ML19343B845
| ML19343B845 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 12/18/1980 |
| From: | Finlay R EMVURSC |
| To: | |
| Shared Package | |
| ML19343B832 | List: |
| References | |
| NUDOCS 8012300719 | |
| Download: ML19343B845 (26) | |
Text
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DIRECT TESTIMONY OF ROSWELL L. FINLAY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY RE HINDERSTEIN CONTENTION 5/ COASTAL SITES
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DIRECT TESTIMONY OF ROSWELL L. FINLAY RE COASTAL SITES 1 Q. Please state your name and position.
2 A. My name is Roswell Le Finlay. I am a vice presi-3 dent in the firm of URS Company, Dallas, Texas.
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4 Please describe your educational background.
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5 A. I graduated from the Massachusetts Institute of 6 Technology in 1939 with a degree of Bachelor of Science in 7 Civil Engineering.
8 Q. Are you a Registered Professional Engineer?
9 A. Yes, I am registered in the states of Texas, 10 Louisiana, Mississippi, Alabama, Georgia, Florida, Arkansas, 11 Tennessee, Kentucky and New York.
12 Q. Are you a member of any professional organiza-13 tions?
14 A. Yes, I am a member of the American Society of 15 Civil Engineers, the National Society of Professional En-16 gineers, the Texas Society of Professional Engineers and the 17 Consulting Engineers Council, 18 Q. What is your area of expertise at URS Company?
19 A. I work primarily in the area of water resources 20 planning, hydrology and hydraulic design, feasibility studies, 21 and a variety of problems associated with reservoir develop-
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22 ment projects, such as reservoir operating procedures, gate 23 operating schedules and flood control. I have testified in 24 fl d damages suits, in condemnation proceedings in connection l 1
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to reservoir yield studies. -
3 Q. Have you previously examined the question of water 4 availability for the Allens Creek project?
3 A. Yes. URS/Forrest and Cotton, Inc. , which was the 6 name under which our organi=ation operated throughout most 7 of the 1970's, was retained by Houston Lighting & Power 3 Company (EL&P) to study the Brazos River resource base and 9 to advise that Company whether or not the Brazos River 10 Authority (BRA) would be able to furnish to EL&P 176,000 11 acre-feet of water per year through the year 2030.
12 Q. What was the reason you considered a require =ent 13 of 176,000 acre-feet of water per year through 20307 14 A. HL&P had negotiated a contract with the Brazos 15 River Authority under which the Company could call for 16 delivery of up to 176,000 acre-feet of water each year for 17 use at its generating plants. This water was to be de-13 livered at points selected by HL&P below the confluence of 19 the Brazos and Navasota Rivers near Hempstead, Texas.
20 Q. How did your study take into account the rights of 21 other entities to use water from the Brazos River?
22 A. Every appropriation, both permits and certified 23 filings, within the Brazos River Basin was exa=Aned and 24 honored in our basin operation sinulation to the full extent
1 of the permitted right prior to allowing any run-off to be 2 stored in BRA reservoirs or utilized for satisfaction of -
3 EL&P demand. For example, a run-of-river permit upstream 4 from a BRA storage reservoir was assumed to have diverted 5 its full quota of water under the permit terms, provided the 6 water was available in the stream at the diversion point.
7 only surplus water was allowed to flow into the BRA reservoir.
3 During periods of low flow, if there was not sufficient 9 water in the stream this permit right might not be fully 10 satisfied, but no water rightfully accruing to the permit 11 holder was treated as available to BRA or EL&P. In the case 12 of a downstream permit holder with a run-of-stream permit, 13 he was accorded a call on reservoir inflows which must be 14 passed through the reservoir in order to satisfy the down-15 stream prior right. Thus, in our simulation no water was 16 held in storage to which downstream prior appropriators have 17 entitlement. In the case of local demand direct diversion 18 from each reservoir was assumed to the full extent of the 19 applicable permit regardless of stream flow conditions. The 20 local demand placed on BRA reservoirs included all existing 21 permitted and projected municipal uses.
22 Q. How were contractual rights taken into account?
23 A. Certain contractual rights were included as part 24 of local demand and drawn directly from storage; however, a 1
1 large part of the contractual demand is associated with 2 major run-of-river permits below the USGS Hempstead gauge -
3 which are firmed up by BRA storage contracts. In this case ,
4 water is released from storage as requested by downstream 5 permit holders whenever the available flev within the river 6 at the downstream point of diversion is insufficient to 7 satisfy the needs of the contracting user and of remaining
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3 downstream priority rights. Permit terms are usually ex-9 plicit as to when calls on storage must be made if the 10 permit holder is to continue diversion at authorized rates.
