TITLE 31.NATURAL RESOURCES AND CONSERVATION

Part 2. TEXAS PARKS AND WILDLIFE DEPARTMENT

Chapter 65. WILDLIFE

Subchapter C. PERMITS FOR TRAPPING, TRANSPORTING, AND TRANSPLANTING GAME ANIMALS AND GAME BIRDS

31 TAC §§65.101, 65.103, 65.105, 65.111, 65.115 - 65.117

The Texas Parks and Wildlife Commission adopts amendments to §§65.101, 65.103, 65.105, 65.111, 65.115, and 65.117, and new 65.116, concerning Permits to Trap, Transport, and Transplant Game Animals and Game Birds. Sections 65.101, 65.103, and 65.115 are adopted with changes to the proposed text as published in the July 28, 2000, issue of the Texas Register (25 TexReg 7117). Sections 65.105, 65.111, 65.116, and 65.117 are adopted without changes and will not be republished. The change to §65.101, concerning Definitions, adds a definition of 'supervisory permittee' to establish the distinction between persons authorized by the permit to perform activities and the person who supervises the activities. The change to §65.103, concerning Trap, Transport, and Transplant Permit, alters subsection (a) to limit the requirement for a wildlife management plan to the release site only, alters subsection (b) to require applications received between September 1 and November 15 to be approved or denied within 45 days, alters subsection (d) to allow the movement of antlered bucks only between contiguous or nearly contiguous properties under common ownership, and adds new subsection (g) to stipulate that mortalities incurred during a permitted activity remain part of the total number of animals or birds authorized to be trapped and may not be replaced. The change to §65.115, concerning Notification, Recordkeeping, and Reporting Requirements, alters subsection (a) to require notification prior to each instance of an activity governed by the subchapter; alters subsection (b) to replace the term 'game warden' with the phrase 'employee of the department acting within the scope of official duties' and adds new paragraph (7) to conform the requirements of the subsection to changes made to subsection (c); eliminates the requirements of proposed subsections (c)(7) and (d) and replaces them with requirements for a financial disclosure form to be signed by the trap site owner and the release site owner and included with the supervisory permittee's report to the department; and rewords subsection (e) to require permittees to maintain all animals that die in the course of permitted activities in an edible condition until final disposition.

The amendment to §65.101, concerning Definitions, is necessary to assign meanings to words and terms used in the subchapter. The amendment to §65.103, concerning Trap, Transport, and Transplant Permit, is necessary: for the department to acquire biological information needed to assess proposed relocations of game animals and game birds for the purposes of determining whether such proposals are consistent with the department's statutory obligation prevent depletion and waste; to provide a system for orderly and timely disposition of applications; and to prevent practices constituting the sale of protected wildlife. The amendment to §65.115, concerning Notification, Recordkeeping, and Reporting Requirements, is necessary to: provide a mechanism by which the department is able to monitor permitted activities to assess compliance with the law; to establish a documentation regime to assist the department in determining that a permittee's activities are consistent with the terms and conditions of a permit; to provide for financial disclosure in order to prevent the sale of protected wildlife; and to set forth requirements for the disposition of animals and birds that die in the process of permitted activities. New §65.116, concerning Nuisance Squirrels, is necessary to provide a convenient and user-friendly method for the humane trapping and relocation of squirrels that are destructive to property. The amendment to §65.117, concerning Prohibited Acts, is necessary to: make language structurally and grammatically consistent and to provide a convention for identifying vehicles and trailers used to conduct permitted activities.

The amendment to §65.103, concerning Trap, Transport, and Transplant Permit, will function by specifying the content of a stocking plan, establishing a minimum deer-to-acreage-ratio for the purpose of waiving release-site inspections, implementing a time limit for department review of permit applications, and stipulating the conditions under which buck deer must have their antlers removed for transport. The amendment to §65.115, concerning Notification, Recordkeeping, and Reporting Requirements, will function by establishing a timeframe for notification of the department prior to the trapping, transporting or release of deer, implementing a requirement for permittees to maintain a daily log of permitted activities, requiring permittees to disclose the financial particulars of permitted activities, and specifying procedures for the disposition of mortalities. New §65.116, concerning Nuisance Squirrels, will function by relocating the provisions of former §65.103(g) in a new section for clarity's sake. The amendment to §65.117, concerning Prohibited Acts, will function by implementing an identification requirement for trailers and vehicles used to transport.

The department received 16 comments concerning adoption of the proposed rules. Six commenters opposed adoption of the rules by stating that the rules constituted the privatization of wildlife resources. The department disagrees and responds that wildlife resources are the property of the people of the state, which status is fixed by the legislature and not subject to change by the commission. No changes were made as a result of the comments. Two commenters opposed adoption of the rules because they claimed there were no provisions for the humane treatment of animals. The department disagrees with the comments and responds that in addition to the animal cruelty provisions contained in the Penal Code, §65.116 and §65.117 contain explicit language requiring the humane treatment of animals, violation of which is a criminal offense. No changes were made as a result of the comments. Two commenters opposed adoption of the rules by stating that TPW personnel should be the only persons permitted to trap, transport, and release wildlife. The department disagrees with the comments and responds that Parks and Wildlife Code, Chapter 43, Subchapter E specifically prohibits the state from incurring any expense for trapping, transporting, or transplanting game animals or game birds pursuant to a permit issued for that purpose. No changes were made as a result of the comments. One commenter opposed adoption of the rules because of the possibility of wildlife diseases being transmitted from one population to another. The department, while acknowledging the potential for disease transmission, disagrees with the comment and responds that TPW has no scientific evidence to suggest the likelihood that diseases will be spread as a consequence of the rules. No changes were made as a result of the comment. One commenter opposed adoption of the rules and stated that contraception should be used, rather than relocation. The department disagrees with the comment and responds that there is no credible scientific research to suggest that contraception would have any effect on populations of free-ranging deer. No changes were made as a result of the comment. One commenter opposed adoption of the rules and stated that the potential for abuse was too high. The department disagrees and responds that it believes that the oversight and enforcement provisions of the rules are sufficient to detect and prosecute violations. No changes were made as a result of the comment. One commenter opposed the 'minimal impact release' ratio of one deer to 200 acres, preferring instead a 1:100 ratio. The department disagrees with the comment and responds that the 1:200 ratio represents a consensus agreement arrived at by staff and members of the regulated community. No changes were made as a result of the comment. One commenter opposed adoption because rule language did not stipulate that walk-in traps be used to trap squirrels and because there were no provisions to prevent the death of animals during transport. The department disagrees with the commenter and responds that language in §65.116(3) explicitly requires all trapping devices to be designed not to inflict physical injury to trapped squirrels. With respect to animals expiring during transport, the department responds that §65.117 contains explicit language requiring the humane treatment of animals; however, due to the very nature of such activities the possibility of animal fatalities cannot be completely eliminated.

Texas Deer Association and Texas Wildlife Association commented in support of the adoption of the proposed rules.

The sections are adopted under Parks and Wildlife Code, §43.061, which requires the commission to adopt rules for the content of wildlife stocking plans, certification of wildlife trappers, and the trapping, transporting, and transplanting of game animals and game birds under the subchapter, and §43.0611, which requires the commission to adopt rules for fees, applications, and activities, including limitations on the times of the activities, relating to permits for trapping, transporting, or transplanting white-tailed deer

§65.101.Definitions.

The following words and terms, when used in this subchapter, shall have the following meanings, unless the context clearly indicates otherwise. All other words and terms shall have the meanings assigned by Parks and Wildlife Code.

(1)

Amendment--A specific alteration or revision of currently permitted activities, the effect of which does not constitute, as determined by the department, a new trapping, transporting and transplanting operation.

(2)

Certified Wildlife Trapper--An individual who receives a department-issued permit pursuant to this section.

(3)

Natural Habitat--The type of site where a game animal or game bird normally occurs and existing game populations are not dependent on manufactured feed or feeding devices for sustenance.

(4)

Nuisance Squirrel--A squirrel that is causing damage to personal property.

(5)

Overpopulation--A condition where the habitat is being detrimentally affected by high animal densities, or where such condition is imminent.

(6)

Permittee - any person authorized by a permit to perform activities governed by this subchapter.

(7)

Release Site--The specific destination of game animals or game birds to be relocated pursuant to a permit issued under this subchapter.

(8)

Stocking Policy--The policy governing stocking activities made or authorized by the department as specified in §§52.101-52.105, 52.201, 52.202, 52.301 and 52.401 of this title (relating to Stocking Policy).

(9)

Supervisory permittee - A person who supervises the activities of permittees authorized to conduct activities.

(10)

Trap Site--The specific source of game animals or game birds to be relocated pursuant to a permit issued under this subchapter.

§65.103.Trap, Transport, and Transplant Permit.

(a)

For the purposes of this subchapter, the content of a wildlife stocking plan shall for a release site shall be the same as that required for a wildlife management plan under the provisions of §65.25 of this title (relating to Wildlife Management Plan). No inspection by the department of a release site is required if the release will not exceed a ratio of one white-tailed deer per 200 acres at the release site; however, when the accumulated releases on a tract result in a ratio of one deer to 200 acres, no further releases shall take place unless a site inspection has been performed by the department.

(b)

Applications received by the department between September 1 and November 15 in a calendar year shall be approved or denied within 45 days of receipt.

(c)

The department may deny a permit application if the department determines that:

(1)

the removal of game animals or game birds from the trap site may be detrimental to existing populations or systems;

(2)

the removal of game animals or game birds may detrimentally affect the population status on neighboring properties;

(3)

the release of game animals or game birds at the release site may be detrimental to existing populations or systems;

(4)

the release site is outside of the suitable range of the game animal or game bird;

(5)

the applicant has misrepresented information on the application or associated wildlife stocking plan; or

(6)

the activity identified in the permit application does not comply with the provisions of the department's stocking policy.

(d)

A buck deer transported under the provisions of this subchapter shall have its antlers removed prior to transport, unless:

(1)

the transport takes place between February 10 and March 31 of a calendar year; or

(2)

the trap site and the release site are owned by the same person. The sites shall be contiguous, but may be separated by a water body or public roadway.

(e)

The department may establish trapping periods, based on biological criteria, when the trapping, transporting, and transplanting of game animals and game birds under this section by individuals will be permitted.

(f)

The department may, at its discretion, require the applicant to supply additional information concerning the proposed trapping, transporting, and transplanting activity when deemed necessary to carry out the purposes of this subchapter.

(g)

Game animals and game birds killed in the process of conducting permitted activities shall count as part of the total number of game animals or game birds authorized by the permit to be trapped.

§65.115.Notification, Recordkeeping, and Reporting Requirements.

(a)

No person shall trap, transport, or release a game animal or game bird under a permit authorized by this subchapter unless that person has notified the department not less than 24 hours nor more than 48 hours prior to each instance of trapping, transportation, or release. Notification shall be by fax or telephone contact with the Law Enforcement Communications Center in Austin, and shall consist of:

(1)

in the case of trapping or transport, the supervisory permittee's name, permit number, and the date(s) that the trapping or transport will occur; and

(2)

in the case of release, the date, time, and specific location of the release.

(b)

A supervisory permittee shall maintain, keep current, and furnish upon request by a department employee acting within the scope of official duties a daily log containing:

(1)

the number of game animals or game birds trapped;

(2)

the sex of game animals or game birds trapped;

(3)

the locations where game animals or game birds were trapped and released;

(4)

the dates when trapping occurred;

(5)

the trapping methods used;

(6)

any mortality incurred during the permitted activity and the disposition of carcasses; and

(7)

the completed financial disclosure forms required by subsection (d) of this section.

(c)

The supervisory permittee shall file a report on a form provided by the department not later than 30 days following the expiration date of the permit. The report shall include, at a minimum:

(1)

the number of game animals or game birds trapped;

(2)

the sex of game animals or game birds trapped;

(3)

the locations where game animals or game birds were trapped and released;

(4)

the dates when trapping occurred;

(5)

the trapping methods used;

(6)

any mortality incurred during the permitted activity and the disposition of carcasses; and

(7)

the completed financial disclosure forms required by subsection (d) of this section.

(d)

Upon the completion of trapping activities authorized by a permit under this subchapter, the supervisory permittee shall complete and sign a Triple T verification form. The form shall also be signed by the landowner of the trap site (or a full-time employee of the landowner who is authorized to act on the landowner's behalf) prior to the transport of any game animal or game bird. Upon the release of the game animals or game birds, the form shall be signed by landowner of the release site (or a full-time employee of the landowner who is authorized to act on the landowner's behalf). In the instance that a permit authorizes multiple release sites, a separate Triple T Verification form shall be required for each trap site/release site combination. The form shall be supplied by the department to the supervisory permittee and shall be retained as provided by subsection (b) of this section.

(e)

All game animals or game birds that die as a result or in the course of activities conducted under a permit issued under authority of this subchapter shall be kept in an edible condition until disposed of by one of the following methods:

(1)

documented donation to charitable organizations, public hospitals, orphanages, or indigent persons;

(2)

documented transfer or donation to other persons authorized to receive such specimens under a license or permit issued by the department; or

(3)

special disposition as prescribed in writing by the department.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007371

Gene McCarty

Chief of Staff

Texas Parks and Wildlife Department

Effective date: November 7, 2000

Proposal publication date: July 28, 2000

For further information, please call: (512) 389-4775


Part 10. TEXAS WATER DEVELOPMENT BOARD

Chapter 355. RESEARCH AND PLANNING FUND

Subchapter B. ECONOMICALLY DISTRESSED AREAS FACILITY ENGINEERING

31 TAC §355.72, §355.77

Texas Water Development Board (board) adopts amendments to 31 TAC §355.72 and new §355.77, Research and Planning Fund, concerning criteria for eligibility of facility planning projects for financial assistance and procurement of facility engineering services for projects funded through the Economically Distressed Areas Program (EDAP). Section 355.72 is adopted without change to the proposed text as published in the September 1, 2000 issue of the Texas Register (25 TexReg 8599) and will not be republished. New §355.77 is adopted with change to correct a typographical error in §355.77(C)(4)(a). The word "a" should be "at" in reference to "at least three persons."

The amendments to §355.72 are adopted in anticipation of a limited amount of funding for facility engineering becoming available as a result of cost savings on some projects, the termination of non-performing contracts, and the lapse of commitments. They are intended to clarify criteria that must be met and documentation which must be submitted before the board may consider an application for financial assistance for facility planning projects under the EDAP. The new §355.77 will provide guidance for applicants procuring facility engineering services for EDAP projects.

In 1999, the legislature added requirements to §15.407 of the Water Code for the board to adopt rules governing the procurement process for facility engineering services and for the executive administrator to review and approve the selection process used by an EDAP applicant to procure such services. The amendments are intended to address problem areas that have been identified in processing applications for EDAP assistance.

The amendments to §355.72 make it clear that certain fiscal information, including recent audits, rates and charges, and capital improvement plans, must be submitted, reviewed and evaluated by staff before the board will consider an application for facility engineering financial assistance under EDAP. The requirement for an executed contract for facility engineering services is reflective of the statutory amendments and recognizes the importance of these services to the quality of facility planning projects. Current rules require that an applicant must hold a Certificate of Convenience and Necessity (CCN) or have an application on file with TNRCC to obtain one for service to the proposed project area. The amendment to §355.72 would require that applicant to obtain any necessary CCN before consideration of an application by the board; however, an alternative is included that would allow the applicant to submit an executed interlocal agreement with the holder of the applicable CCN as evidence of the applicant's authority to provide services to the project area.

New §355.77 is intended to fulfill the legislative directive in SB 1421 for the board to adopt rules concerning the procurement of facility engineering services by recipients of EDAP funding. The new provisions are supplemental to the basic provisions of the Professional Services Procurement Act (Chapter 2254, TEX. GOV. CODE) and make it clear that the service provider must be selected pursuant to written procedures that assure that the selection process is open to all qualified providers and that each step of the selection process is documented. Also provided are basic requirements of: (i) an acceptable statement of qualifications (SOQ); (ii) recommended procedures for solicitation of SOQs, including publication and response schedules and minimum contents of a Request for Qualifications; (iii) criteria for evaluation of SOQs based on factors indicative of qualifications and experience; (iv) procedures for review of SOQs, including suggested makeup of an evaluation committee, a ranking process, and an interview procedure; and (v) contract negotiation process. The suggested procurement guidelines are formulated to ensure that the selection of a provider of facility engineering services has documentation which the Executive Administrator can review to verify that a qualified provider has been selected who can deliver needed engineering services at a reasonable cost within the constraints of the particular project.

The requirement for an applicant to submit an executed contract for facility engineering services that have been procured in compliance with state law and the procedural requirements set out in the new §355.77 with the application may be of particular significance. This and the other information to be required by the proposed amendment will allow staff to make a preliminary evaluation of the state of the applicant's fiscal affairs and of its potential capacity to manage and complete the proposed project. These amendments may also alleviate the need for conditional commitments, which can tie up funds that may never be accessed because the applicant cannot provide basic information necessary to evaluate an application, such as the recent audits.

No comments were received on the proposed amendments and new section.

The amendments and new section are adopted under the authority of the Texas Water Code, §6.101.

§355.77.Procurement of Facility Planning Services.

(a)

Professional engineering services necessary for preparing a facility plan for economically distressed areas shall be procured according to the Texas Government Code, Chapter 2254 (Professional Services Procurement Act), other applicable state and local laws, and the requirements of this section. The objective of this section is to establish basic parameters from which it can be determined that applicants receiving facility planning funds obtain the necessary professional engineering services through a process that is open to all interested qualified providers. Written procedures and documentation are recommended in order to insure receipt of services of qualified professionals at a responsible cost within the reasonable constraints of location and time for performance.

(b)

Applicants shall procure the services of a consultant to perform the facility planning services pursuant to written procedures adopted by the applicant. The applicant shall maintain documentation of compliance with each step. The procedures and documentation submitted in the selection of the consultant will generally comply with the following requirements:

(1)

contents of an acceptable statement of qualifications ( SOQ);

(2)

criteria for evaluating SOQs;

(3)

solicitation of SOQs;

(4)

review of SOQs according to criteria; and

(5)

negotiation of a consulting services contract.

