Comments from Victoria County/Refugio Groundwater Conservation
District
Garrett Engelking, General Manager
In my brief review of the draft, it has inherently left out what I believe
to be a key agency. Groundwater Districts have some of the important
information that may be needed. We have or may know the location of all
septic systems within a district because every domestic water well needs a
septic system. Secondly the location of some water wells for livestock
purposes may lead to a simplistic observation that this an area of
congregation for livestock animals, and that bacteria may persist longer in
these areas as a result. Some livestock wells are located next to
depressions that may flood during high rainfall events leading to a
potential point-source for some of the bacteria.
The density of wells is further more an indicator of more activity, thereby
providing further evidence that a Groundwater District may have information
vital to assessing or evaluating a TMDL project.
I have experience in TMDL s as a research scientist at TAMUK, and collecting
much the data for Sandy and Elm Creek in the Guadalupe watershed, Onion
Creek on the Colorado Watershed, Aransas, Nueces, and Frio Rivers, Upper and
Mid Cibolo Creeks, and Leon Creek in the San Antonio Watershed back in
2000-2002.