11 All such terms and restrictions as explained in individual 12 permits were recognized in the operation simulations.
13 Q. What about riparian rights?
14 A. We assumed that there would be no change in his-13 torical usage. This is an extremely conservative assumption 16 since irrigation from surface yater is projected to be on 17 the decline.
18 Q. What was the basic conclusion of that study?
19 A. We concluded that the Brazos River Authority had 20 the capability at that time to meet all of its existing 21 commitments, including the contract with HL&P, and that it 22 would continue to have this capability through at least the 23 year 2030, even after giving full consideration to rights of 24 thers and projected increases in municipal demand.
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1 1 Q. You mentioned the Brazos River resource base. Can 2 you briefly describe this? -
3 A. The resource base constitutes the flows in the 4 Brazos River and its tributaries, together with the regula-5 tion afforded by the BRA-controlled reservoirs, less uses 6 under prior rights of other entities within the drainage 7 basin, plus return flows from upstream uses. The Brazos 8 River Basin has a drainage area of 44,460 square miles, of 9 which about 9,240 square miles above the Caprock Escarpement 10 is considered noncontributing. This leaves an effective 11 drainage area of about 35,400 square miles. The average 12 discharge of the Brazos River, based on a 50-year record 13 maintained by the USGS, at the Richmond, Texas gauge amounts 14 of 7,354 cfs or 5,328,000 acre-feet per year. This flow is 15 partially regulated by reservoirs, including six under the 16 control of the Brazos River Authority as of the date of our 17 study (1973), with aggregate storage capacity in excess of 13 1,000,000 acre-feet. The six reservoirs in existence at the 19 time of our study and under Brazos River Authority control 20 included Possum Kingdom Reservoir, Lake Granbury, Lake 21 Procter, Lake Belton, Lake Stillhouse Hollow and Lake Somer- l 22 ville. In addition, four other reservoirs were planned.
These were Aquilla, Millican, Laneport, and North Fork !
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24 Reservoirs. Our studies considered both the six reservoir ]
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1 system then in existence and the ten reservoir system antic-2 ipated to be in existence prior co the end of the study 3 period in the year 2030. Two of these reservoirs, Laneport 4 and North Fork on the San Gabriel River, have now been 5 constructed. The San Gabriel River is a tributary of the 6 Brazos River.
7 Q. How was this resource base analyzed to determine 8 availabi]ity of water for Houston Lighting & Power Company?
9 A. Two basin operation simulations were considered in 10 the study, the first based on the six reservoir system then 11 in existence and under the control of the BRA, and the 12 second based on the ten reservoir system ultimately con-13 templated as being under the control of the 3RA. Each of 14 these basin operation simulations was run for the entire 25-15 year study period from 1941 through 1965 with detailed 16 analysis on a month-by-month basis.
17 Q. You speak of reservoirs under BRA control. Was 18 consideration given to other reservo trs within the basin?
19 A. Yes, full recognition was given to the impact of 20 all existing reservoirs in the basin, regardless of owner, 21 on the available water resource below the point at which the 22 Navasota River empties into the Brazos River. This included 23 consideration of evaporation losses from reservoir surface 24 and diversions from these reservoirs to serve other users.
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1 Recognition was given to the resource depletion associated 2 with Stamford, Millers Creek, Graham, Hubbard Creek, Fort 3 Phanton Hill, Elm Creek, Leon and Smithers Reservoirs, none 4 of which are under BRA control and to two existing federally 5 controlled reservoirs, Waco and Whitney, in which the BRA 6 has no conservation rights. Recognition was also given to 7 the 220 Soil Conservation Service (SCS) floodwater retarding 8 reservoirs which had been completed as of 1972. Allowance 9 was also made for anticipated future SCS reservoirs under 10 year 2030 conditions.
I 11 Q. Why was the period 1941 through 1965 chosen as the 12 study period?