(c)

The procedures and documentation establishing the applicant's compliance with the procedures shall be reviewed and approved by the executive administrator prior to consideration by the board of an application for financial assistance for such services; provided however, the executive administrator may approve variations from the requirements of this subsection based on a written finding that the applicant has substantially met the objectives of this section. The executive administrator shall review the procedures and documentation to ascertain compliance with these requirements.

(1)

The applicant shall establish the contents of the statement of qualifications, or SOQ, for persons seeking to provide the facility planning services which will be reviewed by the applicant. The SOQ shall include at a minimum:

(A)

the key personnel (including subconsultants or subcontracted personnel) who will be performing tasks within the scope of services identifying such personnel by name, professional license or registration number, areas of expertise, years of experience in that area, and the elements of the scope of services for which each such personnel will be responsible and describe specific project experience that would demonstrate expertise for that element;

(B)

references establishing experience with government projects, facility planning phase engineering, demographic research, and residential surveys identified by specific project identification, location, project reference contact person and telephone number, and dates of engagement and completion of assignment;

(C)

insurance coverage held by the respondent relative to the project identifying the carrier by name, address, telephone number, and type and extent of coverage;

(D)

a signed and notarized statement that the respondent has no interest in the project that would conflict with the performance of the responsibilities of an engineer; and

(E)

a list of any litigation, arbitration, administrative action related to past or current project performance, or the subject of any professional censure or licensure suspension involving any identified key personnel, and if so, a brief description of each and including a brief explanation if the respondent has ever been terminated from an assignment for nonperformance or unsatisfactory work.

(2)

Criteria for evaluating the SOQ will include:

(A)

educational and experiential background of key consultant personnel who will perform work on the project;

(B)

record of success by the consultant and its key personnel, demonstrated by similar work previously performed;

(C)

adequacy of staff and equipment to perform the work within the time needed;

(D)

demonstrated ability of consultant to work effectively with other parties and public agencies related to the project;

(E)

demonstrated continuing interest by the consultant in the success, efficiency, and effective performance of facilities and plans on which the consultant has previously worked;

(F)

record of timely completion of previous projects; and

(G)

demonstrated capacity to carry out the kind and extent of work required.

(3)

The applicant shall insure a sufficient number of qualified respondents by publicizing a request for qualifications, or RFQ, once at least 21 days and once at least seven days before selection of a consultant, in a local newspaper within the geographical area in which the work will be performed and in a newspaper of the nearest major municipality. The RFQ shall contain at a minimum:

(A)

a general description of the project planning area and the facility planning services sought specifically including a reference to the work required pursuant to §355.73 of this title;

(B)

a statement that documentation of the minimum requirements for consideration which are to be submitted in the SOQ shall be available upon request;

(C)

a statement that criteria for evaluating the qualifications is available from the applicant;

(D)

a deadline by which respondents must submit SOQs to the requesting applicant; and

(E)

the requesting applicant's contact person.

(4)

The applicant shall select the most qualified respondent by order of highest qualification based on the published criteria.

(A)

Evaluation of the SOQs shall be performed by at least three persons: at least one resident within the applicant's customer base who will be affected by the proposed project, at least one with a technical expertise in the field for which the services are sought, and at least one from the management of the applicant. Each member of the ranking team will independently rank each SOQ based on the published criteria. The scores assigned to each SOQ will be accumulated to achieve a single ranking for each SOQ.

(B)

Based on the rankings, the applicant shall identify the three consultants with the highest rankings, or short list.

(C)

Upon completion of ranking and preparation of the short list, if the applicant deems it necessary to interview firms in order to determine the most qualified respondent, the applicant shall issue an invitation to appear for an interview to each respondent on the approved short list.

(D)

Upon the issuance of invitations to appear, the applicant shall form an interview panel to interview each respondent on the short list for the purpose of ascertaining qualifications of each interviewee and ultimately selecting the most qualified respondent. At the conclusion of the interviews or upon completion of the short list if interviews are deemed unnecessary by the applicant, the applicant shall identify the most qualified respondent, the second most qualified, and the third most qualified.

(5)

In order to complete the procurement process, the applicant shall negotiate the terms of a consulting services contract, including a task budget, with the consultant receiving the highest ranking. The contract shall be acceptable in form and substance to the executive administrator. In the event that the applicant cannot conclude an acceptable contract with the highest ranked consultant, the applicant shall negotiate the terms of a consulting services contract, including a task budget, with the consultant receiving the second highest ranking. In the event that the applicant cannot conclude an acceptable contract with the second highest ranked consultant, the applicant shall negotiate the terms of a consulting services contract, including a task budget, with the consultant receiving the third highest ranking. If the applicant cannot conclude an acceptable contract with the third highest ranked consultant, the applicant shall be required to commence the process over from the start.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007325

Suzanne Schwartz

General Counsel

Texas Water Development Board

Effective date: November 7, 2000

Proposal publication date: September 1, 2000

For further information, please call: (512) 463-7981


Chapter 375. CLEAN WATER STATE REVOLVING FUND

The Texas Water Development Board (the board) adopts amendments to 31 TAC §§375.2, 375.15, 375.17, and 375.221 concerning the funding program for the Clean Water State Revolving Fund (CWSRF) without changes to the proposed text as published in the September 1, 2000, issue of the Texas Register (25 TexReg 8602) and will not be republished. The amendments are adopted to update the rules, expand the scope of definitions, and clarify administrative procedures.

Section 375.2, relating to Definitions of Terms, is amended to add nonpoint source or estuary management to the types of projects eligible for funding. Previously, the board has focused on those activities that met the Clean Water Act (Act), section 212 definition of "treatment works". The board now intends to broaden that focus to address the funding of all nonpoint source and estuary management activities, as authorized in sections 601, 319 and 320 of the Act. Therefore, the broader meaning of "project" is adopted to include sections 319 and 320 projects, and the broader term "project" is substituted for the term "treatment works" throughout the definition section.

The section is further amended to expand the definition of "building" to include the implementation of a project. The current definition fits the erection, acquisition, alteration, remodeling, improvement or extension of a treatment works facility, but the additional word "implementation" is a better description of activities funded as nonpoint source or estuary management projects. Additionally, the definition of "construction" is adopted for amendment to eliminate the redundant listing of activities already included in the definition of "building". Finally, the definition of "estuary management project" is amended to allow funding of the development of an estuary management plan, as authorized in section 601 of the Act.

Section 375.15, relating to Criteria and Methods for Distribution of Funds, is amended for consistency, to include the two new types of projects (nonpoint source or estuary management) into the eight categories of funding. The section is also amended to extend a commitment deadline in limited circumstances where an applicant has timely submitted an application, as defined in the chapter rules, but additional information is deemed to be necessary for consideration of a proposed project. The change will allow the Executive Administrator to request additional information from an applicant without causing the applicant to lose its place on the funding list.

Section 375.17, relating to Intended Use Plan, is amended to describe acceptable changes that may be made to a project after it has been listed on an adopted Intended Use Plan. These changes include the applicant, itself; the number of participants in a consolidated project; and the solution to an identified water supply problem. The amendments allow the board to focus on providing funding for solutions to the water supply needs of a particular area, rather than focusing on a particular applicant or project.

Section 375.221, relating to Pre-Design Funding Option, is amended to delete the requirement that loans made under this option must be closed within six months of the board commitment. The purpose of the six-month time limitation was to encourage timely closing so as to move the federal dollars into immediate projects. Experience has shown that six months is too short a time and that many of the commitments must return to the board for time extensions. The remainder of the subsections are renumbered accordingly.

There were no comments received on the proposed amendments.

Subchapter A. GENERAL PROVISIONS

1. INTRODUCTORY PROVISIONS

31 TAC §375.2

The amendments are adopted under the authority of the Texas Water Code §6.101 and §15.605 which provide the Texas Water Development Board with the authority to adopt rules necessary to carry out the powers and duties in the Water Code and other laws of the State including specifically the SRF program.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007322

Suzanne Schwartz

General Counsel

Texas Water Development Board

Effective date: November 7, 2000

Proposal publication date: September 1, 2000

For further information, please call: (512) 463-7981


2. PROGRAM REQUIREMENTS

31 TAC §375.15, §375.17

The amendments are adopted under the authority of the Texas Water Code §6.101 and §15.605 which provide the Texas Water Development Board with the authority to adopt rules necessary to carry out the powers and duties in the Water Code and other laws of the State including specifically the SRF program.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007323

Suzanne Schwartz

General Counsel

Texas Water Development Board

Effective date: November 7, 2000

Proposal publication date: September 1, 2000

For further information, please call: (512) 463-7981


Subchapter B. PROVISIONS PERTAINING TO USE OF CAPITALIZATION GRANT FUNDS

3. PREREQUISITES TO RELEASE OF FUNDS

31 TAC §375.221

The amendments are adopted under the authority of the Texas Water Code §6.101 and §15.605 which provide the Texas Water Development Board with the authority to adopt rules necessary to carry out the powers and duties in the Water Code and other laws of the State including specifically the SRF program.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007324

Suzanne Schwartz

General Counsel

Texas Water Development Board

Effective date: November 7, 2000

Proposal publication date: September 1, 2000

For further information, please call: (512) 463-7981


Part 20. EDWARDS AQUIFER AUTHORITY

Chapter 701. GENERAL PROVISIONS

31 TAC §§701.1, 701.3, 701.5

I. INTRODUCTION.

The Edwards Aquifer Authority ("Authority") adopts new 31 TAC §§701.1, 701.3, and 701.5, consisting of general provisions relating to the Authority's rules, without changes to the proposed text as published in the August 11, 2000 issue of the Texas Register (25 TexReg 7493). The sections will not be republished.

These rules have been written to provide general information regarding the purpose and construction of all rules adopted by the Authority, as well as to provide the business office and mailing address of the Authority.

II. SUMMARY OF THE FACTUAL BASIS FOR THE ADOPTED RULES; AND CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The Authority is required by the Edwards Aquifer Authority Act (Act of May 30, 1993, 73rd Legislature, Regular Session, Chapter 626, 1993 Texas General Laws 2350, 2358-59, as amended by Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 261, 1995 Texas General Laws 2505, Act of May 16, 1995, 74th Legislature, Regular Session, Chapter 524, 1995 Texas General Laws 3280, and Act of May 6, 1999, 76th Legislature, Regular Session, Chapter 163, 1999 Texas General Laws 634) ("Act"), to implement Edwards Aquifer management programs relating to, among other things, fees, exempt wells, interim authorization, permitted wells, permit conditions, groundwater available for permitting, proportional adjustment, equal percentage reduction, abandonment and cancellation of permits, aquifer recharge, storage and recovery, additional groundwater supplies available for permitting, transfers, meters and alternative measuring methods, groundwater trust, water quality, and comprehensive water management plan implementation.

A primary manner in which these various groundwater management programs will be implemented by the Authority will be through the adoption of rules for each program. Rulemaking has become essential for the operation of agencies charged by the legislative branch with programmatic implementation responsibilities. Thus while the Authority's activities are derived from express and implied powers set forth in the Act, the implementation of these powers is accomplished largely through rulemaking. In order to ensure uniform and consistent application of rules adopted by the Authority, it is essential that basic parameters be established. This is accomplished by the adoption of §§701.1, 701.3, and 701.5.

Section 701.1 states the general purpose of the Authority's rules. This section provides that the purpose of the Authority's rules is to implement the Act and other laws applicable to the Authority and to set forth the administrative procedures to be followed in Authority proceedings.

Section 701.3 relates to the construction of the Authority's rules. This section provides that unless otherwise expressly provided, the past, present, and future tense shall each include the other; the masculine, feminine and neutral gender shall each include the other; and the singular and plural number shall each include the other.

Section 701.5 states the business office and mailing address of the Authority.

III. REGULATORY IMPACT ANALYSIS OF MAJOR ENVIRONMENTAL RULES.

Section 2001.0225 of the Texas Government Code requires an agency to perform, under certain circumstances, a regulatory analysis of "major environmental rules." The Authority has determined that none of the rules are "major environmental rules" as that term is defined by §2001.0225(g)(3) of the Texas Government Code. The basis for this determination is that the rules do not have the specific intent to "protect the environment" or "reduce risks to human health from environmental exposure." The rules set forth general provisions that will apply to all the rules issued by the Authority. They are informational in nature and have been written to provide basic parameters for all the rules of the Authority. The specific intent of these rules is to provide a basic understanding of the purpose and construction of the rules of the Authority. For this reason, the Authority finds that none of the rules are "major environmental rules" and that, therefore, no further analysis is required by §2001.0225 of the Texas Government Code.

IV. TEXAS PRIVATE REAL PROPERTY RIGHTS PRESERVATION ACT.

Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act," ("TPRPRA") requires governmental entities, under certain circumstances, to prepare a takings impact assessment ("TIA") in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the adoption of these rules. First, the Authority has made a "categorical determination" that rules that provide general information only do not affect private real property. These rules provide general information only. They simply state the purpose of the rules of the Authority, some general rules regarding construction of Authority rules, and provide the business office and mailing address of the Authority. They have no direct affect on private real property and may not result in a taking. Second, the Authority's action in adopting these rules is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from TPRPRA under §2007.003(b)(4) of the Texas Government Code. See Act §§1.08(a), 1.11(a), 1.11(h); TEXAS GOVERNMENT CODE ANNOTATED, §2001.004(1) (Vernon 2000). It was held, in Edwards Aquifer Authority v. Bragg, 21 S.W.3d. 375 (Tex. App.--San Antonio 2000, pet. filed), that the Act expressly mandates the adoption of substantive and procedural rules and that such actions are therefore excepted from the TPRPRA. The holding in that case controls here. Third, it is the position of the Authority that all valid actions of the Authority are excluded from the TPRPRA under §2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the adoption of these rules.

V. SUMMARY OF PUBLIC COMMENTS.

Five public hearings were held on this and other rules proposed by the Authority on: Wednesday, August 9, 2000 at 6:00 p.m. at the Conference Center of the Edwards Aquifer Authority, 1615 N. St. Mary's Street, San Antonio, Texas; Tuesday, August 15, 2000 at 6:00 p.m. at the New Braunfels Civic Center, 380 S. Seguin Avenue, New Braunfels, Texas; August 17, 2000 at 6:00 p.m. at St. Paul's Lutheran Church, 1303 Avenue M, Hondo, Texas; Tuesday, August 22, 2000 at 6:00 p.m. at the Sgt. Willie De Leon Civic Center, 300 E. Main Street in Uvalde, Texas; and Thursday August 24, 2000 at the San Marcos Activities Center, 501 E. Hopkins, San Marcos, Texas. At those hearings, no public comments were received on proposed §§701.1, 701.3, or 701.5. Further, no written comments were submitted to the Authority on proposed §§701.1, 701.3, or 701.5.

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The new sections are adopted pursuant to §§1.08(a), 1.11(a) and (h) of Act; and TEXAS GOVERNMENT CODE, §§2001.004(1) (Vernon 2000) of the Administrative Procedure Act ("APA"). The Authority interprets these sections as requiring the Authority to adopt rules providing a basic understanding of the purpose and construction of all the rules adopted by the Authority, as well as to provide the public with the Authority's business office and mailing address to promote effective communication between the regulated community and the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer. The Authority interprets this provision as authorizing the establishment of general provisions applicable to all rules adopted by the Authority.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rules governing procedures of the board and the authority." This section directs the Board to adopt rules as necessary to implement the various substantive programs set forth in the Act related to the Edwards Aquifer, including, in particular, administrative procedures to be used before the Board and the Authority. The Authority interprets this section as requiring the adoption of general provisions applicable to all rules adopted by the Authority.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. Pursuant to this section, the Authority is required to comply with the APA in connection with its rulemaking, even though the Authority is not a state agency and would therefore otherwise not generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." The Authority interprets establishing general provisions applicable to all rules adopted by the Authority as falling within this requirement.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007340

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Chapter 702. GENERAL DEFINITIONS

31 TAC §702.1

I. INTRODUCTION.

The Edwards Aquifer Authority ("Authority") adopts new 31 TAC, §702.1, relating to definitions generally applicable to the rules of the Authority, with changes to the proposed text as published in the August 11, 2000, issue of the Texas Register (25 TexReg 7495-7500).

The Authority adopts the rule for the purpose of satisfying its statutory obligation to adopt rules necessary to carry out the Authority's power and duties under the Edwards Aquifer Authority Act. See Act of May 30, 1993, 73rd Legislature, Regular Session, Chapter 626, 1993 Texas General Laws 2350, 2358-59, as amended by Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 261, 1995 Texas General Laws 2505, Act of May 16, 1995, 74th Legislature, Regular Session, Chapter 524, 1995 Texas General Laws 3280, and Act of May 6, 1999, 76th Legislature, Regular Session, Chapter 163, 1999 Texas General Laws 634 ("Act").

II. SUMMARY OF THE FACTUAL BASIS FOR THE ADOPTED RULES.

The Authority is required by the Act to implement Edwards Aquifer management programs relating to, among other things, fees, exempt wells, interim authorization, permitted wells, permit conditions, groundwater available for permitting, proportional adjustment, equal percentage reduction, abandonment and cancellation of permits, aquifer recharge, storage and recovery, additional groundwater supplies available for permitting, transfers, meters and alternative measuring methods, groundwater trust, water quality, and comprehensive water management plan implementation. Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rules governing procedures of the board and the authority." This section directs the Board to adopt rules as necessary to implement the various substantive programs set forth in the Act related to the Edwards Aquifer. This duty to adopt rules necessarily includes rules related to the definitions that apply for any of the Authority programs. This duty under §1.11(a) to adopt procedural and substantive rules for its programs is incorporated into the discussion below of each definition.

A primary manner in which these various groundwater management programs will be implemented by the Authority is through the adoption of rules for each program. Rulemaking has become essential for the operation of agencies charged by the legislative branch with programmatic implementation responsibilities. Thus while the Authority's activities are derived from express and implied powers set forth in the Act, the implementation of these powers is accomplished largely through rulemaking.

