation would likely result in granting an increase in pumping to the next phase level that would lead to a greater exceedance of the desired future conditions.  
3.     The permit further jeopardizes the desired future conditions (DFCs) for the aquifers, the District, adjacent Districts, and the region (see sidebar below)
  • The model predicts that End Op pumping, especially when combined with other permitted pumping in the region (baseline pumping + End Op pumping + Forestar pumping + LCRA pumping + Vista Ridge pumping), will cause the desired future conditions of the Simsboro Aquifer to be exceeded by 200-300 ft of drawdown.
    • This level of exceedance will trigger "pro-rata" curtailment of all permitted pumping.  However, once contracts, pipelines and communities dependent on the water are in place, we believe it is very unlikely that such curtailment will be possible. 
Please help us sustain our efforts to protect and defend our groundwater
 and surface water resources by making a 
tax-deductible donation today.  
Environmental Stewardship  RECOMMENDATIONS and REQUESTS


1.     In order to comply with Section 36.113(d)(2), the Operating Permit should contain a condition that states that: once the ongoing GAM improvements are completed, the District, working with GMA-12, will conduct studies to predict and consider:
a.    The impact of the permitted pumping on surface waters and terrestrial               habitats,

b.    The impact of permitted pumping on hydrologically connected aquifers

c.     The impact of the permitted pumping on domestic wells in hydrologically           connected aquifer,

d.    The impact of the permitted pumping on currently adopted DFCs.

e.    Changes that may be made to the terms and conditions of the Operating          Permit to accommodate the above findings. 


2.     Special Condition (13) on mitigation should be amended to include the "Simsboro, Calvert Bluff, Carrizo, and Hooper aquifers" in order to protect registered domestic wells in the communicating aquifers.  

3.    Special Condition (4) calculations should be revised to include a factor that considers future changes in the "rate of change" that are predicted by the groundwater model.

4.    The monitoring well agreement should contain a requirement that groundwater-surface water monitoring wells be included to provide real-time data on the impact of pumping on the Colorado River and its tributaries. 

5.    The Operating Permit should contain "living document" language to convey that this is a work in progress and subject to future revisions.

Please help us sustain our efforts to protect and defend our groundwater
 and surface water resources by making a 
tax-deductible donation today. 

Steve Box
Executive Director
Environmental Stewardship
P.O. Box 1423
Bastrop, TX 78602   

Join Our Mailing List
ES logo jpg
Regional Impacts of Combined 
Groundwater Pumping

The combined pumping in the Simsboro Aquifer is predicted to cause 900 to 1200 feet of drawdown in Burleson and Lee counties by the year 2060 according to groundwater modeling conducted by professional hydrologist George Rice ( Click here for Rice Report March 22, 2016).  The affects of groundwater pumping within Lost Pines and Post Oak Savannah Groundwater Conservation Districts (GCD) are predicted to impact not only the Simsboro Aquifer, but also the Carrizo, Calvert Bluff and Hooper aquifers extending to points as far away as Gonzoles, Lavaca, Colorado, Austin, Grimes and Walker counties.   These aquifers are hydraulically connected throughout the Carrizo-Wilcox Aquifer Group.
  • More than 200,000 ac-ft/y.r of permits and deals are in play.
  • On top of about 90,000 ac-ft/yr of other permitted pumping.
The groundwater availability model predicts:
  • Significant communication between the Simboro, Hooper, Carrizo and Calvert Bluff aquifers in the Carrizo-Wilcox Group.
  • Significant drawdown in the Hooper, Carrizo, and Calvert Bluff aquifers from anticipated pumping of the Simsboro Aquifer.  
Baseline plus additional planned pumping is predicted to exceed the current and proposed desired future conditions (DFCs)  by 200-300 feet of drawdown for the Simsboro Aquifer by 2060 (see Table 3 from Rice Report), and will decrease flow in the Colorado River (see Figure 5 below).    

Rice used the same groundwater availability model (GAM) as is used by the groundwater districts.  Baseline pumping data were provided by the Lost Pines GCD and included baseline pumping in Lost Pines and Post Oak Savannah Groundwater Districts.  