13 A. This 25-year period is representative of the full 14 range of hydrologic phenomena which woul". be expected to 15 occur in the Brazos River Basin. It covers the continuous 16 period of historical flow records, including a period of 17 relative plentitude from 1941 through 1948, a period of 13 severe drought from 1949 through 1956, and a period of plentitude from 1957 to 1965. The drought of 1949 through 19 20 1956 extended more specifically from July 1949 through January 1957. In both of our simulation operations, all 21 reservoirs were full at the end of June 1949, experienced 22 23 rapid recovery beginning in February 1957 and were full and spilling by May 1957. This drought is generally referred to 24
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d 1 as th- '950 to 1956 Drought.
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In order to test the severity 2 of this drought period against other periods, rainfall 3 records were examined for the much longer period starting in
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4 the 1880's and extending into the 1970's. These records 5 confirmed that the drought from 1950 to 1956 is the most 6 severe drought experienced in the Brazos River Basin since 7 records have been available. It can be inferred from re-8 ference to records from rainfall gauge stations in operation 9 prior to the 1880's and lying outside of the Brazos River 10 Basin but subject to the influence of the same meteorological 11 conditions that this is possibly the most severe drought 12 since 1856. There were some severe droughts of short dura-13 tion during the 1915 to 1918 period, but these short dura-l l 14 tion droughts are not critical in basin operation or re-15 servoir yield studies.
l l 16 Q. What exactly is a basin operation simulation?
l l 17 A. It is computer analysis, starting at the upper end 1
18 of the drainage basin, and working step by step downstream 19 through the various sub-basins of the Brazos River, in this
- 20 instance, and tributary streams. The analysis starts with l
21 runoff data within each sub-basin, accounts for all diver-22 sions for beneficial use in accordance with existing rights, 23 with due consideration of relative priority between these 24 rights, and develops net inflows to all water supply re-i
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1 servoirs. Calls in inflows by prior downstream rights are 2 identified so that they may be passed on through to satisfy -
3 these rights. cua system reservoir routings are accomplished, 4 as a part of the overall basin operation simulation, in 5 which storage changes, evaporation losses, reservoir de-6 mands, spills and releases are all quantified on a monthly 7 basis. The impact of non-system reservoirs on downstream 8 flows was also evaluated by individual reservoir routings 9 which, in general, were accomplished by equating demand with 10 reservoir yield to determine spills. In some instances, 11 where minor water supply. reservoirs were involved, it was 12 simply assumed that the entire watershed above the reservoir 13 would be non-contributing to the downstream resource. In 14 this way, all basin reservoirs and uses were evaluated in a 15 step-by-step process. This process develops the total 16 available flow an the Brazos River just below the USGS 17 Hempstead gauge. It also demonstrates how these flows, 18 together with releases from BRA reservoirs, and calls on 19 inflows to BRA reserVJ1rs are able to satisfy the rights 20 below Hempstead, including the projected HL&P demand to the 21 year 2030.
22 Q. Why is your study based on flows as measured by 23 the USGS Hempstead gauge?
24 A. The August 1, 1972 contract which Houston Lighting t
1 & Power Company has with the Brazos River Authority provides 2 that the water to be furnished under the contiact will be 3 delivered at diversion points selected by Houston Lighting &
4 Power Company below the point at which the Navasota River 5 empties into the Brazos River. Hempstead is a long-term 6 gauge upstream from the proposed point of diversion for the 7 Allens Creek facility and above major prior rights in the 8 lower basin. It is also downstream from all major tribu-9 taries, such as the Navasota River. It is primarily a point 10 of convenient reference for the operation simulation in 11 which the net effect of all upstream run-off, permitted 12 diversions, evaporatior. losses, impact of SCS reservoirs, 13 and storage changes can be accumulated to develop the total 14 available flow below the mouth of the Navasota River. Also, 15 it is a realistic point of reference in that many permits in 16 the lower basin are tied to the downstream gauge at Richmond, 17 and the surplus flow at Hempstead, as compared with minimum 18 flow rcquirements at Richmond, is a measure of water avail-19 able on a run-of-river basis to satisfy existing permits.
20 Q. What was the basic data on which you based your 21 basin operation simulation?
22 A. Each of the basin operation simulations utilized 23 reservoir inflow data based on " natural runoff" data. These 24 were adjusted to reflect the affect of diversions under all l
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1 prior rights, assuming full utilization of such rights and 2 full satisfaction of all BRA contracts. In addition to the '
3 priority afforded existing rights, municipal and domestic 4 water requirements from surface water sources were projected 5 to the year 2030 and these requirements were given priority 6 over all demands in the river basin and dependent coastal 7 areas, including EL&P's requirements. Recognition was also 8 given to the effect of re-regulation of main stem flowr, by 9 Whitney Reservoir and to evaporation losses from ell re-10 servoirs within the Brazos River Basin whether or not the 11 reservoirs are controlled by the Brazos River Authority.