In addition to the practicality of program implementation through rulemaking, there are legal requirements set forth in the Act that governs the program development of the Authority. These legal requirements are pre-existing legal "facts" that bind the Authority because it is a creature of the Act. In addition, there may be other facts that operate to provide contours as to the development of the general definitions that the Authority may choose to adopt. Both types of facts, legal and otherwise, may exist to provide a factual basis for the rule as adopted. The factual basis for the general definitions in §702.1 and the rational connection between the factual basis for the rule and the rule as adopted is discussed below.

The factual basis for the definitions of aquifer, augmentation, authority, beneficial use, board, commission, conservation, diversion, domestic or livestock use, industrial use, irrigation use, livestock, municipal use, order, person, pollution, recharge, reuse, water supply facility, well, well J-17, well J-27, and withdrawal are grounded in legal facts. All of these terms are already defined in §1.03 or §1.11(f) of the Act. These definitions in this final rule are taken directly from, and conform with these sections of the Act. There is a rational connection between the legal factual basis of the pre-existence of these definitions in §1.03 and §1.11(f) of the Act and the final rule as adopted because the rule merely incorporates the statutory definitions into the regulatory definitions in §702.1.

The factual basis for the definitions of "groundwater" and "underground water" are grounded in legal facts. In §1.03(20), the term "underground water" is assigned the meaning that this term has in §52.001,TEXAS WATER CODE. Since the passage of the Act, chapter 52, TEXAS WATER CODE, has been repealed and recodified as chapter 36, TEXAS WATER CODE. See Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 933, sec. 2, 6, 1995 Texas General Laws 4673. In so doing, the legislature abandoned the use of the term "underground water" in favor of the more modern term "groundwater" found at §36.001(5), TEXAS WATER CODE, and is defined as "water percolating below the surface of the earth." Under §1.08(a) of the Act, chapter 36, TEXAS WATER CODE (which replaced chapter 52) is now applicable to the Authority to the extent that it does not conflict with the Act. The Act provides no other guidance relative to the definition of groundwater or underground water. Accordingly, the Authority can identify no conflict within the Act that would prevent adopting the statutory definition of groundwater found in chapter 36, TEXAS WATER CODE. Thus, in correlating and updating the definition of underground water in the Act, which is cross-referenced to a part of the TEXAS WATER CODE that was subsequently repealed and recodified, a rational connection is established between the legal factual basis and the final rule as adopted.

The factual basis for the definition for "general manager" is that §1.11(d)(5) of the Act provides that the Board may hire an "executive director" to manage the Authority. Groundwater conservation districts normally call their chief executive officer a "general manager." Likewise, the Authority would prefer to call its chief executive officer a general manager. The functions and duties of the general manager would be no different than those envisioned, by the Act, to be performed by the executive director. The actual title that the Authority may adopt for its chief executive officer does not confer particular substantive duties or obligations separate and distinct from any other title that may be adopted. Thus, there is a rational connection between the legal factual basis for the hiring of an executive director in §1.11(d)(5) of the Act and the conventions of groundwater conservation districts and the adoption of a definition for "general manager."

The factual basis for the definition of "Act" is that the Act does not include a section setting out the official name for the Act. The Texas Supreme Court has referred to the Act as the "Edwards Aquifer Act." See Barshop v. Medina County Under. Wat. Cons. Dist. , 925 S.W. 2d 618, 623 (Texas 1996); see also Edwards Aquifer Authority v. Bragg, 21 S.W. 3d 375, 377 (Texas App. - San Antonio 2000 pet. filed). In the rules of the Authority, and in other documents in which it is appropriate to cite to sections of the Act leading to authority for a proposition, it will be necessary to specifically cite to the Act. In light of the Act's creation of an official name for the Act, it is useful to adopt the short-form definition, namely "Act", to mean the "Edwards Aquifer Authority Act." In so doing, the need to continually refer to a form of the name that is long and cumbersome will be eliminated and clarify that the Edwards Aquifer Act also creates the Edwards Aquifer Authority. This substitution provides a rational connection between the facts and the definition of "Act" because the definition accurately provides a short form for "Edwards Aquifer Authority Act" and the definition specifically references the longer-form of the name of the Act that has been cited by appellate courts in the state, numerous legal pleadings, and other documents citing to the Act.

The factual basis for the definition of "APA" is grounded in legal facts. Section 1.ll(h) of the Act provides that the Authority is, among other things, "subject to . . . the Administrative Procedure and Texas Register Act, (Article 6252-13a, Vernon's Texas Civil Statutes)." This article was generally referred to as "TAPTRA." Since the passage the Act, TAPTRA, has been repealed and recodified as chapter 2001, TEXAS GOVERNMENT CODE . See Act of May 22, 1993, 73rd Legislature, Regular Session, Chapter 268, § 1, 1993 Texas General Laws 583. The official title of chapter 2001 is the "Administrative Procedures Act." TEXAS GOVERNMENT CODE ANNOTATED, §2001.002 (Vernon 2000). The Administrative Procedures Act is uniformly referred to as the "APA." It is not likely that the legislature intended for the Authority to continue to be "subject to" a law that has been repealed. Instead, the more reasonable interpretation is that the Authority is subject to TAPTRA as it may be amended, repealed, or, in this case, recodified. Thus, in correlating and updating the outdated reference to TAPTRA with the APA, in the definitions in §702.1, a rational connection is established between the legal factual basis and the final rule as adopted.

The factual basis for the definitions of "applicant" and "application" are derived initially from the legal facts derived from the Act. Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first obtaining a permit issued by the Authority (subject to exceptions not relevant to this discussion). Section 1.15(c) envisions the Authority's issuance of regular, term, and emergency permits for the withdrawal of groundwater from the aquifer. Section 1.16(a) envisions that an existing user may "apply" for an initial regular permit. The permitting process, possibly culminating in the issuance of a permit (or other approval) by an administrative agency, is normally commenced by the filing of an "application." An application essentially requests that the Authority issue a permit authorizing an activity sought to be conducted. The application must demonstrate facts justifying the issuance of the permit. The person or entity filing an application is generally referred to as an "applicant." The term "applicant" appears in §1.16(b) the Act. The term "application" is mentioned in §§1.16(b), 1.17(d)(1), 1.18(b) and 1.29(f) of the Act. The concepts of "applicant" and "application" are often considered part of the terminology used by an agency in its procedural rules related to its permit program. The Act does not provide definitions for the terms "applicant" and "applications." Because these terms are likely to be regularly used by the Authority in referring to its rules, the general facilitation of its procedures, in relation to its permit program, and by the regulated community interacting with the Authority as applicants, as well, the Authority has determined that definitions of these terms is useful. There is a rational connection between this factual basis and the definitions of "applicant" and "application" in §702.1 because these definitions refer to an "applicant" as one who filed an application, and an "application" as the document that is required to be filed with the Authority in order to commence the processes of obtaining a permit or other approval.

The Authority requires physical facilities for the purpose of conducting its activities. Persons or entities interested in the affairs of the Authority will need to know the location of the Authority in order properly transact business with the Authority. Thus, it is necessary for the Authority to identify to the public where the official Authority offices are and, when the Authority refers to "its offices", where it is referring to. The Act does not provide a definition for the term "Authority offices." Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to the Authority's programs, as well as by the regulated community that will interact with the Authority, the Authority has determined that it is useful to define this term. There is a rational connection between this factual basis and the definition of "Authority offices" in §702.1 because this definition cross-references the rule in §701.5 of this title (relating to Business Office and Mailing Address of the Authority) which provides the physical as well as the mailing address of the Authority.

The factual basis for the definitions of "declarant," "declaration of historical use" (or "declaration") is derived initially from the legal facts contained in the Act. Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first having obtained a permit issued by the Authority (subject to exceptions not relevant to this discussion). Section 1.15(c) envisions that the Authority may issue regular, term and emergency permits for the withdrawal of groundwater from the aquifer. Section 1.16(a) envisions that an existing user may "apply" for an initial regular permit by filing a "declaration of historical use." Under §1.16(a), a declaration is essentially an application for an initial regular permit requesting that the Authority issue an initial regular permit for the withdrawal of groundwater from the aquifer, and the facts during the historical period justifying the issuance of the permit. A person or entity filing a declaration is generally referred to as a "declarant." The term "declarant" does not appear in the Act. The term "declaration of historical use" (and therefore "declaration") is mentioned in §§1.16(a), (b), (c), (d)(1), §1.17(a)(2), (b), and (d)(2) of the Act. The concepts of "declarants" and "declarations of historical use" (or "declarations") are often considered to be part of the terminology used by water resource management agencies in water rights proceedings similar to a water rights adjudication and in the procedural rules related to such a proceeding. The Act does not provide definitions for the terms "declarant", "declaration of historical use" (or "declaration"). Because these terms are likely regularly used by the Authority in its rules, and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that interacts with the Authority as a declarant(s), the Authority has determined that it is useful to define these terms. There is a rational connection between this factual basis and the definitions of "declarant" and "declaration of historical use" (or "declaration") in §702.1 because these definitions refer to a "declarant" as an existing user who filed a declaration, and a "declaration of historical use" (or "declaration") as the document that is required to be filed with the Authority in order to apply for an initial regular permit under §1.16(a) of the Act.

The factual basis for the definitions of "permit" and "permittee" are derived initially from the legal facts derived from the Act. Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first having obtained a permit issued by the Authority (subject to exceptions not relevant to this discussion). Section 1.15(c) envisions that the Authority may issue regular, term, and emergency permits for the withdrawal of groundwater from the aquifer. Section 1.16(a) envisions that an existing user may apply for an initial regular permit. The permitting process culminates in the granting (or denial) of an application. If an application is granted, then a "permit" is issued by the appropriate administrative agency. The permit essentially authorizes a regulated activity to proceed pursuant to conditions. The person or entity owning or holding a permit is generally referred to as a "permittee." The term "permittee" does not appear in the Act. The term "permit" is mentioned in §§1.11, 1.14, 1.15, 1.16, 1.17, 1.18, 1.19, 1.20, 1.21, 1.22, 1.23, 1.24, 1.26, 1.29, 1.30, 1.32, 1.34, 1.35, 1.36, 1.40, and 1.44. The term "permit" is primarily used in the context of a groundwater water permit, i.e. a permit that authorizes withdrawal of groundwater from the aquifer. The concepts of "permit" and "permittee" are often considered part of the terminology used by water resource management agencies in water rights proceedings, similar to water rights adjudication, and in procedural rules related to such proceedings. The Act does not provide definitions for the terms "permittee" or "permit." Because these terms are likely to be regularly used by the Authority, in its rules and in the general conducting of its procedures as they relate to its permit program, and by the regulated community that interacts with the Authority as a permittee, the Authority has determined that it is useful to define these terms. There is a rational connection between this factual basis and the definitions of "permittee" and "permit" in §702.1 because these definitions refer to a "permittee" as one to whom a permit has been issued, and a "permit" as the document issued by the Authority as a result of the granting of an application.

The factual basis for the definitions of "registrant" and "registration" is derived initially from the legal facts contained in the Act. Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first having obtained a permit issued by the Authority, for exempt wells and interim authorization withdrawals. Section 1.33(b) envisions that the owner of an exempt well will "register" the well with the Authority. A "registration" is essentially an application for the owner of a well to obtain exempt well status. The registration provides the request to the Authority to recognize the well's exempt status, and the facts supporting the recognition. No permit is issued to the owner of an exempt well. A person or entity filing a registration is generally referred to as a "registrant." The term "registrant" does not appear in the Act, The term "registration" appears in §1.29(g) of the Act. Also, the term "register" is mentioned in §1.33(b) of the Act. The concepts of "registrants" and "registrations" are often considered to be part of the terminology used by water resource management agencies in managing exempt wells and in the procedural rules related to such a proceeding. The Act does not provide definitions for the terms "registrant" or "registration." Because these terms are likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as a registrant, the Authority has determined that it is useful to define these terms. There is a rational connection between this factual basis and the definitions of "registrant" and "registration" in §702.1 because these definitions refer to a "registrant" as one who files a registration, and a "registration" as the document required to be filed with the Authority in order to qualify for exempt well status, or other registrations that may be required by other permit program rules of the Authority.

The Authority requires staff to manage its permitting and rulemaking files. Persons or entities interested in the affairs of the Authority will need to know the administrative point of contact for the filing of documents with the Authority in order to properly transact business with the Authority. Thus, it is necessary for the Authority to identify to the public the official to whom documents should be directed and filed relative to pending permitting or rulemaking matters. The Authority would like to designate that point of contact as its "docket clerk." The term "docket clerk" does not appear in the Act. Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its procedures, as they relate to the Authority's permitting and rulemaking, as well as by the regulated community that will interact with the Authority, the Authority has determined that it is useful to define this term. There is a rational connection between this factual basis and the definition of "docket clerk" in §702.1 because this definition identifies that the docket clerk is the person designated by the general manager as such.

The Board of Directors of the Authority and the Authority staff require legal counsel relative to the matters of the Authority. Persons or entities interested in the affairs of the Authority may require identification of the Authority's legal counsel in order to properly transact business with the Authority. Thus, it is necessary for the Authority to identify to the public the legal counsel relative to matters pending before the Authority. The Authority would like to designate the legal counsel to the Board, and the staff, as its "general counsel." The term "general counsel" does not appear in the Act. Because this term is likely to be used, on a regular basis, by the Authority in its rules, the general conducting of its procedures as they relate to the Authority's permitting and rulemaking, and by the regulated community that will interact with the Authority, the Authority has determined that it is useful to define this term. There is a rational connection between this factual basis and the definition of "general counsel" in §702.1 because this definition identifies the general counsel as the attorney engaged as such by the Board.

The factual basis for the definitions of "judge", "party", "petitioner", "pleadings", "protestant", and "SOAH " are derived initially from the fact that the Authority is "subject to" the APA due to the operation of §1.11(h) of the Act. Section 2001.004(1), TEXAS GOVERNMENT CODE, also provides that the Authority is required to adopt rules of practice stating the nature and requirement of all available formal and informal procedures. This would necessarily include definitions relevant to the rules of practice or procedural rules. The permitting procedures relative to certain permit applications may result in contested case hearings. Contested cases are governed by subchapter C of the APA. Contested case hearings are trial-type proceedings that resemble trials. Judges, parties, petitioners, pleadings, protestants, and SOAH are all persons, documents, or entities that are often part of the terminology used by administrative agencies that have matters before them that may result in a contested case hearing. The Act does not provide definitions for these terms. Because these terms are likely to be regularly used by the Authority in its rules and in the general conducting of its contested case proceedings as they relate to its permit program, as well as by the regulated community that will interact with the Authority as applicants, the Authority has determined that it is useful to define these terms. The term "judge" is derived from §2003.001(1), TEXAS GOVERNMENT CODE. The basis for the definition of "party" is §2001.003(4), TEXAS GOVERNMENT CODE. The basis for the definition of "pleadings" is 31 TAC § 155.5 (6). The basis for the definition of "SOAH" is §2003.001(1), TEXAS GOVERNMENT CODE. The definitions of "petitioners" and "protestants" are based on generally accepted notions and understandings of the terms. There is a rational connection between this factual basis and these definitions in §702.1 because they are derived from and closely track the statutory or regulatory definitions found in other provisions that are similar to and relevant to the conduct of the contested case hearings that may result from the Authority's permit application processing or are derived from generally accepted understandings of the terms.

Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first having obtained a permit issued by the Authority (subject to exceptions not relevant to this discussion). Section 1.14(d) of the Act provides the grounds for and the procedure by which the Authority may increase the quantity of groundwater available for permitting and modify the effect of §1.14(b) and (c) of the Act which creates maximum quantities of groundwater that may be permitted for certain periods of time. Among the groundwater strategies available to "raise the cap" is supplemental recharge. Also, §1.11(f) of the Act empowers the Authority to contract with a person who uses water from the aquifer to construct, operate, own, finance, and maintain water supply facilities. That section defines the term "water supply facility" as including, among other things, a recharge project. Section 1.44 of the Act provides the terms and conditions under which a political subdivision of the state may enter into an interlocal contract with the Authority for an aquifer recharge project. Section 1.45 of the Act authorizes the Authority to build or operate recharge dams and provides certain terms and conditions for the operation of such facilities as well as eligible source water for the recharge project. These sections of the Act, among others, create the legal facts that recognize the authority of the Authority over recharge projects associated with the aquifer. Recharge projects have three basic components: (1) recharge; (2) storage; and (3) recovery. Recharge to the aquifer results in increasing the supply of groundwater within the aquifer. The purpose of the recharge is to store the water in the aquifer for a period of time such that the recharged water may be recovered from a point of withdrawal at a later time when needed. In order to recharge to and store water in the aquifer, the Authority would be required to issue a permit for this purpose. The Authority proposes to call this permit an "aquifer recharge and storage permit." In order to withdraw the water that has already been recharged and stored in the aquifer the Authority would be required to issue a permit for this purpose. The Authority proposes to call this permit a "recharge recovery permit." The Act does not provide definitions for these terms. Because these terms are likely to be regularly used by the Authority in its rules and in the general conducting of permit program related to recharge project, as well as by the regulated community that will interact with the Authority as applicants for these projects, the Authority has determined that it is useful to define these terms. There is a rational connection between this factual basis and the definitions of "aquifer recharge and storage permit" and "recharge recovery permit" in §702.1 because these definitions identify the name of the permit that would authorize the recharge of the aquifer, and the withdrawal of the recharged water from the aquifer.