Additional pumping by Vista Ridge, End Op LP, Forestar Real Estate Group, and the Lower Colorado River Authority were added to the baseline pumping to predict the combined impacts of Simsboro pumping throughout the region.  
Rice concluded that baseline pumping will:
  • Reduce hydraulic heads (i.e., water levels or hydraulic pressure) in the Hooper, Simsboro, Calvert Bluff and Carrizo aquifers. 
  • Where these aquifers are confined, the reduced heads would cause water levels in wells to decline.
  • Where these aquifers are unconfined (recharge areas), the reduced heads would cause dewatering of portions of the aquifers. 
  • Reduce groundwater discharge to the Colorado River, thereby reducing its flow.
  • Additional pumping by Vista Ridge, End Op, Forestar, and LCRA would result in greater head reductions than would baseline pumping alone, and a greater decrease in groundwater discharge to the Colorado River.
Below are drawdown maps showing the impact of baseline plus additional pumping in the Simsboro Aquifer, and the direct affect of the Simsboro pumping on the Hooper, Calvert Bluff and Carrizo aquifers.  (The southeast boundaries of the aquifers shown on the maps are limited by the extent of the GAM model.  It is likely that the drawdowns extend further into the counties south and east of the drawdowns lines shown on the maps). 

Figure 1.  GAM predicted drawdowns in the Simsboro Aquifer due to baseline pumping plus additional pumping by Vista Ridge, End Op, Forestar, and LCRA 2000-2060.

Figure 2.  GAM predicted drawdowns in the Hooper Aquifer due to baseline pumping plus additional pumping by Vista Ridge, End Op, Forestar, and LCRA 2000-2060.

Figure 3.  GAM predicted drawdowns in the Calvert Bluff Aquifer due to baseline pumping plus additional pumping by Vista Ridge, End Op, Forestar, and LCRA 2000-2060.

Figure 4.  GAM predicted drawdowns in the Carrizo Aquifer due to baseline pumping plus additional pumping by Vista Ridge, End Op, Forestar, and LCRA 2000-2060.

Figure 5.  GAM prediction of reduced groundwater discharge to the Colorado River and tributaries. 

Lost Pines Groundwater Statistics
Region K
Below are some statistics about current applications, existing permits and facts from the Lost Pines Management Plan. 

Current Simsboro Aquifer Applications Pending:

-  45,000 acre-feet/yr          Forestar Group      Approved at 12,000 ac-ft/yr
-  10,000 acre-feet/yr          LCRA                    Approved at 8,000 ac-ft/yr
-  56,000 acre-feet/yr          End Op                 Contested
-    2,000 acre-feet/yr          City of Bastrop/XS Ranch   Contested
-    3,226 acre-feet/yr          Manville WSC        Approved
-    3,360 acre-feet/yr          Heart of Texas      Withdrawn
-    1,613 acre-feet/yr          City of Bastrop      Approved

Previously Approved Permits in the Simsboro Aquifer 
-  23,627 acre-feet/yr            Aqua WSC
-    6,653 acre-feet/yr            Manville WSC 
-  11,023 acre-feet/yr            Lee Co. WSC 
-       100 acre-feet/yr            Lee Co. FWSD 
-         67 acre-feet/yr            Hunters Crossing 
-    3,850 acre-feet/yr            Alcoa (currently pumping 6201 acre-feet/yr)
45,365 acre-feet/yr        TOTAL PERMITS FOR SIMSBORO WELLS

  4.4 times the Available Water (2060 MAG) for the Simsboro Aquifer
  5.6 times the Available Water (2010 MAG) for the Simsboro Aquifer



A FEW FACTS From the Lost Pines Management Plan

-  Total Available Groundwater (MAG) in the District by 2060 is 58,888 acre-feet/yr.

-  Bastrop County projected water demand by 2060 is 65,266 acre-feet/yr.

-  Lee County projected water demand by 2060 is 6,603 acre-feet/yr.   

-  Current discharge to surface waters from all aquifers is 78,612 acre-feet/yr.  

-  Net recharge to all aquifers (recharge - discharge) is 7,249 acre-feet/yr.   

-  Current pumping for all aquifers in the District is 47,811 acre-feet/yr (website)

-  Current permits for all aquifers 73,000 acre-feet/yr (Austin-American Statesman) 

websiteblog Website and Blog
WebsiteHeaderLaGrangeWe are excited to announce that we have a new website and blog.  The site contains the same information that was on our old site, but now includes the ability to BLOG.  This means the site is MUCH MORE INTERACTIVE by allowing you, the reader, to make comments on specific pages and information posted.  We look forward to having a conversation with you about your interests and concerns. 

Click here to link to our RSS Feed


If you find this information useful and informative, please and invite them to join our e-News mailing list. 

Be a Supporting Steward

Stay Informed

Be Involved


Join Our Mailing List

Our Mission
NF Archery

Environmental Stewardship is a charitable nonprofit organization whose purposes are to meet current and future needs of the environment and its inhabitants by protecting and enhancing the earth's natural resources; to restore and sustain ecological services using scientific information; and to encourage public stewardship through environmental education and outreach. 

We are a Texas nonprofit 501(c) (3) charitable organization headquartered in Bastrop, Texas.  
Quick Links
Join Our Mailing List