12 The basin operation simulation also included consideration 13 of losses attributable to existing and planned floodwater
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14 retardation structures.
15 Q. What do you mean by " natural runoff"?
l A. The Bureau of Reclamation has prepared estimates l 16 i
17 of runoff in the Brazos River watershed. " Natural runoff" 18 is defined by the Bureau of Reclamation as follows:
1 19 Natural runoff at a point or from a watershed is the runoff which would have occurred with historic land 20 treatment, ponds and minor reservoirs, and floodwater retarding structures but a constant minimum condition 21 of development in all other respects. Thus, if a l reservoir were constructed within a watershed during i 22 the period of streamflow record and period of study, the historic runoff from the subwatershed after the 23 reservoir began operation would be increased by the
- amount of the estimated reservoir depletions to obtain l 24 natural runoff. Diversions and return flows which 1
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1 reflect changed develop =ent are adjusted out in a si=ilar =anner. Small depletions caused by develep-2 =ents which were anchanged during the entire per cd of strea=ficw record er entire period of study are no:
, 3 adjusted cut in calculating natural runoff.
4 Q. What provision was =ade for future =unicipal 5 de= ands which wculd have priority over EL&P's contract with 6 the 3RA?
7 A. We projected future population and asscciated 3 =unicipal type de= ands to determine the extent to which the 9 existing resource would be taxed by this anticipated higher 10 cricriev. rec.uire=ent.
. These er o "aections indicated a 2030 111 population of 2,275,625 for the 3ra:os River contributing 12 watershed areas as cc= pared with the 1970 census value of 13 1,115,770 for the sa=e area. The =unicipal and rural water 14 require =ents associated with this projected population as of 15 the year 2030 a= cunts to 375,406 acre-feet frc= surface 16 water sources and 99,616 acre-feet per year frc= ground 17 water sources for a total of 475,222 acre-feet per year.
13 Q. Ecw do =unicipal uses as projected by you to the 1.o vear 2030 cc==.are with current usa 9e?
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20 A. We have projected a population increase within the 21 service area of the Bra:cs River Basin of a- er roximatelv. 204 22 percene between the 1970 census and the year 2030. We have 23 also projected an increase of about 30 percent in the per 24 capita daily consumption. This results in an increase in
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1 municipal use from about 154,000 acre-feet per year in 1970
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2 to about 475,000 acre-feet per year in the year 2030, or an -
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3 overall increase of about 321,000 acre-feet per year. Fe 4 also assu=ed a shift from grounC water to surfac' water for 3 a portion of this demand even though it is highly possible 6 that present ground water source will continue to be utilized.
7 Q. What consideration did you give to riparian rights?
3 A. We gave full consideration to riparian rights, 9 which have been filed in accordance with Texas Law. It must 10 be recognized that these filings in many instances were
.1 simply claims made in an attempt to establish the right and 12 do not necessarily bear any relationship to historical usage 13 or probable future usage. As a result, it is extremely 14 doubtful that these clai=s will ever be exercised to the 13 extent implied by the filings. With respect to the impact 16 of possible future riparian irrigation, our investigation
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17 indicates that irrigation within the Brazos River Basin will 13 probably be on the decline and apparently lacks economic 19 justification when the high investment and operating costs 20 associated with the utilization of surface water resources are considered. Nevertheless, no adjustment of riparian 21 22 irrigation was made. Since historical uses were reflected 23 by the runoff data utilized, this was equivalent to assuming that future riparian uses will continue in amounts equivalent 24
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1 to historical uses.
2 How many permits and certified filings are there Q.
3 in the Brazos River Basin?
4 A. In the range of 400-500. These were all analyzed 5 in the course of our study.
6 Q. Were they all considered in your basin operation 7 '
simulations?
8 A. Yes. Detailed consideration was given tc all 9 existing appropriations and contracts, all of which were 10 assumed to remain in force thro 1tgh the year 2030, regardless 11 of actual termination dates on some of the contracts. These 12 rights were fully honored in basin operation simulations, 13 and the requirements of Houston Lighting & Power Company 14 were satisfied only af ter satisfaction of all of these other 15 rights.