Section 1.16(a) of the Act authorizes only an "existing user" to file declarations of historical use (also known as applications for initial regular permit) for withdrawals of groundwater placed to beneficial use during the historical period (June 1, 1972 through May 31, 1993). In order to qualify as an existing user, the existing user would had to have owned a well from which withdrawals from the aquifer were made and placed to beneficial use during the historical period. See e.g. §§ 1.16(a); and 1.17(a) and (d)(2). This necessarily means that the well owned by the existing user would had to have been installed and made withdrawals no later than May 31, 1993. The Authority proposes to refer to these wells as "existing wells." Section 1.14(e) of the Act also provides for a prohibition on withdrawals of groundwater from the Edwards Aquifer ("Aquifer") from wells drilled after June 1, 1993. The purpose of preventing withdrawals from post-June 1, 1993 wells is to prevent an uncontrolled ever increasing demand on the aquifer at the expense of the historical users of the aquifer. See Barshop, 925 S. W. 2d at 632. The Authority proposes to refer to the post-June 1, 1993 wells as "new wells." The term "existing well" then functions in harmony with the term "existing user" that is defined in §1.03(10) of the Act. The term "new well" would function with the term "new user." Existing users are made eligible by the Act to receive an initial regular permit, while new users are not so eligible. Thus, existing wells are eligible for an initial regular permit, while new wells are not. The Act does not provide definitions for "existing well" or "new well." Because the Act creates the concept of "existing user," "historical use," and a date for the establishment of a prohibition against the withdrawal of groundwater from certain wells, it is necessary to give meaning and definition to "existing well" and "new well." These terms are also likely to be regularly used by the Authority in its rules and in the general conducting of its permit program, as well as by the regulated community that will interact with the Authority. There is a rational connection between this factual basis and the definitions of "existing well" and "new well" in §702.1 because the definition of "existing well" is linked to the concept of "existing user" and "historical period" and "new well" is linked to the concept of post-June 1, 1993 wells which are ineligible to receive an initial regular permit.

Section 1.14(f) of the Act authorizes the Authority to allow "uninterruptible" withdrawals from the Aquifer when certain index wells for the "San Antonio pool" and the "Uvalde pool" are at certain levels. Section 1.19(b) of the Act provides for the minimum index well level for the San Antonio Pool below which term permit withdrawals are automatically "interrupted." Section 1.19(c) of the Act provides for the minimum index well level for the Uvalde pool below which term permit withdrawals are automatically "interrupted." The Act does not provide definitions for the terms "San Antonio pool," "Uvalde pool," or "interruptible." Because these terms are likely to be regularly used by the Authority in its rules and in the implementation of the Authority's aquifer management programs, as well as by the regulated community that will interact with the Authority, the Authority has determined that it is useful to define these terms. The Act has identified that the Authority should manage the aquifer on a two-pool basis for certain purposes (although, the Act does allow for the Authority to create additional pools if warranted. See § 1.14(g)). The Authority interprets the current hydrogeologic data as indicating that within the aquifer, unique hydrological conditions exist in some areas relative to other areas. Examples of these hydrological conditions include varying aquifer transmissivities, storativity, flow paths and water quality conditions. Two areas within the aquifer that may be considered different pools include the "Uvalde pool" and the "San Antonio pool." Hydrographs from monitoring wells in these two areas indicate that aquifer conditions, such as groundwater flow paths and storativity, are such that different pools for these areas exist. Generally, there are not yet enough data points to accurately map the boundary location between the two pools. Moreover, the likelihood that such data will be developed within the time frames required for the Authority to begin implementation of its aquifer management programs, for example, permitting and critical period, as required by the Act, do not permit it to wait for the development of such data. The Authority notes that as the data improves it will be able to refine its definition of these pools accordingly. However, the Authority interprets the current relevant data to suggest that the boundary between the pools is generally near the Uvalde-Medina County line, with the "Uvalde pool" being confined to the part of the aquifer underlying Uvalde County, with the balance of the aquifer underlying the jurisdictional boundaries of the Authority as constituting the "San Antonio pool." As for the term "interruptible", sections 1.14(f) and 1.19 clearly indicate that this term is used to describe the cessation, curtailment, or reduction of a permittee's right to make withdrawals from the aquifer due to aquifer level conditions as measured as certain index wells. There is a rational connection between the factual basis discussed above and the definitions of "Uvalde pool" and "San Antonio pool" in §702.1 because these definitions refer to the "Uvalde pool" as the part of the aquifer under Uvalde County, and the "San Antonio pool" as the portion of the aquifer underlying the Authority's jurisdictional boundaries. There is a rational connection between the factual basis discussed above and the definition of "interruptible" because the definition refers to the conditioning of the right to make withdrawals under a permit based on index well levels.

Section 1.15(a) of the Act provides broad authority to the Authority to manage (1) withdrawals from the Aquifer, and (2) points of withdrawals pursuant to the Act. Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer, or the construction of a well, without first having obtained a permit issued by the Authority. These sections of the Act provide the legal facts that recognize the regulation of certain activity through the issuance of permits that the Authority proposes to call "groundwater withdrawal permits," "well construction permits," and "monitoring well permits." The Act does not provide definitions for these terms. Because these terms are likely to be regularly used by the Authority in its rules and in the general conducting of permit program, as well as by the regulated community that will interact with the Authority as applicants, the Authority has determined that it is useful to define these terms. There is a rational connection between this factual basis and these definitions in §702.1 because these definitions, respectively, provide that "groundwater withdrawal permits" authorize withdrawals of groundwater from the aquifer, "well construction permits" authorize the construction of a well designed for the purpose of making withdrawals from the aquifer, and "monitoring well permits" authorize the measuring of water level or water quality of the aquifer.

The factual basis for the definitions of "initial regular permit" and "historical use" is derived initially from the legal facts contained in the Act. Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first having obtained a permit issued by the Authority (subject to exceptions not relevant to this discussion). Section 1.15(c) envisions that the Authority may issue, among other things, regular permits for the withdrawal of groundwater from the aquifer. Section 1.16(a) envisions that an existing user may apply for an "initial regular permit" by filing a declaration of historical use. Under §1.16(a), a declaration is essentially an application for an initial regular permit for withdrawals made during the statutorily established historical period. This section provides that the "historical period" is from June 1, 1972 through May 31, 1993. Section 1.16(d) of the Act provides some of the elements that, if proven by convincing evidence, would require the Board to grant an application for an "initial regular permit." Section 1.17(a) of the Act authorizes persons owning wells meeting certain criteria to continue to make withdrawals from the well even though they have yet not been issued an "initial regular permit." These concepts of "initial regular permit" and "historical period" will be part of the terminology used by the Authority in the implementation of its permit program and in the procedural rules associated therewith. The Act does not provide definitions for these terms. Because these terms are likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as an applicant, the Authority has determined that it is useful to define these terms. There is a rational connection between this factual basis and the definition of "historical use" because the definition tracks the same dates used in §1.16(a) the Act. There is a rational connection between this factual basis and the definition of "initial regular permit" because the definition refers to this type of permit as a groundwater withdrawal permit authorized pursuant to §1.16 of the Act.

The factual basis for the definition of "additional regular permit" is derived initially from the legal facts contained in the Act. Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first having obtained a permit issued by the Authority (subject to exceptions not relevant to this discussion). Section 1.15(c) envisions that the Authority may issue, among other things, regular permits for the withdrawal of groundwater from the aquifer. Section 1.18(a) of the Act authorizes the Authority to issue "additional regular permits" if there remains water available for permitting after the issuance of all initial regular permits. The section also provides that groundwater withdrawals pursuant to "additional regular permits" are subject to maximum permitted groundwater withdrawal amounts set out in sections 1.14(b) and (c) of the Act. Section 1.18(b) of the Act prohibits the Authority from considering or taking action on an application for an "additional regular permit" until the Authority has taken final action on all pending applications for initial regular permits. This concept of an "additional regular permit" will be part of the terminology used by the Authority in the implementation of its permit program and in the procedural rules associated therewith. The Act does not provide a definition for this term. Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as an applicant, the Authority has determined that it is useful to define this term. There is a rational connection between this factual basis and the definition of "additional regular permit" because the definition refers to this type of permit as a groundwater withdrawal permit authorized pursuant to §1.18 of the Act.

The factual basis for the definition of "term permit" is derived initially from the legal facts contained in the Act. Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first having obtained a permit issued by the Authority (subject to exceptions not relevant to this discussion). Section 1.15(c) envisions that the Authority may issue, among other things, term permits for the withdrawal of groundwater from the aquifer. Section 1.19(a) of the Act authorizes the Authority to issue term permits for groundwater withdrawals from the Aquifer for up to 10 years. Section 1.19(b) of the Act provides for the minimum index well level for the San Antonio pool below which term permit withdrawals would be automatically interrupted. Section 1.19(c) of the Act provides for the minimum index well level for the Uvalde pool below which term permit withdrawals would be automatically interrupted. This concept of a "term permit" will be part of the terminology used by the Authority in the implementation of its permit program and in the procedural rules associated therewith. The Act does not provide a definition for this term. Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as an applicant, the Authority has determined that it is useful to define this term. There is a rational connection between this factual basis and the definition of "term permit" because the definition refers to this type of permit as a groundwater withdrawal permit authorized pursuant to §1.19 of the Act.

The factual basis for the definition of "emergency permit" is derived initially from the legal facts contained in the Act. Section 1.15(a) authorizes the Authority to "manage all withdrawal points from the aquifer." Section 1.15(b) generally prohibits the withdrawal of groundwater from the aquifer without first having obtained a permit issued by the Authority (subject to exceptions not relevant to this discussion). Section 1.15(c) envisions that the Authority may issue, among other things, emergency permits for the withdrawal of groundwater from the aquifer. Section 1.20(a) of the Act authorizes the Authority to issue emergency permits for groundwater withdrawals from the Aquifer not to exceed 30 days to prevent severe, imminent threats to the public health or safety. This concept of a "emergency permit" will be part of the terminology used by the Authority in the implementation of its permit program and in the procedural rules associated therewith. The Act does not provide a definition for this term. Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as an applicant, the Authority has determined that it is useful to define this term. There is a rational connection between this factual basis and the definition of "emergency permit" because the definition refers to this type of permit as a groundwater withdrawal permit authorized pursuant to §1.20 of the Act.

The factual basis for the definition of "aquifer management fee" is derived initially from the legal facts contained in the Act. Section 1.29(b) of the Act directs the Authority to assess an "aquifer management fee" on aquifer use to finance its administrative and programmatic expenses authorized under the Act. Section 1.29(e) of the Act provides that in developing its fees, the Authority may charge different fee rates on a per acre-foot basis for different types of uses as long as they are equitable between types of uses. This section also creates a fee differential between agricultural users and non-agricultural users for "aquifer management fees" whereby the agricultural fee may not exceed 20 percent of the aquifer management fees assessed against non-agricultural users. In addition, this section creates a distinction between agricultural and non-agricultural users when calculating aquifer use under §1.29(b) of the Act by providing that aquifer use for agricultural users is the actual volume of groundwater withdrawn, while for non-agricultural users it is the face value authorized to be withdrawn in an initial regular permit. This concept of an "aquifer management fee" will be part of the terminology used by the Authority in the implementation of its fee program and in the procedural rules associated therewith. The Act does not provide a definition for this term. Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its fee program, as well as by the regulated community that will interact with the Authority, the Authority has determined that it is useful to define this term. There is a rational connection between this factual basis and the definition of "aquifer management fee" because the definition refers to this type of fee as a fee based on aquifer use or taxes in lieu of user fees under certain circumstances as authorized pursuant to §1.29 of the Act.

The factual basis for the definition of "non-exempt well" is derived initially from the legal facts contained in the Act. Section 1.31(a) of the Act provides that owners of "non-exempt wells" are required to install meters on wells, or, if the meter requirement is waived, apply alternative measuring methods to calculate the volume of groundwater withdrawals from the Aquifer. This reference to a "non-exempt well" must necessarily mean that there is something in the Act contemplated to be an "exempt well." In addition, this raises the issue of from what are the wells "exempt." Section 1.33(a) and (c) essentially provides the definition for "exempt well." To qualify for exempt well status a well must (1) produce no more than 25,000 gallons water a day , (2) for domestic or livestock use, (3) not be located within a subdivision requiring platting, and (4) not serve a subdivision requiring platting. Section 1.33(a) provides that the "exemption" extends to the duty to install a meter. Section 1.33(b) of the Act provides that "exempt wells" must be registered with the Authority. Section 1.16(c) of the Act provides that owners of exempt wells are also not required to file declarations of historical use in order to continue to make lawful withdrawals from their exempt wells (i.e. they are exempt from the duty to file a declaration of historical use). Only wells that file a declaration of historical use are eligible for interim authorization status under §1.17(a)(2) of the Act. A review of §1.31 and §1.33 of the Act lead to the conclusion that the Act contemplates two types of wells within the jurisdiction of the Authority. First, some wells will require a groundwater withdrawal permit (e.g. initial regular permit, additional regular permit, term permit or emergency permit). These wells are referred to in §1.31 as "non-exempt wells." The second type of wells are "exempt wells." Pursuant to sections 1.15(b) and 1.16(c) these wells do not require a permit. The Authority interprets these sections as precluding the issuance of a groundwater withdrawal permit to owners of exempt wells. Instead, §1.33(b) merely requires the owners of exempt wells to register the wells. The Act does not provide for the waiver of exempt well status. These concepts of a "exempt well" and "non-exempt" will be part of the terminology used by the Authority in the implementation of its permit program and in the procedural rules associated therewith. The Act does not provide a definition for these terms. Because these terms are likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority, the Authority has determined that it is useful to define these terms. There is a rational connection between this factual basis and the definition of "exempt well" and "non-exempt well" because the definition of "exempt well" tracks the statutory criteria found in §1.33(a) and (c) of the Act. As for the definition of "non-exempt well" there is a rational connection between this factual basis and this definition because the definition requires that the legal basis for the withdrawals from non-exempt wells be interim authorization status or groundwater withdrawal permit.

The factual basis for the definition of "surface water" is derived initially from the legal facts contained in the Act. Section 1.08(b) of the Act provides that the Authority does not have the authority to regulate "surface water." The Act does not provide a definition for this term. The definition of the term is fundamental to identifying over what water resources the Authority has jurisdiction. Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its permit program, as well as by the regulated community that will interact with the Authority, the Authority has determined that it is useful to define this term. The Authority interprets the jurisdictional limitation in §1.08(b) to apply to surface water over which the prior appropriation doctrine applies and jurisdiction is vested in the Texas Natural Resource Conservation Commission. Surface water is generally considered to be "state water." The definition of "state water" is found in §11.021(a), TEXAS WATER CODE. There is a rational connection between this factual basis and the definition of "surface water" because the definition refers to the definition of state water as identifying the surface water over which the Authority would have no jurisdiction.

III. REGULATORY IMPACT ANALYSIS OF MAJOR ENVIRONMENTAL RULES.

Section 2001.0225 of the Texas Government Code requires an agency to perform, under certain circumstances, a regulatory analysis of "major environmental rules." The Authority has determined that this proposed rule in not a "major environmental rule" as that term defined by §2001.0225(g)(3) of the Texas Government Code. The basis for this determination is that the proposed rules do not have the specific intent to "protect the environment" or "reduce risks to human health from environmental exposure." The proposed rule would set forth general definitions that will apply to all the rules issued by the Authority. These rules have been written to provide uniform definitions for words and phrases that are expected to be used consistently throughout the Authority's other rules. Some of these definitions are identical to the definitions that appear in the Act while other definitions provide useful "short-hand" to reduce the amount of cumbersome regulatory language necessary in other Authority rules. The specific intent of these definitions is thus to allow for a more efficient understanding and operation of other rules of the Authority. For this reason, we find that the proposed rule is not a "major environmental rule" and that, therefore, no further analysis is required by §2001.0225 of the Texas Government Code.

IV. TEXAS PRIVATE REAL PROPERTY RIGHTS PRESERVATION ACT.

Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act," ("TPRPRA") requires governmental entities, under certain circumstances, to prepare a takings impact assessment ("TIA") in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the proposal of this rule. First, the Authority's action in adopting this rule is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from the TPRPRA under §2007.003(b)(4) of the Texas Government Code. See Act §§ 1.03, 1.08(a), 1.11(a), and 1.11(f); TEXAS WATER CODE ANN. § 36.001(5). It was held, in Edwards Aquifer Authority v. Bragg, 21 S.W.3d. 375,(Texas App. San Antonio 2000 pet. filed), that the Edwards Aquifer Act expressly mandates the adoption of substantive and procedural permitting rules and that such actions are therefore excepted from TPRPRA. Third, it is the position of the Authority that all valid actions of the Authority are excluded from the TPRPRA under §2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the proposal of this rule.

V. SUMMARY OF PUBLIC COMMENTS AND AUTHORITY RESPONSES.

Five public hearings were held on these and other rules proposed by the Authority on: Wednesday, August 9, 2000, at 6:00 p.m. at the Conference Center of the Edwards Aquifer Authority, 1615 N. St. Mary's Street, San Antonio, Texas; Tuesday, August 15, 2000 at 6:00 p.m. at the New Braunfels Civic Center, 380 S. Seguin Avenue, New Braunfels, Texas; August 17, 2000 at 6:00 p.m. at St. Paul's Lutheran Church, 1303 Avenue M, Hondo, Texas; Tuesday, August 22, 2000 at 6:00 p.m. at the Sgt. Willie De Leon Civic Center, 300 E. Main Street in Uvalde, Texas; and Thursday August 24, 2000 at the San Marcos Activities Center, 501 E. Hopkins, San Marcos, Texas. At those hearings, public comments were received on the proposed §702.1. In addition, written comments were received from members of the public regarding §702.1. The public comment period closed on September 11, 2000. Oral and/or written comments were provided by Earl & Brown, P.C. ("Earl & Brown"); Bickerstaff, Heath, Smiley, Pollan, Kever & McDaniel, L.L.P. on behalf of the Texas Farm Bureau ("TFB"); the Texas Nursery & Landscape Association ("TNLA"); William R. Haney ("Haney"); Color Spot Nurseries ("CSN"); Glenn, JoLynn and David Bragg (the "Braggs"); the Texas Cattle Feeders Association, Inc. ("TCFA"); and Vivian Windrow ("Windrow").

Public Comments No. 1, No. 2, and No. 3:

The TCFA seeks a revision of the definition of "agricultural use" in order to include the watering of livestock within the definition. Similarly, the TNLA and CSN seek a revision of the definition of "agricultural use" in order to include the watering of nursery products by a nursery grower. Section 702.1, however, does not include a definition for "agricultural use." Instead, that term is defined in the Authority's proposed Chapter 709 rules.

