Email (excerpted), Nick Dornak, watershed services program coordinator, The Meadows Center for Water and the Environment, Texas State University, Oct. 12 and 15, 2018

12:24 p.m.

...I would defer to the City of Austin, Watershed Protection Department on this one….

I don’t have the data to confirm or dispute the 60% of streams being unsafe to swim due to bacteria statement. I would venture to say that the part about pets being the primary source of fecal contamination might be a stretch to back up without seeing the study used to justify that claim. Sources of nonpoint source pollution are generally very difficult to conclusively identify. That said, better management of fecal waste from pets is a top priority for watershed protection efforts throughout the state. We do know it is a problem.

Statewide, the majority of our monitored streams are no longer meeting their “designated use”, as defined by TCEQ, due to high levels of bacteria and other contaminants. Other common impairments include high levels of dissolved solids (salts) and depressed dissolved oxygen. Nutrient concentrations (nitrogen and phosphorus) are also major concerns, however, TCEQ does not have listed standards for these algae bloom inducing contaminants, so there are very few regulatory tools for dealing with these harmful pollutants. TCEQ produces a biannual report of documented stream impairments. You will want to look at the 303(d) list.

https://www.tceq.texas.gov/waterquality/assessment

Back to Austin, there was a fairly extensive bacterial source tracking study conducted by a UT graduate student that showed a fair amount of human influence on bacteria concentrations in Austin stream. I saw the poster at a Waller Creek Conservancy event this spring.

Good luck!

Nick Dornak

(Selby)

12:19 p.m.

Oct. 15, 2018

I am back at you--and pasting below what we fielded this morning from a TCEQ official in case you have time to offer more perspective.

Would we be accurate in reading this response as suggesting the cited study didn't apply the best indicator of water contamination affecting swimmability?

Anything more below strike you as substantively important as we review the candidate's claim?

PASTE:

Below are the TCEQ’s responses to the questions you posed about Austin’s waterways:

Is the 60-percent claim accurate? Why or why not?

The 60-percent claim appears to be based on the following statement in the reference study: “Of the 76 test sites within Austin’s city limits, 46 exceeded bacteria levels safe for recreational contact at least once in 2017.” The criterion used in the report is based on the swimmer advisory single sample criterion of 399 colony forming units (cfu)/100 milliliters (mL) E. coli in the Texas Surface Water Quality Standards (TSWQS)(§307.7(b)(1)(A) and §307.7(b)(1)(C)). This criterion is only applicable as a short-term indicator of recreational suitability. This only means that the 46 sites exceeded the short-term criteria on one day. Bacteria data can be quite variable from day to day, and results are dependent upon a number of factors, such as antecedent precipitation. Due to the variability bacteria data, the TCEQ performs assessments of waters over time using a geometric mean criterion. The results of these assessments are reported in the Texas Integrated Report of Surface Water Quality, which provides a better overall assessment of risks associated with recreational activities such as swimming. The TCEQ water quality assessment process and TSWQS are described in greater detail below.

It appears the study sampling is especially concentrated in Austin’s urban core. It is unclear whether the study includes many areas in Austin with a high amount of recreation. For example, there do not appear to be samples from Bull Creek.

TCEQ water samples figured into the study's conclusions. Do those samples support the conclusion aired by Strenger? If not, what would be accurate?

Based on a review of TCEQ’s 2014 Integrated Report for the Austin urban area we arrived at the following:

The results in the table indicate that 9 percent of waters (segments) or 13 percent of stream miles do not meet the primary contact recreation criterion, and no reservoirs were found to exceed the primary contact recreation criterion. This represents the waters where there are exceedances of the standard and therefore an elevated level of risk of illness from contact recreation and do not necessarily indicate areas considered unsafe to swim. Swimming in all natural waters (including those that meet water quality standards) comes with risk, whether that be from pathogen exposure or other risks. Risk of illness can vary from person to person due to other health issues, compromised immune systems, etc.

How does the commission gauge if a waterway has too much contamination to rule out safe swimming?

TCEQ sets recreational water quality standards on the basis of risk, and these standards are based on fecal indicator bacteria (E. coli for freshwater). Fecal indicator bacteria suggest the potential presence of pathogenic organisms of fecal origin that are much more difficult to measure. The Primary Contact 1 (§307.3(50), §307.4(j)(2)(A), §307.7(b)) recreational criteria found in the TSWQS relates to risks associated with activities that are presumed to involve a significant risk of ingestion (e.g., wading by children, swimming, diving, water skiing, etc.). PCR 1 corresponds to the freshwater geometric mean water quality standard (criterion) of 126 cfu/100 mL E. coli. This corresponds with an estimated illness rate of 36 per 1,000 recreators.

TCEQ completes assessments of surface water bodies against the water quality standards and reports results in the Integrated Report. Waterways which do not meet water quality standards are classified as impaired. For bacteria, TCEQ requires at least 20 data points to calculate a geometric mean and assess whether water quality standards are met.

Which Austin and Texas waterways are considered not safe for swimming due to pollution?

The following waters within Austin were determined to be impaired in the 2014 Integrated Report for exceeding the geometric mean criterion for E. coli of 126 per 100 mL:

The full list of impaired waters for Texas can be found within in the Index of Impaired Waters report which is included in the Integrated Report.

Anything more to consider?

Data used by TCEQ are collected by TCEQ as well as Clean Rivers Program partners. The Lower Colorado River Authority is the CRP partner in the Austin area, and the city of Austin provides in kind data to TCEQ via the LCRA CRP. Data used by TCEQ conform to specific monitoring protocols, analytical method requirements, and quality assurance requirements.

Other recommended sources?

• Data used by TCEQ can be accessed through the TCEQ Surface Water Quality Data Viewer.
• The 2014 Guidance for Assessing and Reporting Surface Water Quality in Texas includes detail on the methodology used to perform assessments of the Integrated Report.
• TCEQ monitoring protocols, analytical method requirements, and quality assurance requirements are available on this TCEQ webpage.

More information may be found in LCRA’s CRP Program on LCRA’s CRP webpage.  

12:33 p.m.

I would agree with your assessment. The study looked at a “snapshot” of water quality and represented a kind of worst case scenario that may be a little misleading. This data does show that there are definitely days where swimming may not be safe around Austin area streams. The 5 locations listed as “impaired” in the 2014 Integrated Report represent areas of chronic/long term bacteria concentrations that make it unsafe for contact recreation.

Side note: Meadows is working with the Shoal Creek Conservancy and City of Austin to develop a Watershed Protection Plan for the Shoal Creek Watershed focused on improving water quality through stakeholder driven initiatives.