16 Q. Does this mean that, in your basin operation 17 simulations, HL&P only took water after all holders of prior 18 appropriations and contracts were fully satisfied?
19 A. No. There is a big difference between permit 20 holders being satisfied and permit rights being fully honored.
21 In our operation simulations, all prior rights were fully 22 honored in accordance with permit terms. However, permits 23 can only grant rights to a resource to the extent that it 24 exists. For example, a permit holder on a tributary stream
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1 may be granted the right to the natural flow in the stream 2 at his authorized point of diversion, but if there is no -
3 flow, he is out of luck. Ht might have to call on the 4 inflows to an upstream reservoir, and all such rights were 5 honored in our simulations. But, he would not have any 6 rights to water which entered the stream below his point of 7 diversion. Of course, this would be the case whether or not 3 HL&P uses any water for the Allens Creek project.
9 Q. Can you give us some concept, based on your studies,
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10 of the relationship between water supp1f available within 11 the Brazos River Basin, and existing commitments on this 12 resource?
13 A. The resource base constitutes the flows in the 14 Brazos River and its tributaries, together with the regula-15 tion afforded by the BRA-controlled reservoirs, less uses 16 under prior rights of others within the drainage basin and 17 plus return flows. The average natural runoff for the 25 18 year study period of 1941 through 1965 in the Brazos Basin 19 is 6,190,640 acre-feet. Of more significance is the natural 20 run ff in the critical drought period, 1950 through 1956, 21 for which the average natural runoff is only 2,695,000 acre-22 feet, or about 44% of the long term average.
23 In that portion of our study dealing with the initial 24 six reservoir system controlled by BRA, the adjusted inflow
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l 1 to these reservoirs averaged 953,000 acre-feet per year 2 during the critical drought period. The usable storage -
3 available, allowing for siltation to the year 2030, amounts 4 to about 1,084,000 acre-feet, of which about 268,000 acre-5 feet were still available at the end of the critical period.
6 This indicates a total storage draw down of about 816,000 7 acre-feet over the six year drought period or an average of 3 about 122,000 acre-feet of water per year. Thus, the avail-9 able resource under the control of the BRA with the initial 10 six reservoir system in operation amounts to about 953,000 +
11 122,000 or 1,075,000 acre-feet per year during the critical 12 drought period. Of this amount, approximately 173,000 acre-13 feet per year is lost during the critical period to evapora-14 tion from the six system reservoirs. This leaves an average 15 of about 902,000 acre-feet per year, during the critical l
16 period, with which BRA can satisfy up its contractual obli-17 gations, and satisfy local demands.
18 Q. What is the total demand on this supply?
l 19 A. Local demand on the six BRA controlled reservoirs 20 totals about 203,000 acre-feet per year, and has been treated 21 as a constant in our operation simulation. Another 62,000 22 acre-feet average demand during the critical period went to 23 firm up BRA contracts below Hempstead other than the con-24 tract for HL&P. Finally, an average of about 65,000 acre-l
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1 feet per year was used during the critical period to firm up 2 ll the projected EL&P demand for 176,000 acre-feet per year. -
3 Thus, actual delivery from BRA reservoirs averages about 4 330,000 acre-feet per year during the critical period, 5 including the EL&P demand. Had it been necessary to supply 6 the full 176,000 contracted to HL&P out of the BRA reservoirs 7 each year, there would have still been a 76,500 acre-feet 3 supply of water in storage left in the six BRA system re-9 servoirs at the end of the critical period, under projected 10 year 2030 demand and siltation conditions. With a ten-11 reservoir system, the residual usable supply of water in 12 storage at the end of the critical period would have been 13 669,000 acre-feet.
14 Q. In your reservoir operation simulations, has any 15 water been utilized to satisfy EL&P demands at the expense 16 of other appropriations?
17 A. No. All rights were fully honored in the data i 18 processing phase. The adjusted inflow to BRA reservoirs was 19 fully depleted to the extent of all upstream run-of-river 20 permitted diversions; permitted calls on inflows for down-stream use; and the effects of the SCS program. l 21 22 Q. Have you reviewed your 1973 study to see if_it is 23 still an accurate analysis of supply and demand on the 24 Brazos River?