Authority's Response:

The Authority believes that the comments of the TCFA, the TNLA, and CSN on this point will be more appropriately addressed when Chapter 709 is adopted by the Authority. For this reason, the Authority disagrees with the comments to the extent they relate to §702.1, and the Authority has declined to modify §702.1 in response to the comments.

Public Comment No. 4:

The TFB's comments correctly point out that while the text of the preamble to the notice of proposed rulemaking for §702.1 (25 Texas Reg. 7495-96) erroneously suggests the Authority is proposing a definition of the "Medina Pool," §702.1 actually includes no such definition.

Authority's Response:

The Authority agrees with the comment. It is unclear whether the TFB would support or oppose the inclusion of such a definition. The Authority has determined not to include a definition of the "Medina Pool" in §702.1. Section 1.14(g) of the Act states: "The authority by rule may define other pools within the aquifer, in accordance with hydrogeologic research, and may establish index wells for any pool to monitor the level of the aquifer to aid the regulation of withdrawals from the pools." The Authority has decided not to include such a definition at this time. No amendment to §702.1 is necessary in response to this comment.

Public Comment No. 5:

Both Haney and Earl & Brown submitted comments on the definition of "exempt well" found at §702.1(b)(22). As proposed, that definition reads as follows:

Exempt well- A well that produces 25,000 gallons of water a day or less for domestic or livestock use that is not within or serving a subdivision requiring platting.

Haney asks that the definition state:

Exempt well- A well that produces 25,000 gallons of water a day or less for domestic or livestock use, or livestock watering, that is not within and serving a subdivision requiring platting. The withdrawal and beneficial use of less than 1250 gallons of water a day from an otherwise exempt well for purposes other than domestic or livestock use, or livestock watering, does not void a well's exempt status.

Haney reasons that these changes are merited because: (1) an otherwise exempt well owner, under proposed §702.1(b)(22), may inadvertently come to reside in a platted subdivision without incurring a change in water usage; and (2) a "de minimus" exception, defined by Haney to mean 1,250 gallons per day or less, ought to be created for otherwise exempt well owners who wish to pump relatively small amounts of water for non-exempt purposes from their exempt wells.

Authority's Response:

The Authority disagrees with the Haney comments. First, the current definition of "exempt well" as proposed by the Authority closely tracks the criteria found in §1.33 of the Act. Second, the addition of the phrase "or livestock watering" is redundant and unnecessary. Further, §702.1(b)(20)(c) already specifies that "domestic or livestock use" includes the "watering of animals."

Third, §1.33(c) specifically states that a well is not exempt if it is "within or serving a subdivision requiring platting." The Authority believes that changing this phrase to "within and serving a subdivision requiring platting" would be contrary to the Act. Such a change would allow, for example, a domestic or livestock well located outside a subdivision requiring platting to provide service to unlimited connections within the subdivision. The Authority believes that such an arrangement would violate the Act. Further, the Authority has, in its proposed exempt well rules, found at Subchapter C of the Authority's proposed Chapter 711 rules, attempted to address the concern raised by Haney involving a situation in which a well owner resides on land which was unsubdivided during the historical period but which subsequently came to be subdivided in a way that required platting. Amendment of §702.1 is not necessary or warranted on this point.

Finally, the Authority believes the Act mandates that if an exempt well is used for non-exempt purposes then it loses its exempt status and should require a permit. Thus, exempt well owners should not be allowed to pump up to 1,250 gallons per day for non-exempt purposes from their exempt wells. Further, there are practical and logistical impediments to this proposal by Haney. The only way to confirm whether a given exempt well owner were, in fact, pumping no more than 1,250 gallons per day for non-exempt uses would be by installing a meter on the well. However, §1.33 of the Act clearly states that exempt wells are exempt from the metering requirement. The Authority has declined to modify §702.1(b)(22) in response to the Haney comments.

Public Comment No. 6:

Earl & Brown asks that the definition of "exempt well" be revised as follows:

Exempt well- A well that produces 25,000 gallons of water a day or less or which is physically capable of only producing up to a maximum of 25,000 gallons per day average on an annual basis for domestic of livestock use that is not within or serving a subdivision requiring platting, which is exempt from metering requirements.

Authority's Response:

The Authority disagrees with the Earl & Brown comment. First, the current definition of "exempt well" as proposed by the Authority closely tracks the criteria found in §1.33 of the Act. The Earl & Brown comment would add new a criterion outside the scope of §1.33 of the Act. Allowing for the averaging of pumpage throughout the year would clearly allow pumping on any given day to exceed 25,000 gallons. The Authority believes this would contravene the clear language of §1.33 of the Act. Second, the language proposed by Earl & Brown appears to be nonsensical. It is unclear how a well could be "physically capable" of producing more than 25,000 gallons on certain days, but less on other days, so that the average on an annual basis was below 25,000 gallons. Third, the only way to measure average use is with a meter. However, §1.33 of the Act specifies that exempt wells are excluded from the meter requirement. The Authority has declined to modify §702.1(b)(22) in response to the Earl & Brown comments.

Public Comment No. 7:

Haney also submitted comments on the definition of "industrial use" found at §702.1(b)(29). As proposed, that definition reads as follows:

Industrial use- The use of water for, or in connection with, commercial or industrial activities, including manufacturing, bottling; brewing; food processing; scientific research and technology; recycling; production of concrete, asphalt, and cement; commercial uses of water for tourism, entertainment, and hotel or motel lodging; generation of power other than hydroelectric; and other business activities.

Haney suggests the following definition:

Industrial use- The use of water in excess of 1250 gallons per day for, or in connection with, commercial or industrial activities, including manufacturing, bottling; brewing; food processing; scientific research and technology; recycling; production of concrete, asphalt, and cement; commercial uses of water for tourism, entertainment, and hotel or motel lodging; generation of power other that hydroelectric; and other business activities.

As with his proposed change to the definition of "exempt well," Haney proposes this change because he believes a "de minimus" exception, defined by Haney to mean 1,250 gallons per day or less, ought to be created for otherwise exempt well owners who wish to pump relatively small amounts of water for non-exempt purposes from their exempt wells.

Authority's Response:

The Authority disagrees with this comment. First, the Authority's definition of "industrial use" in §702.1(b)(29) identically tracks the definition found in §1.03(11) of the Act. The definition found in the Act does not include any de minimus exclusion. Second, the Authority believes the Act mandates that if an exempt well is used for non-exempt purposes then it loses its exempt status. Thus, exempt well owners should not be allowed to pump up to 1,250 gallons per day for non-exempt purposes, such as industrial purposes, from their exempt wells. Further, there are practical and logistical impediments to this proposal by Haney. The only way to confirm whether a given exempt well owner were, in fact, pumping no more than 1,250 gallons per day for non-exempt uses, such as industrial uses, would be by installing a meter on the well. However, §1.33 of the Act clearly states that exempt wells are exempt from the metering requirement. The Authority has declined to modify §702.1(b)(22) in response to the Haney comment.

Public Comments No. 8 and No. 9:

Both the TNLA and CSN assert that the definition of "irrigation use" is inadequate and circular, thereby leading to confusion and misinterpretation. Neither entity proposes substitute language.

Authority's Response:

The Authority disagrees with this comment. The definition of "irrigation use," found at §702.1(b)(31), is identical to the definition found at §1.03(12) of the Act. Further, the Authority believes that the definition is clear. The Authority has declined to modify §702.1(b)(31) in response to this comment.

Public Comments No. 10 and No.11:

The Braggs and Windrow both commented upon proposed rule § 702.1(32) which states:

(32) Interruptible-When referring to a groundwater withdrawal permit, the conditioning of the right to withdraw groundwater from the aquifer that makes the right subject to complete cessation, temporary curtailment, or reduction of the amount of groundwater that may be withdrawn from the aquifer based upon the measurement of a water level at an index well, or as otherwise determined by the board.

The Braggs and Windrow recommend that the ending phrase, "or as otherwise determined by the board," be deleted. The Braggs assert that this language is too general and will render groundwater management and planning impossible. They also contend that interruptiblility should be keyed solely upon "spring flow protection" or "groundwater and spring flow modeling." Windrow feels that the phrase is too vague and, instead, any criteria for interruption of groundwater withdrawals should be specified.

Authority's Response:

The Authority agrees that the phrase "or as otherwise determined by the board" is somewhat vague and could be made more definite. The intent of this definition is to make withdrawal amounts subject to interruption based upon the measurement of a water level at an index well or upon the criteria set forth in the Authority's comprehensive water management plan implementation rules which, though not yet adopted by the Authority, will, when adopted, be codified at 31 TAC Chapter 715. Accordingly, the Authority has modified §702.1(b)(32) in response to these comments by deleting the phrase "or as otherwise determined by the board" and replacing it with the phrase "or as otherwise required by the comprehensive water management plan implementation rules found at 31 TAC Chapter 715 (relating to Comprehensive Water Management Plan Implementation)."

Public Comment No. 12:

The TFB asserts that the Authority was required by the Texas Private Real Property Rights Preservation Act to prepare a "takings impact assessment" or "TIA" before providing notice of the proposed adoption of rule 702.1.

Authority's Response:

The Authority disagrees. Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act" ("TPRPRA"), requires governmental entities, under certain circumstances, to prepare a TIA in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the adoption of this rule. First, the rules themselves impose no burden upon vested private real property. As such, they have no direct affect on vested private real property and may not result in a taking. Second, the Authority's action in adopting these rules is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from the Texas Private Real Property Rights Preservation Act under §2007.003(b)(4) of the Texas Government Code. See Act §§1.03, 1.08(a), 1.11(a), (f) and (h); Texas Government Code Annotated, §§ 2001.004(1), 2001.021(b), 2001.026, 2001.029, and 2001.031, and §36.001(5) of the Texas Water Code. It was held, in Edwards Aquifer Authority v. Bragg, 21 S.W.3d. 375, 379 (Texas App. San Antonio 2000, pet. filed), that the Edwards Aquifer Act expressly mandates the adoption of substantive and procedural rules and that such actions are therefore excepted from the Texas Private Real Property Rights Preservation Act. The holding in that case controls here. Third, it is the position of the Authority that all valid actions of the Authority are excluded from the Texas Private Real Property Rights Preservation Act under §2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the adoption of these rules.

VI. CONCISE RESTATEMENT OF PARTICULAR STATUTORY PROVISIONS UNDER WHICH THE RULE IS ADOPTED AND THE AUTHORITY INTERPRETATION OF THE PROVISIONS AS AUTHORIZING OR REQUIRING THE RULE.

Section 1.03 of the Act sets forth definitions of various words and phrases used throughout the Act that the Legislature provided in passing the Act. Many of the definitions in this final rule are taken directly from, and conform with this provision. In addition, §1.14(d) of the Act provides the grounds for and the procedure by which the Authority may increase the quantity of groundwater available for permitting and modify the effect of §1.14(b) and (c) of the Act which creates maximum quantities of groundwater that may be permitted for certain periods of time. Among the groundwater available is conservation, augmentation, and supplemental recharge. Also, §1.11(f) of the Act empowers the Authority to contract with a person who uses water from the aquifer to construct, operate, own, finance, and maintain water supply facilities. That section defines the term "water supply facility" as including "a dam, reservoir, treatment facility, transmission facility, or recharge project." Section 1.44 of the Act provides the terms and conditions under which a political subdivision of the state may enter in to an interlocal contract with the Authority for an aquifer recharge, storage and recovery project. Section 1.45 of the Act authorizes the Authority to build or operate recharge dams and provides certain terms and conditions for the operation of such facilities as well as eligible source water for the recharge project. In conjunction with §1.08(a) and §1.11(a) of the Act discussed below, the Authority interprets these sections as authorizing the adoption of the following general definitions in conformance with the Act: (6) aquifer; (9) augmentation; (10) authority; (12) beneficial use; (13) board; (14) commission; (15) conservation; (18) diversion; (20) domestic or livestock use; (29) industrial use; (31) irrigation use; (34) livestock; (36) municipal use; (39) order; (43) person; (46) pollution; (48) recharge; (52) reuse; (59) water supply facility; (60) well; (62) well J-17; (63) well J-27; and (64) withdrawal. The Authority also interprets these sections, as well as §36.001(5), Texas Water Code, as authorizing the adoption of a definition for (26) groundwater and (58) "underground water." In §1.03(20), the term "underground water" is assigned the meaning that this term has in §52.001, Texas Water Code. Since the passage the Act, chapter 52, Texas Water Code, has been repealed and recodified as chapter 36, Texas Water Code. See Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 933, sec. 2, 6, 1995 Texas General Laws 4673. In so doing, the legislature abandoned the use of the term "underground water" in favor of the more modern term "groundwater" found at §36.001(5), Texas Water Code, and is defined as "water percolating below the surface of the earth." Under §1.08(a) of the Act, chapter 36, Texas Water Code, which replaced chapter 52, is now applicable to the Authority to the extent that it does not conflict with the Act. The Authority can identify no conflict with the Act in adopting the statutory definition of groundwater found in chapter 36, Texas Water Code.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rules governing procedures of the board and the authority." This section directs the Board to adopt rules as necessary to implement the various substantive programs set forth in the Act related to the Edwards Aquifer, and the procedural rules associated therewith in the administration of the programs.

Section 1.11(d)(5) of the Act provides that the Board may hire an executive director to manage the Authority. Consistent with groundwater conservation district practices, the preference of the Authority is to refer to its "executive director" as the "general manager." In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (25) general manager.

Section 1.ll(h) of the Act provides that the Authority is, among other things, "subject to the Administrative Procedures Act, TEXAS GOVERNMENT CODE ANN. §§2001.001-2001.902 (Vernon 2000). Because the Authority is "subject to" the APA due to the operation of §1.11(h) of the Act, §2001.004(1), TEXAS GOVERNMENT CODE, provides that the Authority is required to adopt rules of practice stating the nature and requirement of all available formal and informal procedures. This would necessarily include definitions relevant to the rules of practice or procedural rules. In addition, §1.16(a) of the Act provides for existing users to file declarations of historical use (otherwise known as applications for initial regular permits) for withdrawals made during the statutorily established historical period. Section 1.33(b) of the Act provides that exempt wells must be registered with the Authority. In conjunction with §§1.08(a) and 1.11(a) of the Act discussed above, the Authority interprets these sections as authorizing the adoption of the following procedural definitions: (1) Act; (3) APA; (4) applicant; (5) application; (11) Authority offices; (16) declarant; (19) docket clerk; (24) general counsel; (33) judge; (40) party; (41) permit; (42) permittee; (43) petitioner; (45) pleadings; (47) protestant; (50) registrant; (51) registration; and (54) SOAH (State Office of Administrative Hearings).

Section 1.14(d) of the Act provides the grounds for and the procedure by which the Authority may increase the quantity of groundwater available for permitting and modify the effect of §1.14(b) and (c) of the Act which creates maximum quantities of groundwater that may be permitted for certain periods of time. Among the groundwater available is supplemental recharge. Also, §1.11(f) of the Act empowers the Authority to contract with a person who uses water from the aquifer to construct, operate, own, finance, and maintain water supply facilities. That section defines the term "water supply facility" as including, among other things, a recharge project. Section 1.44 of the Act provides the terms and conditions under which a political subdivision of the state may enter in to an interlocal contract with the Authority for an aquifer recharge, storage and recovery project. Section 1.45 of the Act authorizes the Authority to build or operate recharge dams and provides certain terms and conditions for the operation of such facilities as well as eligible source water for the recharge project. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, the Authority interprets these sections as authorizing the adoption of the following terms related to recharge projects: (8) aquifer recharge and storage permit; and (49) recharge recovery permit.

Section 1.14(e) of the Act provides for a prohibition on withdrawals of groundwater from the Edwards Aquifer (Aquifer) from post-June 1, 1993 new wells, as well as, provisions for interruptible withdrawals from such wells if the amount of groundwater available for permitting is increased pursuant to §1.14(d) of the Act. In addition, §1.03(10) defines the term "existing user." Also, §1.16(a) of the Act authorizes "existing user" to files declarations of historical use (also known as applications for initial regular permit) for withdrawals of groundwater placed to beneficial use during the historical period. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act creates the concept of "existing user," "historical use," and a date for the establishment of a prohibition against the withdrawal of groundwater from certain wells, and it is necessary to give meaning and definition to this concept as created in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (23) existing well; and (37) new well.

Section 1.14(f) of the Act authorizes the Authority to allow uninterruptible withdrawals from the Aquifer when certain index wells for the San Antonio and Uvalde Pools are at certain levels identified in the section. Section 1.19(b) of the Act provides for the minimum index well level for the San Antonio Pool below which term permit withdrawals would be automatically interrupted. Section 1.19(c) of the Act provides for the minimum index well level for the Uvalde Pool below which term permit withdrawals would be automatically interrupted. In conjunction with §§1.08(a) and 1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (32) interruptible; (53) San Antonio pool; and (58) Uvalde pool.

Section 1.15(a) of the Act provides broad authority to the Authority to manage (1) withdrawals from the Aquifer, and (2) points of withdrawals pursuant to the Act. Section 1.15(b) of the Act prohibits withdrawals from the Aquifer except pursuant to a prior issued groundwater withdrawal permit. An exception to this permit requirement is recognized for withdrawals made based on interim authorization status under §1.17 of the Act, and exempt wells under §1.33 of the Act. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act creates the concept of groundwater withdrawals by permit, it is necessary to give meaning and definition to this concept as created in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (27) groundwater withdrawal permit; (35) monitoring well permit; and (61) well construction permit.

Section 1.16(a) of the Act provides for existing users to file declarations of historical use (otherwise known as applications for initial regular permits) for withdrawals made during the statutorily established historical period. Section 1.16(d) of the Act provides some of the elements that, if proven by convincing evidence, would require the Board to grant an application for an initial regular permit. Section 1.15(c) of the Act authorizes the Authority to issue, among other things, regular permits. Section 1.17(a) of the Act authorizing persons owning wells meeting certain criteria to continue to make withdrawals from the well even though they have yet not been issued an initial regular permit. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (17) declaration of historical use (or declaration); (30) initial regular permit; and (28) historical period.