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A. Yes, I have and I find no reason to change any of
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our prior conclusions. You must keep in mind that we were 3
asked to give HL&P our professional opinion that there would 4
, be an adequate water supply in the Brazos River for the BRA 1
1 to honor its contract and supply water to the year 2030.
6 HL&P had entered into negotiations with the Brazos River 7 Authority for 176,000 acre-feet per year of water supply, 3 and contract terms based on this requirement had been nego-9 tiated. However, a condition to HL&P's obligations under 10 the contract was assurance from independent consultants 11 relative to the BRA's capability of furnishing the desired 12 quantity of water. Accordingly, we were requested to ex-13 mnine in detail all outstanding rights and the burden that 14 these would place on rhe Brazos River resource base, plus 15 future projected requirements which might be anticipated as
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16 having a priority over HL&P's contractual rights. HL&P
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17 recogni=ed from the outset that a contract, even though 18 signed in good faith, would be worthless if the resource 19 base and the level of regulation available to the BRA should l 20 prove insufficient to satisfy all priority demands ahead of 21 the HL&P needs :hroughout the life of the project. In view 22 of this realization, they imposed extremely strict criteria 23 on our study. The end objective was to assure HL&P that 24 water wou3d be available in accordance with contract terms l
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1 through the year 2030 or to alert them that they could 2 anticipate deficiencies and that the BRA might not be able -
3 to supply the contracted amount under certain conditions.
4 We were in no way attempting to produce a " favorable answer" 5 which would in any way go in the face of possible reality.
6 Nevertheless, our conclusion was that BRA could, with the 7 then-existing six-reservoir system, supply the necessary 8 water until the year 2030 and would have even further en-9 hanced capability upon completion of the projected ten-10 reservoir system.
11 Q. Do you feel that this is a conservative conclu-l 12 sion? -
I 13 A. Yes, I do.
14 Q. Why do you feel that it is conservative?
15 A. In each of the basin operation simulations, the 16 full HL&P contract demand of 176,000 acre-feet per year was 17 satisfied without any shortages, and with prior satisfaction 18 of all other rights, present and projected. In our six l 19 reservoir study the total storage in the existing (1973) BRA l
20 controlled reservoirs amounted to 1,084,000 acre-feet. This 21 storage was full at the end of June, 1949, the start of the 22 critical period, and was drawn to its lowest level by January 23 of 1957 when the available storage reserve had been reduced 24 to 268,000 acre-feet. The total storage in the future ten
1 reservoir study amounted to 1,961,000 acre-feet. This 2 storage was also full at the end of June, 1949, and was 3 drawn to its lowest level by January of 1957 when the avail-4 able storage reserve had been reduced to 842,000 acre-feet.
5 This residual storage reserve remaining at the end of the 6 critical period, amounting to 25% of the total available in 7 the six reservoirs and 43% of the total available in the ten 8 reservoirs affords a substantial margin of safety, indicat-9 ing that the BRA should have the capability of firming up a 10 significantly larger supply at the HL&P delivery points than 11 the 176,000 acre-feet per year stipulated in the contract.
12 As a further test of the margin of safety provided by the 13 system operation, additional computer runs were made utiliz-14 ing a demand of 276,000 acre-feet per year by HL&P, an 15 amount which exceeds the contract limit by 100,000 acre-feet 16 Per year. These test runs indicated that with the existing 17 six reservoir system, the remaining storage at the end of 18 the critical period would still be 118,000 acre-feet, and 19 with a ten reservoir system the remaining storage would be 20 660,000 acre-feet at the end of the critical period. Even with this deliberate test overdraft of 100,000 acre-feet per i 21 f
22 year, no shortages were experienced.
Whenever there was a choice as to procedure, the policy 23 24 was to follow that procedure which resulted in the heaviest
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1 burden on the resource. For example, not all permits below 2 Hampstead predate Possum Kingdom, but because of the im-3 practicability of separating these out, it was assumed that l 4 all permits below Hampstead had priority over Possum Kingdom, l
5 even though, in fact, priority exists only in relation to 6 the more recent BRA-System reservoirs. It should also be 7 recognized that some non-municipal water is utilized in the 8 basin above Possum Kingdom which is junior to the Possum 9 Kingdom right.
10 The assumption was made that existing appropriations 11 would be exercised to the fullest extent at all times. Of 12 course, this is an extremely conservative assumption because 13 a permit right defines the upper limit of use and in no 14 sense defines the use to be anticipated at any given point
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15 in time; nor does such a procedure give any credit to di-16 versity of uses between different permit holders.
l 17 With reference to ground water, substantial amounts are 18 now in use for both municipal and irrigation purposes within 19 the drainage basin. In many instances it was assumed that 20 current ground water supplies would be shifted to surface 21 water with a net result that the return-flow associated with 22 the municipal ground water becomes lost to the system re-source. The less conservative but possibly more realistic 23 24 approach would have been to assume that existing ground
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1 water remained in service thereby decreasing the local 2 demands on reservoirs and increasing the return flow in-3 crement from ground water sources.
4 with reference to the utilization of a six reservoir 5 system versus the anticipated future ten reservoir system, 6 it should be noted that it was considered highly improbable 7 that the year 2030 condition demands as projected would ever 3 develop without prior construction of additional reservoirs.
9 In spite of this, the computer runs indicated that the six 10 reservoir system would meet all future demands without ex-11 hausting the available reserves and would even be able to 12 satisfy an increased annual demand of an additional 100,000 13 acre-feet or a total of 276,000 acre-feet for Houston Light-14 ing & Power Company. In other words, while future reservoir 15 construction will enhance the BRA's capabilities and ma~ r gin 16 of safety in performing under its contract with HL&P, the 17 capability of satisfactorily servicing this contract existed 18 under the six reservoir system of 1973, without new con-19 struction.
20 Q. Have you examined each of the foregoing assump-21 tions to determine if any should be changed because c:
22 changes in conditions since 1973?
22 A. Yes, I have. I have concluded that we were suf-24 ficiently conservative in our assumptions and no changes
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1 need be made in our prior conclusions. The BRA has the 2 capability today of furnishing the desired water to HL&P and -
3 will continue to be able to provide this water even in the 4 absence of future reservoir construction and with due con-5 sideration of all existing prior rights and projected future 6 demands.
7 Q. You stated Laneport and North Fork Reservoirs on 8 the San Gabriel, two of the four additional reservoirs con-9 sidered in the ten reservoir study, have been completed 10 since the 1973 study. What effect would this have on your 11 conclusions?
12 A. In terms of contract capability, there would be no 13 effect whatsoever. Both of these reservoirs are downstream 14 from the initial six reservoirs under BRA control considered 15 in our study. The contract as written is based on the l 16 capability of these six reservoirs alone, and the addition i
17 of these two reservoirs on the San Gabriel has no impact on 13 the yield capability of the upstream reservoir. However, in l 19 terms of overall basin yield, these two reservoirs add to 20 the overall control of the basic basin resource through 21 addition of an init .1 102,600 acre-feet of storage, of 22 which 85,000 will still be available as of the year 2030.
23 This increases PRA's flexibility in overall system opera-tions to the extent of about 10 percent of the incremental 24
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1 capability accorded by the future ten reservoir system over 2 the initial six reservoir system.
3 What about Lake Limestone?
Q. .
4 A. Lake Limestone is located on the upper Navasota 5 River below Lake Mexia. Its yield of 70,109 acre-feet is 6 the result of an impoundment under a permit which is junior 7 to all downstream permits existing at the time of our study.
8 Furthermore, the HL&P contract is based solely on the yield 9 capability of the initial six reservoirs without considera-10 tion of Lake Limestone. None of the water impounded in Lake 11 Limestone flows into any.of the initial six reservoirs con-12 sidered in our study. Therefore, it is clear the construc-13 tion of Lake Limestone in no way impairs the capability of 14 the BRA to supply the requirements of the HL&P contract.
15 Q. Would you please summarize your testimony?
16 A. Based on the extensive study which we have done on 17 the question of supply and demand in the Brazos River, it is 18 my opinion that there is adequate water to supply the Allens 19 Creek plant without jeopardizing the rights of other users l
20 in the Brazos River Basin. Our analysis demonstrates that 21 the BRA can provide HL&P the full 176,000 acre-feet of water 22 provided for in the contract. ACNGS Unit 1 will only have 23 an annual makeup requirement of 30,000 acre-feet, less than 24 one-fifth of the water from the Brazos River Basin which our
1 study confirms is available to HL&P under its contract.
2 Does this complete your testimony?
Q.
3 A. Yes.
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