Section 1.18(a) of the Act authorizes the Authority to issue additional regular permits if there remains water available for permitting after the issuance of all initial regular permits. The section also provides that groundwater withdrawals pursuant to additional regular permits are subject to maximum permitted groundwater withdrawal amounts set out in §1.14(b) and (c) of the Act. Section 1.18(b) of the Act prohibits the Authority from considering or taking action on an application for an additional regular permit until the Authority has taken final action on all pending applications for initial regular permits. Section 1.15(c) of the Act authorizes the Authority to issue, among other things, regular permits. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (2) additional regular permit.

Section 1.19(a) of the Act authorizes the Authority to issue term permits for groundwater withdrawals from the Aquifer for up to 10 years. Section 1.19(b) of the Act provides for the minimum index well level for the San Antonio Pool below which term permit withdrawals would be automatically interrupted. Section 1.19(c) of the Act provides for the minimum index well level for the Uvalde Pool below which term permit withdrawals would be automatically interrupted. Section 1.15(c) of the Act authorizes the Authority to issue, among other things, term permits. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (57) term permit.

Section 1.20(a) of the Act authorizes the Authority to issue emergency permits for groundwater withdrawals from the Aquifer not to exceed 30 days to prevent severe, imminent threats to the public health or safety. Section 1.15(c) of the Act authorizes the Authority to issue, among other things, emergency permits. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (21) emergency permit.

Section 1.29(b) of the Act directs the Authority to assess an aquifer management fee on aquifer use to finance its administrative and programmatic expenses authorized under the Act. Section 1.29(e) of the Act provides that in developing its fees, the Authority may charge different fee rates on a per acre-foot basis for different types of uses as long as they are equitable between types of uses. This section also creates a fee differential between agricultural users and non-agricultural users for aquifer management fees whereby the agricultural fee may not exceed 20 percent of the aquifer management fees assessed against non-agricultural users. In addition, this section creates a distinction between agricultural and non-agricultural users when calculating aquifer use under §1.29(b) of the Act by providing that aquifer use for agricultural users is the actual volume of groundwater withdrawn, while for non-agricultural users it is the face value authorized to be withdrawn in an initial regular permit. In conjunction with § 1.08(a) and §1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (7) aquifer management fee.

Section 1.31(a) of the Act provides that owners of non-exempt wells are required to install meters on wells, or, if the meter requirement is waived, apply alternative measuring methods to calculate the volume of groundwater withdrawals from the Aquifer. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (38) non-exempt well.

Section 1.33(a) of the Act provides that wells qualifying for exempt status are not required to install a meter on the well. This subsection also provides some of the criteria for a well to quality for exempt well status. Section 1.33(b) of the Act provides that exempt wells must be registered with the Authority. Section 1.33(c) of the Act provides additional criteria for a well to quality for exempt well status. Section 1.16(c) of the Act provides that owners of exempt wells are not required to file declarations of historical use in order to continue to make lawful withdrawals from their exempt wells. In conjunction with §§1.08(a) and 1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (22) exempt well.

Section 1.08(b) of the Act provides that the Authority does not have the authority to regulate surface water. The Authority interprets the jurisdictional limitation in §1.08(b) to apply to surface water over which the prior appropriation doctrine applies and jurisdiction is vested in the Texas Natural Resource Conservation Commission. Surface water is generally considered to be "state water." The definition of state water is found in §11.021(a), Texas Water Code. In conjunction with §1.08(a) and §1.11(a) of the Act discussed above, because the Act employs this term and it is necessary to give meaning and definition to this term as used in the Act, the Authority interprets these sections as authorizing the adoption of a definition for (56) surface water.

The new section is adopted pursuant to §§1.03, 1.08(a), 1.11(a), (d)(5), (f) and (h), 1.14(d)-(f), 1.15(a)-(c), 1.16(a), (c), and (d), 1.17(a), 1.18(a) and (b), 1.19(a)-(c), 1.20(a), 1.29(b) and (e), 1.31(a), 1.33(a)-(c), 1.44, and 1.45 of the Act; §§11.021(a) and 36.001(5), Texas Water Code Annotated; and §2001.004(1), Texas Government Code Annotated.

§702.1.General Definitions.

(a)

In its rules, the Authority employs two types of definitions. The first type are general definitions that apply to all rules of the Authority. The second type are specific definitions that apply only to the chapters in this title in which they are located. The specific definitions applying only to terms within a particular chapter are set out in that chapter.

(b)

The following words and terms, when used in any rule of the Authority, shall have the following meanings, unless the context clearly indicates otherwise:

(1)

Act-The Edwards Aquifer Authority Act, Act of May 30, 1993, 73rd Legislature, Regular Session, Chapter 626, 1993 Texas General Laws 2353, as amended.

(2)

Additional regular permit-A groundwater withdrawal permit issued by the Authority pursuant to the Act, § 1.18(a).

(3)

APA-The Administrative Procedures Act, Chapter 2001, Government Code.

(4)

Applicant-A person who files an application with the Authority.

(5)

Application--A form document required by the Authority to initiate the process of obtaining the issuance of a permit, registration, exemption, license or any other Authority approval. A declaration of historical use is an application for an initial regular permit.

(6)

Aquifer-The Edwards Aquifer, which is that portion of an arcuate belt of porous, water-bearing, predominately carbonate rocks known as the Edwards and Associated Limestone in the Balcones Fault Zone extending from west to east to northeast from the hydrologic division near Brackettville in Kinney County that separates underground flow toward the Comal Springs and San Marcos Springs from underground flow to the Rio Grande Basin, through Uvalde, Medina, Atascosa, Bexar, Guadalupe and Comal counties, and in Hays County south of the hydrologic division near Kyle that separates flow toward the San Marcos River from flow to the Colorado River Basin.

(7)

Aquifer management fees-The fee authorized to be assessed by the Authority based:

(A)

on aquifer use under the Act, § 1.29(b) and (e); or

(B)

taxes in lieu of user fees to be paid by groundwater users in a groundwater conservation district governed by Chapter 36, Water Code, pursuant to a contract between the Authority and the water district under the Act, § 1.29(b).

(8)

Aquifer recharge and storage permit - A permit issued by the Authority for the recharge of the aquifer.

(9)

Augmentation-An act or process to increase the amount of water available for use or springflow.

(10)

Authority--The Edwards Aquifer Authority.

(11)

Authority offices-The Authority's principal offices identified in § 701.5 of this title (relating to Business Office and Mailing Address of the Authority).

(12)

Beneficial use--The use of the amount of water that is economically necessary for a purpose authorized by law when reasonable intelligence and reasonable diligence are used in applying the water to that purpose.

(13)

Board-The board of directors of the Authority.

(14)

Commission-The Texas Natural Resource Conservation Commission.

(15)

Conservation-Any measure that would sustain or enhance water supply.

(16)

Declarant-An existing user who files a declaration of historical use.

(17)

Declaration of historical use (or declaration)-The form document required by the Authority to be filed pursuant to the Act, § 1.16(a). A declaration is an application for an initial regular permit.

(18)

Diversion-The removal of state water from a watercourse or impoundment.

(19)

Docket clerk-The docket clerk of the Authority as designated by the general manager.

(20)

Domestic or livestock use-Use of water for:

(A)

drinking, washing, or culinary purposes;

(B)

irrigation of a family garden or orchard the produce of which is for household consumption only, or

(C)

watering of animals.

(21)

Emergency permit-A groundwater withdrawal permit issued by the Authority pursuant to the Act, § 1.20(a).

(22)

Exempt well-A well that produces 25,000 gallons of water a day or less for domestic or livestock use that is not within or serving a subdivision requiring platting.

(23)

Existing well-A well drilled before June 1, 1993.

(24)

General counsel-The general counsel of the authority hired by the board.

(25)

General manager-The executive director hired by the board to be the chief administrator of the Authority.

(26)

Groundwater-Water percolating below the surface of the earth.

(27)

Groundwater withdrawal permit--A permit issued by the authority pursuant to § 1.15(b) of the Act authorizing the withdrawal of groundwater from the aquifer.

(28)

Historical period-The period from June 1, 1972, through May 31, 1993, inclusive.

(29)

Industrial use-The use of water for, or in connection with, commercial or industrial activities, including manufacturing, bottling; brewing; food processing; scientific research and technology; recycling; production of concrete, asphalt, and cement; commercial uses of water for tourism, entertainment, and hotel or motel lodging; generation of power other than hydroelectric; and other business activities.

(30)

Initial regular permit-A groundwater withdrawal permit issued by the Authority pursuant to the Act, § 1.16(d).

(31)

Irrigation use-The use of water for the irrigation of pastures and commercial crops, including orchards.

(32)

Interruptible-When referring to a groundwater withdrawal permit, the conditioning of the right to withdraw groundwater from the aquifer that makes the right subject to complete cessation, temporary curtailment, or reduction of the amount of groundwater that may be withdrawn from the aquifer based upon the measurement of a water level at an index well, or as otherwise required by Chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

(33)

Judge-A SOAH administrative law judge.

(34)

Livestock-Animals, beasts or poultry collected or raised for pleasure, recreational use, or commercial use.

(35)

Monitoring well permit-A permit issued by the Authority pursuant to § 1.15(b) of the Act for the measuring of the water quality of the aquifer or water level of the aquifer.

(36)

Municipal use-The use of water within or outside of a municipality and its environs whether supplied by a person, privately owned utility, political subdivision, or other entity, including the use of treated effluent for certain purposes specified as follows. The term includes:

(A)

the use of water for domestic use, the watering of lawns and family gardens, fighting fires, sprinkling streets, flushing sewers and drains, water parks and parkways, and recreation, including public and private swimming pools;

(B)

the use of water in industrial and commercial enterprises supplied by a municipal distribution system without special construction to meet its demands; and

(C)

the application of treated effluent on land under a permit issued under Chapter 26, Water Code, if:

(i)

the primary purpose of the application is the treatment or necessary disposal of the effluent;

(ii)

the application site is a park, parkway, golf course, or other landscaped area within the authority's boundaries; or

(iii)

the effluent applied to the site is generated within an area for which the commission has adopted a rule that prohibits the discharge of the effluent.

(37)

New well-A well drilled on or after June 1, 1993.

(38)

Non-exempt well-Any well, the groundwater withdrawals from which, are required to be authorized by interim authorization status or a groundwater withdrawal permit.

(39)

Order-Any written directive of the board carrying out the powers and duties of the Authority under Article 1 of the Act.

(40)

Party-Each person admitted as a party in a contested case hearing.

(41)

Permit-The written document issued by the Authority approving an application for a permit.

(42)

Permittee-A person to whom the Authority has issued a permit.

(43)

Person-An individual, corporation, organization, government or governmental subdivision or agency, business trust, estate, trust, partnership, association and any other legal entity.

(44)

Petitioner--A person who files a petition with the authority.

(45)

Pleadings-Any document filed by parties in a contested case hearing.

(46)

Pollution-The alteration or contamination of the physical, thermal, chemical, or biological quality of any water in the state, or the contamination of any water in the state, that renders the water harmful, detrimental, or injurious to humans, animal life, vegetation, property, or public health, safety, or welfare or that impairs the usefulness of the public enjoyment of the water for any lawful or reasonable purpose.

(47)

Protestant-Any person opposing, in whole or in part, an application.

(48)

Recharge-Increasing the supply of water to the aquifer by naturally occurring channels or artificial means.

(49)

Recharge recovery permit-A permit issued by the Authority pursuant to § 1.15(b) for withdrawal of groundwater stored in the aquifer pursuant to an aquifer recharge and storage permit.

(50)

Registrant-A person who files a registration with the Authority.

(51)

Registration-The document required to be filed pursuant to the Act, § 1.33(b) or as may otherwise be required by the rules of the Authority.

(52)

Reuse-Authorized use for one or more beneficial purposes of use of water that remains unconsumed after the water is used for the original purpose of use and before the water is discharged or otherwise allowed to flow into a watercourse, lake, or other body of state-owned water.

(53)

San Antonio Pool-That part of the aquifer underlying the boundaries of the Authority, other than Uvalde County.

(54)

SOAH-The State Office of Administrative Hearings.

(55)

Surface Water-Has the meaning of "state water" as defined by § 11.021, Water Code.

(56)

Term permit-A groundwater withdrawal permit issued by the Authority pursuant to the Act, § 1.19(a).

(57)

Underground water-Has the meaning of "groundwater" as defined by § 36.001(5), Water Code, as incorporated in paragraph (26) of this subsection.

(58)

Uvalde Pool-That part of the Aquifer underlying the boundaries of the Authority and Uvalde County.

(59)

Water supply facility-Any infrastructure designed for the supply of raw or potable water for any beneficial use, including a dam, reservoir, treatment facility, transmission facility, or recharge project.

(60)

Well-A bored, drilled, or driven shaft or an artificial opening, in the ground made by digging, jetting, or some other method where the depth of the shaft or opening is greater than its largest surface dimension, but does not include a surface pit, surface excavation, or natural depression.

(61)

Well construction permit-A permit issued by the Authority pursuant to § 1.15(b) of the Act for the construction or modification of wells or other works designed for the withdrawal of water from the aquifer.

(62)

Well J-17-State well number AY-68-37-203 located in Bexar County.

(63)

Well J-27-State well number YP-69-50-302 located in Uvalde County.

(64)

Withdrawal-An act or a failure to act that results in taking water from the aquifer by or through man-made facilities, including pumping, withdrawing or diverting groundwater.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007341

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Chapter 705. JURISDICTION OF THE EDWARDS AQUIFER AUTHORITY

31 TAC §705.1, §705.3

I. INTRODUCTION.

The Edwards Aquifer Authority ("Authority") adopts new 31 TAC, §705.1 and §705.3, consisting of rules relating to the jurisdiction of the Authority, without changes to the proposed text as published in the August 11, 2000 issue of the Texas Register (25 TexReg 7500-7502). The sections will not be republished.

These rules have been written to clearly define the Authority's jurisdiction.

II. SUMMARY OF THE FACTUAL BASIS FOR THE ADOPTED RULES.

The Authority is required by the Edwards Aquifer Authority Act (Act of May 30, 1993, 73rd Legislature, Regular Session, Chapter 626, 1993 Texas General Laws 2350, 2358-59, as amended by Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 261, 1995 Texas General Laws 2505, Act of May 16, 1995, 74th Legislature, Regular Session, Chapter 524, 1995 Texas General Laws 3280, and Act of May 6, 1999, 76th Legislature, Regular Session, Chapter 163, 1999 Texas General Laws 634 ("Act")), to implement Edwards Aquifer management programs relating to, among other things, fees, exempt wells, interim authorization, permitted wells, permit conditions, groundwater available for permitting, proportional adjustment, equal percentage reduction, abandonment and cancellation of permits, aquifer recharge, storage and recovery, additional groundwater supplies available for permitting, transfers, meters and alternative measuring methods, groundwater trust, water quality, and comprehensive water management plan implementation.

The Authority interprets these provisions as requiring the establishment of rules relating to the Authority's jurisdiction. Specifically, § 1.08(b) expressly provides that the jurisdiction of the Authority extends to underground water within or withdrawn from the Aquifer, but not to surface water. Together, these sections clearly demonstrate a rational connection between the factual basis for the rule and the rule as adopted.

III. REGULATORY IMPACT ANALYSIS OF MAJOR ENVIRONMENTAL RULES.

Section 2001.0225 of the Texas Government Code requires an agency to perform, under certain circumstances, a regulatory analysis of "major environmental rules." The Authority has determined that none of the rules are "major environmental rules" as that term is defined by §2001.0225(g)(3) of the Texas Government Code. The basis for this determination is that the rules do not have the specific intent to "protect the environment" or "reduce risks to human health from environmental exposure." The rules merely state the Authority's understanding concerning its jurisdiction. Their specific intent is to state and clarify the extent of the Authority's power. These rules do not contain any environmental or human health standards that impose requirements on the regulated community. For these reasons, we find that none of the rules are "major environmental rules" and that, therefore, no further analysis is required by § 2001.0225 of the Texas Government Code.

IV. TEXAS PRIVATE REAL PROPERTY RIGHTS PRESERVATION ACT.

Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act," ("TPRPRA") requires governmental entities, under certain circumstances, to prepare a takings impact assessment ("TIA") in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the adoption of these rules. First, the Authority has made a "categorical determination" that rules that provide general information only do not affect private real property. These rules provide general information only; that is, they provide general statements concerning the nature of Authority's jurisdiction. Second, the Authority's action in adopting these rules is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from TPRPRA under §2007.003(b)(4) of the Texas Government Code. See Act § 1.08(a), 1.08(b), 1.11(a). It was held, in Edwards Aquifer Authority v. Bragg, 21 S.W.3d. 375 (Texas App. - San Antonio 2000, pet. filed), that the Act expressly mandates the adoption of substantive and procedural permitting rules and that such actions are therefore excepted from TPRPRA. Third, it is the position of the Authority that all valid actions of the Authority are excluded from TPRPRA under §2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the adoption of these rules.

V. SUMMARY OF PUBLIC COMMENTS.

Five public hearings were held on these and other rules proposed by the Authority on: Wednesday, August 9, 2000 at 6:00 p.m. at the Conference Center of the Edwards Aquifer Authority, 1615 N. St. Mary's Street, San Antonio, Texas; Tuesday, August 15, 2000 at 6:00 p.m. at the New Braunfels Civic Center, 380 S. Seguin Avenue, New Braunfels, Texas; August 17, 2000 at 6:00 p.m. at St. Paul's Lutheran Church, 1303 Avenue M, Hondo, Texas; Tuesday, August 22, 2000 at 6:00 p.m. at the Sgt. Willie De Leon Civic Center, 300 E. Main Street in Uvalde, Texas; and Thursday August 24, 2000 at the San Marcos Activities Center, 501 E. Hopkins, San Marcos, Texas. At those hearings, no public comments were received on proposed §705.1 or §705.3. Further, no written comments were submitted to the Authority on proposed §705.1 or §705.3.

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer.

Section 1.08(b) of the Act provides that the Authority's "powers regarding underground water apply only to underground water within or withdrawn from the aquifer." The term "aquifer" is defined by § 1.03(1) of the Act as "the Edwards Aquifer, which is that portion of an arcuate belt of porous, water-bearing, predominately carbonate rocks known as the Edwards and Associated Limestones in the Balcones Fault Zone extending from west to east to northeast from the hydrologic division near Brackettville in Kinney County that separates underground flow toward the Comal Springs and San Marcos Springs from underground flow to the Rio Grande Basin, through Uvalde, Medina, Atascosa, Bexar, Guadalupe, and Comal counties, and in Hays County south of the hydrologic division near Kyle that separates flow toward the San Marcos River from flow to the Colorado River Basin."

The term "underground water" is located in § 1.03(20) of the Act and is assigned the meaning that this term has in § 52.001, Texas Water Code. Since the passage of the Act, chapter 52, Texas Water Code, has been repealed and recodified as chapter 36, Texas Water Code. See Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 933, sec. 2, 6, 1995 Texas General Laws 4673. In so doing, the legislature abandoned the use of the term "underground water" in favor of the more modern term "groundwater" found at § 36.001(5), Texas Water Code, and is defined as "water percolating below the surface of the earth." Under § 1.08(a) of the Act, chapter 36, Texas Water Code (which replaced chapter 52) is now applicable to the Authority to the extent that it does not conflict with the Act. The Act provides no other guidance relative to the definition of groundwater or underground water. Accordingly, the Authority can identify no conflict within the Act that would prevent adopting the statutory definition of groundwater found in chapter 36, Texas Water Code.

Section 1.08(b) also states that "this subsection is not intended to allow the authority to regulate surface water." The Authority interprets the jurisdictional limitation in § 1.08(b) to apply to surface water over which the prior appropriation doctrine applies and jurisdiction is vested in the Texas Natural Resource Conservation Commission. Surface water is generally considered to be "state water." The definition of "state water" is found in § 11.021(a), Texas Water Code.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rules governing procedures of the board and the authority." This section directs the Board to adopt rules as necessary to implement the various substantive programs set forth in the Act.

The new sections are adopted pursuant to §§1.08(a), 1.08(b) and 1.11(a) of the Act. The Authority interprets these sections as requiring the Authority to adopt rules establishing the jurisdiction of the Authority.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000

TRD-200007342

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Chapter 707. PROCEDURE BEFORE THE AUTHORITY

I. INTRODUCTION.

The Edwards Aquifer Authority ("Authority") adopts new 31 TAC, §§707.1, 707.101-707.106, 707.201-707.208, 707.301-707.315, 707.401-707.417, 707.422, 707.424, 707.426, 707.428, 707.501-707.519, 707.601-707.626, consisting of rules governing procedure before the Authority. Sections 707.201, 707.203, 707.303, 707.304, 707.309, 707.311, 707.312, 707.405, 707.411-707.416, 707.428, 707.504, 707.510, 707.515, 707.601, 707.604, and 707.605 are adopted with changes to the proposed text as published in the August 11, 2000, issue of the Texas Register (25 TexReg 7500-7533). Sections 707.1, 707.101, 707.102, 707.103, 707.104, 707.105, 707.106, 707.202, 707.205, 707.206, 707.207, 707.208, 707.301, 707.302, 707.305, 707.306, 707.307, 707.308, 707.310, 707.313, 707.314, 707.315, 707.401, 707.402, 707.403, 707.404, 707.406, 707.407, 707.408, 707.409, 707.410, 707.417, 707.422, 707.424, 707.426, 707.501, 707.502, 707.503, 707.505, 707.506, 707.507, 707.508, 707.509, 707.511, 707.512, 707.513, 707.514, 707.516, 707.517, 707.518, 707.519, 707.602, 707.603, 707.606, 707.607, 707.608, 707.609, 707.610, 707.611, 707.612, 707.613, 707.614, 707.615, 707.616, 707.617, 707.618, 707.619, 707.620, 707.621, 707.622, 707.623, 707.624, 707.625, and 707.626 are adopted without changes to the proposed text and will not be republished. Section 707.204 is being withdrawn from consideration and therefore will not be republished.

These rules have been written to provide the public and Authority staff with procedures necessary for the effective implementation of many of the Authority's substantive programs including permitting, well registration, exempt wells, meters, transfers of groundwater withdrawal rights, agricultural conservation loans, monitoring wells, and cancellation and abandonment of permitted rights. These rules also establish basic requirements governing the filing of documents with the Authority and the service of such documents on other persons, and for the conduct of meetings of the Authority's Board of Directors. Finally, these rules establish procedures governing contested case hearings on certain applications.

II. SUMMARY OF THE FACTUAL BASIS FOR THE ADOPTED RULES.

The Authority is required by the Edwards Aquifer Authority Act (Act of May 30, 1993, 73rd Legislature, Regular Session, Chapter 626, 1993 Texas General Laws 2350, 2358-59, as amended by Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 261, 1995 Texas General Laws 2505, Act of May 16, 1995, 74th Legislature, Regular Session, Chapter 524, 1995 Texas General Laws 3280, and Act of May 6, 1999, 76th Legislature, Regular Session, Chapter 163, 1999 Texas General Laws 634) ("Act") to implement Edwards Aquifer management programs relating to, among other things, permitting, well registration, exempt wells, meters, transfers of groundwater withdrawal rights, agricultural conservation loans, monitoring wells, and cancellation and abandonment of permitted rights. In order to implement these programs, the Authority must establish rules of procedure that will allow for the fair, consistent, and efficient administration of these and other programs. Moreover, the Authority is required to establish rules governing the filing of documents with the Authority, the service of documents, and the conduct of meetings of the Authority's Board of Directors. Finally, the Authority is required to establish rules governing contested case hearings on certain applications filed with the Authority.

Subchapter A consists solely of §707.1. Section 707.1 provides uniform definitions to be used throughout the rest of Chapter 707. It clarifies the meaning of certain terms used in Chapter 707, provides useful short-hand to reduce the amount of cumbersome regulatory language, and generally allows for a more efficient understanding and operation of the chapter.

Subchapter B consists of six sections (§§707.101-.106) and contains general provisions related to Authority procedures. Section 707.101 states the purpose of Chapter 707, explaining that Chapter 707 provides the procedures to be followed in Authority proceedings. Section 707.102 provides general standards regarding the computation of time when a period of time is prescribed or allowed under the Authority's rules or by applicable statute. This section adds clarity and consistency to Authority practice.

Section 707.103 provides general rules to be followed by persons when filing documents with the Authority. It requires that all such documents be submitted to the docket clerk of the Authority, that any docket or application number appear on the first page, and that such documents be filed by mail or by hand delivery. It also states the circumstances under which documents may be filed by facsimile. It provides that if a person files a document by facsimile, he or she must file an additional copy or copies with the docket clerk by mail or hand delivery within three days. This section also includes a requirement that "the Authority may waive one or more of the requirements of this section or impose additional filing requirements" §707.103(h). The purpose of this provision is to allow the Authority flexibility in the filing of documents. It may be appropriate, in some instances, for the Authority to waive certain requirements. In other instances, it may be appropriate to impose additional filing requirements. Where the Authority imposes additional filing requirements on a class of applicants or registrants, it has every intention of providing sufficient notice to persons who would be required to comply with that additional requirement. The Authority has no intention of imposing additional filing requirements with insufficient notice.

Section 707.104 provides general requirements to be followed by persons when serving documents under Chapter 707. It requires service either in person, by courier, United States mail, or facsimile. Section 707.104 also includes general rules concerning when service by mail and by facsimile is considered complete. It provides that service to a person by facsimile must be followed by service of an extra copy in person, by mail, or carrier-receipted delivery within one day. It also contains a certificate of service requirement and provides an extra three days when a person has a right or is required to do some act within a prescribed period after a document is served on that person by mail or facsimile.

The difference between the number of days following filing by facsimile in which a "hard copy" copy must be filed (§707.103(c)) (three) versus the number of days following service by facsimile in which a "hard copy" must be served (§707.104(b)) (one) is based on the fact that the rule regarding service of documents contains a "mailbox rule" while the rule regarding the filing of documents contain no "mailbox rule." Specifically, §707.104(b) states that "service by mail shall be complete upon deposit of the document, enclosed in a postage-paid properly addressed wrapper, in a post office of official depository under the case and custody of the United States Postal Service." Accordingly, when §707.103(c) requires a party filing by facsimile to file a copy of the document by mail within three days, the docket clerk of the Authority must actually receive the document within three days. On the other hand, since service by mail is complete upon deposit with the U.S. Postal Service, a party serving a document by facsimile may simply deposit a copy of the document in the mail on the day following the day that service by facsimile is made.

Section 707.105 states requirements for applicants, registrants and permittees regarding changes to addresses or telephone numbers. The Authority believes that these requirements are needed for the Authority to adequately maintain information necessary for its various permitting, registration and other programs.

Section 707.106 sets forth general requirements regarding the use of forms provided by the general manager. The Authority believes that the use of forms created and furnished by the Authority is necessary for the efficient processing of various applications and registrations and for the efficient administration of the Authority's permitting, registration and other programs. The fact that supplements may be attached as needed allows parties to avoid being constrained by space limitations on the forms.

Subchapter C consists of eight sections (§§707.201-.208) and establishes general rules regarding the conduct of meetings of the Board of Directors of the Authority. The Act provides that the Authority is governed by its Board of Directors, Act, §1.09. The purpose of subchapter C is facilitate the efficient conduct of the meetings of that body. It is intended to help create an environment at Board meetings that is conducive to decision-making and to orderly public input. This chapter is also intended to impart predictability and transparency to the decision-making process.

Section 707.201 states requirements regarding the frequency, scheduling, notice and conduct of board meetings. Section 707.202 relates to the conduct and decorum at Board meetings, and provides some general rules regarding the conduct of persons at such meetings. It also pertains to instances in which persons attending Board meetings have special requests. Section 707.203 pertains to deadlines to file comments on matters set for discussion at a Board meeting and it states some general rules regarding such deadlines. Section 707.205 pertains to the signing of orders or resolutions showing actions taken at Board meetings. It specifies that any such orders or resolutions may be signed by the chair or by any Board member if he or she did not vote against the action taken. Section 707.206 relates to audio recording of Board meetings. It specifies that the assistant to the secretary of the Board shall make audio recordings of meetings of the Board that are open to the public under the Texas Open Meetings Act. It also states that audio recordings will be made of closed sessions, except that no recordings will be made of private consultations with an attorney. Section 707.207 concerns minutes taken in meetings of the Board and states some requirements concerning such minutes. Section 707.208 pertains to instances in which an evidentiary hearing is held before the Board. It specifies that in such cases, the procedures of subchapter G of Chapter 707, 31 TAC, shall apply.

Subchapter D consists of fifteen sections (§§707.301-.315) and states requirements to file various applications and registrations in order to conduct certain activities related to the withdrawal of water from the Edwards Aquifer. These sections seek to establish clear requirements regarding which activities require the filing of an application or a registration with the Authority.

Section 707.301 states that subchapter D applies to any application or registration filed with the Authority. Section 707.302 states the basic requirement that any person who wishes to obtain a permit, authorization, or other approval from the Authority must submit a written application to the Authority on a form provided by the general manager. The Authority believes that the use of forms created and furnished by the Authority is necessary for the efficient processing of various applications and registrations and for the efficient administration of the Authority's permitting, registration and other programs.

Section 707.303 relates to who the Authority considers to be the proper applicant, registrant, or declarant in situations where a well has one owner. Many wells in the Edwards Aquifer region are owned by more than one person. This rule clarifies the responsibility of joint well owners and specifies that where a well has more than one owner, the owners shall select one among them to act for and represent the others in the filing the application, registration or declaration.

Section 707.304 states the general rule that any person seeking to withdraw groundwater from the Edwards Aquifer must file an application for a groundwater withdrawal permit. This section essentially reflects a requirement stated in §1.15(b) of the Act. It also makes clear that no such application must be filed if the well is exempt from the permit requirement by §1.16(c) and §1.33 of the Act and §711.20 of the Authority's rules.

Section 707.305 pertains to the requirement to file an application for a well construction permit and provides that a person seeking to perform one of the activities mentioned in §711.12(2)-(5) of the Authority's rules must file such an application. As with §707.304, this section essentially reflects a requirement stated in §1.15(b) of the Act.

Section 707.306 pertains to the requirement to register a well and provides that an owner of an existing well or an exempt well must register the well. It also states that well registrations must be filed no later than 180 days from the effective date of the Chapter 707 rules. It is through this requirement that the Authority can keep track of and manage all points of withdrawal of groundwater from the Edwards Aquifer. Section 1.15(a) of the Act requires the Authority to manage all withdrawal points from the Edwards Aquifer. Moreover, §1.33(b) of the Act requires the registration of all exempt wells. This section helps to implement these statutory requirements.

Section 707.307 concerns the effect of registrations filed before the effective date of the Chapter 707 rules. It provides that owners of wells that were registered with the Authority prior to the effective date of these rules need not file another well registration. This section avoids unnecessary duplication of work on the part of those regulated by the Authority.

Section 707.308 pertains to the requirement to file an application for exempt well status. It states that an owner of an existing or proposed well that the owner believes to be exempt from the requirements to obtain a permit, and who wishes to withdraw groundwater from that well, must file such an application. It also provides that an owner of a permitted well who wishes to convert that well to one with exempt well status must file such an application. This section helps to implement §1.16(c) and §1.33 of the Act which exempt certain well owners from permitting and metering requirements. It is through the requirement stated in this section that the Authority can assess and, where appropriate, validate, a person's claim that a well is exempt from permitting and metering requirements under these sections of the Act.

Section 707.309 pertains to the requirement to file an application for a permit to install or modify a meter. It states that a person seeking to install a new meter or modify an existing meter must file such an application with the Authority. It also provides that a person seeking to employ an alternative measuring method or modify an existing alternative measuring method must file such an application. Section 707.310 pertains to the requirement to register a meter. It states that an owner of an existing well equipped with a meter or alternative measuring method must register the meter or alternative measuring method. It also requires that meter registrations be filed with the Authority no later than 180 days from the effective date of the Chapter 707 rules. The Authority is directed by the Legislature, in §1.11(b) of the Act, to ensure compliance with metering requirements. Meters are an essential way that the Authority monitors groundwater withdrawals from the Edwards Aquifer. Such information is necessary for the implementation of many of the Authority's statutorily-mandated programs. Information derived from meters is also necessary to determine compliance with limitations on withdrawal, including permitted amounts. Information from meters may also be necessary for the assessment of fees under §1.29 of the Act.

Section 707.311 concerns the requirement to file a declaration of historical use. It states that for each well from which groundwater from the aquifer has been withdrawn and placed to beneficial use during the historical period, a declaration of historical use must have been filed by December 30, 1996. This section helps to implement §1.16 of the Act. The deadline stated in this section is required under §1.16(b) of the Act as modified by the opinion of the Texas Supreme Court in Barshop v. Medina County Underground Water District, 925 S.W.2d 618, 628-630 (Tex. 1996). This section also states that an owner of a well that is exempt from the requirement to obtain a groundwater withdrawal permit is not under a requirement to file a declaration of historical use. This provision helps to implement §1.15(b) and §1.33 of the Act.

Section 707.312 pertains to declarations of historical use received before the effective date of Chapter 707 and provides that such declarations need not be resubmitted. This provision avoids unnecessary duplication of work on the part of those seeking initial regular permits from the Authority.

Section 707.313 pertains to the requirement to file an application for a monitoring well permit and provides that a person seeking to perform one of the activities mentioned in §711.12(3) of the Authority's rules must file such an application. Monitoring wells are a potential conduit for contamination of the aquifer. This requirement allows the Authority to regulate and control such devices.

Section 707.314 pertains to the requirement to file an application for an aquifer recharge and storage permit and provides that a person seeking to perform one of the activities mentioned in §711.12(7) of the Authority's rules must file such an application.

Section 707.315 pertains to the requirement to file an application for a recharge recovery permit and provides that any person seeking to perform one of the activities mentioned in §711.12(8) of the Authority's rules must file such an application. Under §1.08 of the Act, the Authority may take actions to increase the recharge of the aquifer. Under §1.11(f) and §1.44, the Authority may enter into contracts with persons and political subdivisions to construct or operate a recharge facility. By this section, the Authority initiates a mechanism to allow it to regulate such activities.

Subchapter E consists of twenty-six sections (§§707.401-.428) and sets forth, with particularity, the required contents of various applications and registrations to be filed with the Authority. These sections will put persons subject to regulation by the Authority on notice as to the Authority's information requirements.

Essentially, the sections in subchapter E list the information that the Authority has determined is necessary for its review and processing of various types of registrations and applications. Section 707.401 lists the contents of and requirements for all applications and registrations. The remaining sections in subchapter E each list the required additional contents for particular types of applications or registrations. In addition to requiring information necessary for the review and processing of applications and registration, some of these requirements are intended to help the Authority to obtain information that the Authority needs in order to effectively manage, conserve and protect the Aquifer and to implement its statutorily-mandated programs.

The sections of subchapter E set forth informational requirements. They do not establish the substantive criteria that will be applied to each type of registration and application. Substantive criteria that apply to each type of permit or registration are to be found elsewhere in the Authority's rules. To a large extent, the required contents reflect the substantive criteria that will be applied to each type of application and registration. However, oftentimes, they are not an exact match. As noted above, some of the information may be necessary, not for the review of that application or registration, but to satisfy other informational needs of the Authority.

Section 707.401 provides general requirements concerning the contents of and requirements for all applications and registrations filed with the Authority. It requires that all applications and registrations be typewritten or printed legibly in ink. It also states that each application and registration shall include: the full name, post office address, and telephone number of applicant or registrant; the signature of the applicant or registrant; and an attestation. The section also states additional requirements pertaining to the name and signature of the applicant or registrant, depending upon the type of entity. This section helps to assure that the Authority will be able to process all applications and registrations and can contact the applicant or registrant. It also helps to establish clarity with regard to the person responsible for each application and registration and the statements contained therein.

Section 707.402 states that applicants and registrants are encouraged to confer with the Authority staff on any questions concerning the preparation of an application or registration. This section makes it clear that the Authority does not believe that applicants and registrants are expected to work in isolation from the Authority. Rather Authority staff is available to persons throughout the application or registration process.

Section 707.403 pertains to application fees to be charged by the Authority and requires that a non-refundable application fee of $25 accompany all applications other than an application for an agricultural conservation loan. The basis for this fee is found in §1.29(f) of the Act and the $25 amount is necessary to offset some of the Authority's administrative costs incurred in the processing of applications. Section 707.403 also requires a non-refundable application fee of $250 to accompany an application for an agricultural conservation loan. The basis for this fee is found in §17.896(c) of the Texas Water Code and Title 31, Texas Administrative Code, §367.44(e). The $250 amount is to cover administration of the conservation loan program and to establish and maintain a default reserve account. The amount was established in a loan agreement between the Authority and the Texas Water Development Board.

Section 707.404 concerns registration fees to be charged by the Authority and requires that a $10 registration fee accompany all registrations filed with the Authority. The basis for this fee is found in §1.29(g) of the Act and the $10 amount is necessary to offset some of the Authority's administrative costs incurred in the processing of registrations.

Section 707.405 list the required contents for applications for initial regular permit (that are in addition to the information specified in §707.401). The Authority is directed by §1.16 of the Act to issue initial regular permits to certain "existing users" of the Edwards Aquifer groundwater. The required contents of such applications are: the name and address of the well owner; the source of groundwater supply; the rate of withdrawal; the method of withdrawal; and a declaration of historical use. This section also specifies the required contents of a declaration of historical use. The declaration must contain: the total amount of water beneficially used during each calendar year of the historical period; the maximum number of acres irrigated during any one calendar year of the historical period; the purpose for which the groundwater was used during each year of the historical period; the amount of groundwater claimed as the maximum beneficial use during any one calendar year of the historical period; the number and location of each well owned by the applicant for which the applicant claims withdrawals during the historical period; and the place of use of groundwater withdrawn from each well. If the groundwater was withdrawn or used by a contract user or a prior or former existing user, the name, address, and telephone number of each contract user or prior or former existing user must be provided. If the applicant requests equitable adjustment on the grounds that the applicant's use was affected by a requirement of or participation in a federal program, then any fact upon which such a request is made must be stated. If the groundwater is to be sold on a wholesale or bulk basis, the declaration of historical use must also contain a description of how it will be sold, transported or transferred and the name, address, and telephone number of every person to whom it will be delivered, the location to which it will be delivered, and the purpose for which it will be used. This information is necessary to allow the Authority or a party protesting a proposed permit to investigate and verify an applicant's claims regarding the historical use of a contract user, prior user or former existing user.

The list of the required contents of an application for an initial regular permit provided in §707.405 will assist the Authority in obtaining the information necessary for it to assess a claim to an initial regular permit. This provision will also help the Authority to obtain other valuable information needed to manage all points of withdrawal from the Edwards Aquifer and to accomplish its other various duties to manage, conserve, preserve, and protect the Aquifer and to prevent waste or pollution of water in the Edwards Aquifer.

Section 707.406 concerns applications for additional regular permits and lists the required contents for such applications (that are in addition to the information specified in §707.401). Section 1.18 of the Act allows the Authority to issue additional regular permits following the issuance of initial regular permits, to the extent water is available for permitting. The required contents of an application for such a permit are: the name and address of the well owner; the source of groundwater supply; the proposed amount of withdrawal; the proposed purpose of use; the proposed maximum rate of withdrawal; the proposed method of withdrawal; the proposed place of use; a legal description of the location of each well; a map showing the location of each well; a water conservation plan; a water reuse plan; a description of the meter to be used; a list of all other permits applied for or issued by the Authority to the applicant; and any other information as may be required by the general manager. The list of the required contents of an application for an additional regular permit provided in §707.406 will assist the Authority in obtaining the information necessary for it to assess a claim to such a permit.

Section 707.407 concerns applications for term permits and lists the required contents for such applications (that are in addition to the information specified in §707.401). Section 1.19 of the Act allows the Authority to issue interruptible term permits for withdrawal of groundwater. The required contents of applications for such a permit are: the name and address of the well owner; the source of groundwater supply; the proposed amount of withdrawal; the proposed purpose of use; the proposed maximum rate of withdrawal; the proposed method of withdrawal; the proposed place of use; a legal description of the location of each well; a map showing the location of each well; a water conservation plan; a water reuse plan; a description of the meter; a list of all other permits applied for or issued by the Authority to the applicant; and any other information as may be required by the general manager. The list of the required contents of an application for a term permit provided in §707.407 will assist the Authority in obtaining the information necessary for it to assess a claim to such a permit.

Section 707.408 concerns applications for emergency permits and lists the required contents for such applications (that are in addition to the information specified in §707.401). Section 1.20 of the Act allows the Authority to issue emergency permits only to prevent the loss of life or to prevent a severe, imminent threat to public health and safety. The required contents of an application for such a permit are: the name and address of the well owner; the source of groundwater supply; the proposed amount of withdrawal; the proposed purpose of use; the proposed maximum rate of withdrawal; the proposed method of withdrawal; the proposed place of use; a reasonably clear description of the location of each well; a list of all other permits applied for or issued by the Authority to the applicant; the basis for the issuance of an emergency permit; and any other information as may be required by the general manager. The list of the required contents of an application for an emergency permit provided in §707.408 will assist the Authority in obtaining the information necessary for it to assess a claim to such a permit.

Section 707.409 concerns applications to renew emergency permits. Section 1.20(c) of the Act allows the Authority to renew emergency permits when appropriate. Under §707.409, such an application must contain the information specified in §707.408. It also states that such an application must be filed before the existing emergency permit has expired. The list of the required contents of an application to renew an emergency permit provided in §707.409 will assist the Authority in obtaining the information necessary for it to assess a claim to such a permit.

Section 707.410 concerns well registrations and lists the required contents for such registrations (that are in addition to the information specified in §707.401). Section 1.15(a) of the Act requires the Authority to manage all withdrawal points from the Edwards Aquifer. Moreover, §1.33(b) of the Act requires the registration of all exempt wells. Taken together, these provisions allow the Authority to impose a registration requirement on all wells. The required contents of such a registration are: the name and address of the well owner; a legal description of the location of the well; a map showing the location of the well, the three nearest wells within a quarter mile of the well, and any possible sources of contamination; the purpose of use; the amount of withdrawal; the maximum rate of withdrawal; the depth of the well; the size of the pump and pumping method; the date of construction; a list of all other permits applied for or issued by the Authority to the applicant; and any other information as may be required by the general manager.

The Authority has developed the list of items required in a well registration in order to provide the Authority with necessary baseline information. These required contents will allow the Authority to obtain valuable information needed to manage all points of withdrawal from the Edwards Aquifer and to accomplish its other various duties to manage, conserve, preserve, and protect the Aquifer and to prevent waste or pollution of water in the Edwards Aquifer. For example, the requirement for registrants to include a map showing, among other things, any possible sources of contamination is one of the primary ways in which the Authority is able to gather information on potential sources of contamination of the aquifer. It is through such well registrations that the Authority collects information that is vital to the development and implementation of a variety of its statutorily-mandated programs.

Section 707.411 concerns applications for a well construction permits and lists the required contents for such applications (that are in addition to the information specified in §707.401). Section 1.15(b) of the Act directs the Authority to regulate new well construction through a well construction permit program. The required contents of an application for such a permit are: the name and address of the owner of the proposed well; a legal description of the location of the proposed well; a map showing the location of the proposed well, the three nearest wells within a quarter mile of the proposed well, and any possible sources of contamination within 500 feet of the well; the proposed purpose of use; the amount proposed to be withdrawn; the proposed maximum rate of withdrawal; the proposed depth of the well; the size of the pump and pumping method; the approximate date that construction will begin; the identity of the well drilling contractor; a list of all other permits applied for or issued by the Authority to the applicant; the claimed legal basis under which groundwater will be withdrawn; and any other information as may be required by the general manager. The list of the required contents of an application for a well construction permit provided in §707.411 will assist the Authority in obtaining the information necessary for it to assess a person's right to construct a well. This provision will also help the Authority to obtain other valuable information needed to manage all points of withdrawal from the Edwards Aquifer and to accomplish its other various duties to manage, conserve, preserve, and protect the Aquifer and to prevent waste or pollution of water in the Edwards Aquifer.

Section 707.412 concerns meter registrations and lists the required contents for such registrations (that are in addition to the information specified in §707.401). The Authority is directed by the Legislature, in §1.11(b) of the Act, to ensure compliance with metering requirements. The required contents for meter registrations are: the name and address of the well owner; a legal description of the location of the well on which the meter is located; a map showing the location of the well; whether or not the well is an exempt well or a permitted well; the purpose of use of the water withdrawn from the well; a description of the meter; the date that the meter was installed; and any other information as may be required by the general manager. In addition, the rule lists the specific elements to be included in the description of the meter. It is through the required contents of meter registrations and through meters that the Authority collects information that allows it to monitor the withdrawal of groundwater from the aquifer as well as compliance with substantive meter requirements, withdrawal limitations derived from the Act, the Authority's rules, or stated in a groundwater withdrawal permit, and to assess certain fees based on usage.

Section 707.413 concerns applications for a permit to install or modify a meter and lists the required contents for such applications (that are in addition to the information specified in §707.401). The Authority is directed by the Legislature, in §1.11(b) of the Act, to ensure compliance with metering requirements. The required contents of such applications are: the name and address of the owner of the well on which the meter is proposed to be installed; a legal description of the location of the well; a map showing the location of the well; whether or not the well is an exempt well or a permitted well; the purpose of use of the water withdrawn from the well; a description of the meter; and any other information as may be required by the general manager. In addition, the rule lists the specific elements to be included in the description of the meter. It is through the required contents of this application and the meters themselves that the Authority collects information that allows it to monitor the withdrawal of groundwater from the aquifer as well as compliance with substantive meter requirements, withdrawal limitations derived from the Act, the Authority's rules, or stated in a groundwater withdrawal permit, and to assess certain fees based on usage.

Section 707.414 concerns applications to transfer interim authorization status and to amend an application for an initial regular permit and lists the required contents for such applications (that are in addition to the information specified in §707.401). The required contents of such applications are: the names and addresses of the person who seeks to transfer his or her interim status and of the person to whom that status is proposed to be transferred; legal descriptions of the locations of the two wells; the purpose of use for the well that has current interim authorization status and the proposed purpose of use for the well to which the transfer is proposed; the amount of groundwater proposed to be withdrawn at the well to which the transfer is proposed; the place of use of the water withdrawn from the well under interim status and the proposed place of use for the water withdrawn from the well to which the transfer is proposed; the period of time for which the transfer is proposed; a copy of the transfer agreement; the price per acre-foot or other consideration; and any other information as may be required by the general manager.

Section 707.415 concerns applications to transfer and amend a permit and lists the required contents for such applications (that are in addition to the information specified in §707.401). Those required contents of such applications are: the names and addresses of the person who seeks to transfer his or her permitted rights and person to whom those rights are proposed to be transferred; legal descriptions of the locations of the two wells; the purpose of use for the currently permitted well and the proposed purpose of use for the well to which the transfer is proposed; the amount of groundwater proposed to be withdrawn at the well to which the transfer is proposed; the place of use of the water withdrawn from the permitted well and the proposed place of use for the water withdrawn from the well to which the transfer is proposed; the period of time for which the transfer is proposed; a copy of the transfer agreement; the price per acre-foot or other consideration; and any other information as may be required by the general manager.

Section 1.34 of the Act governs the ability of permit applicants or permit holders to transfer their rights. However, only certain types of transfers are allowed by §1.34. It is through the required contents of an application to transfer interim authorization status and to amend an application for an initial regular permit (§707.414) or an application to transfer and amend a permit (§707.415) that the Authority can assess whether a particular proposed transfer is allowed and approve or disapprove the proposed transfer. With particular reference to the requirement that such applications include the price per acre-foot for the water right purchased, such information is of great value to the Authority. Specifically, the Authority may be required to pay market prices for the purchase, proportional adjustment, or "buy down" of water rights. The Authority must have the means to determine the market prices of groundwater withdrawal rights within the Edwards Aquifer region. Requiring the inclusion of prices in applications allows the Authority to develop such information. However, the Authority realizes that some transfers may not involve a true price (e.g., a gift) and will therefore allow an application for a transfer of water rights to indicate other consideration given, in appropriate circumstances.

Section 707.416 concerns applications for exempt well status and lists the required contents for such applications (that are in addition to the information specified in §707.401). Sections 1.16(c) and 1.33 of the Act exempt certain well owners from permitting and metering requirements. The required contents of such applications are: the name and address of the owner of the well (or proposed well); a legal description of the location of the well; a map showing the location of each well; the purpose of use; the maximum amount of withdrawal per day; the maximum rate of withdrawal; the depth of the well; the size of the pump and pumping method; the approximate date of well construction; a list of all other permits applied for or issued by the Authority to the applicant; a statement as to whether the well is within a subdivision requiring platting; a statement as to whether the well serves a subdivision requiring platting; and any other information as may be required by the general manager. The list of the required contents of an application for exempt well status provided in §707.416 will assist the Authority in obtaining the information necessary for it to assess a person's claim of exemption from permitting and metering requirements.

Section 707.417 pertains to applications for well monitoring permits and lists the required contents for such applications (that are in addition to the information specified in §707.401). Those required contents are: the name and address of the well owner; a legal description of the location of the well; a map showing the location of the well; a statement of the purpose of the monitoring well; a description of the method to be used to measure water depth or quality; the amount of water to be withdrawn per annum; the depth of the well; and any other information as may be required by the general manager. This provision will help the Authority regulate and keep track monitoring wells which are potential conduits of contamination of the aquifer and will thus help the Authority to prevent pollution of water in the aquifer.

Section 707.422 pertains to applications for agricultural conservation loans and lists the required contents for such applications (that are in addition to the information specified in §707.401). Section 1.11(d)(1) of the Act empowers the Authority to issue and administer grants, loans, or other financial assistance to water users for water conservation and water reuse. Section 1.24(c) of the Act allows the Authority to issue grants or make loans to finance the purchase or installation of equipment or facilities for water conservation. The required contents of such applications are: the name and address of the well owner; the tax identification or social security number of the applicant; a description of the intended use of the loan proceeds; a description of any item to be purchased; a legal description of the real property to be affected; any Authority permit application number; credit references; any invoice of items to be purchased with loan proceeds; if, for refinancing, a statement of the date that the equipment was purchased; a statement the applicant's consent and compliance meeting certain requirements; certain specified financial records; documents verifying the organization, existence and authority of the applicant; and any other information that may be required by the general manager. The list of the required contents of an application for an agricultural conservation loan provided in §707.422 will assist the Authority in obtaining the information necessary to assess whether a person is eligible for a agricultural conservation loan, whether the Authority can adequately protect its interests if it extends such a loan, and whether to extend such a loan.

Section 707.424 pertains to applications for a declaration of abandonment of a groundwater withdrawal permit and lists the required contents for such applications (that are in addition to the information specified in §707.401). Section 1.16(g) provides that an initial regular permit remains in effect until the permit is abandoned. The required contents of an application for declaration of abandonment of a groundwater withdrawal permit are: the name and address of the well owner; a description of the facts demonstrating non-use; a description of facts showing an intent to abandon; and any other information that may be required by the general manager. The list of the required contents provided in §707.424 will assist the Authority in obtaining the information necessary for it to determine whether a groundwater withdrawal permit should be abandoned.

Section 707.426 pertains to applications to cancel a groundwater withdrawal permit and lists the required contents for such applications (that are in addition to the information specified in §707.401). Section 1.16(g) provides that an initial regular permit remains in effect until the permit is cancelled. The required contents of an application to cancel a groundwater withdrawal permit are: the name and address of the well owner; a description of the facts demonstrating non-use; and any other information that may be required by the general manager. The list of the required contents provided in §707.426 will assist the Authority in obtaining the information necessary for it to determine whether a groundwater withdrawal permit should be cancelled.

Section 707.428 pertains to applications to convert base irrigation groundwater and lists the required contents for such applications (that are in addition to the information specified in §707.401). Section 1.34(c) of the Act places limits on the transfer of a portion of a permit holder's groundwater withdrawal rights where such rights are based on irrigation use. However, under circumstances described in Chapter 711, subchapter L, of the Authority's rules, the Authority has determined that such limitations can be removed through the "conversion of base irrigation groundwater." The required contents of an application to convert base irrigation groundwater are: the name and address of the well owner; and, if the application is based in physical impossibility, a description of all facts demonstrating physical impossibility. If the application is based on conservation, additional contents are required. The list of the required contents provided in §707.428 will assist the Authority in obtaining the information necessary for it to assess whether a permit holder should be allowed to convert base irrigation groundwater and thus remove the limitations on transfer.

Generally speaking, many of the sections listing the required contents of types of applications and registrations include a provision requiring: "any other information that the general manager may require." (See §§707.405(5)(K), 707.406(14), 707.407.15, 707.408(10), 707.410(10), 707.411(13), 707.412(8), 707.413(7), 707.414(9), 707.415(14), 707.416(14), 707.417(8), 707.422(13), 707.424(4), 707.426(3), 707.428(3)(O). The basis for this language lies in the need for flexibility in the review and processing of applications and the registrations by the Authority. The Authority, acting through its general manager, will need to exercise such flexibility. The processing and review of many applications and registrations will be straight-forward, presenting a generic and well-defined set of issues to be examined. Other applications and registrations, however, will be unique and will present special issues and raise questions that are particular to that application or registration. These provisions, allowing the general manager to require "other information," included in the sections listing the required contents of each type of application and registration, provides the Authority with some flexibility in dealing with unique applications and registrations.

Subchapter F consists of nineteen sections (§§707.501-.519) and sets forth the procedures to be used by the Authority when processing and taking action on various applications and registrations filed with the Authority. The intent of this subchapter is to provide well-defined procedures and time-frames regarding the processing of applications and registrations. Also, many of the provision in subchapter F aim to ensure that permit decisions are reached through an unbiased method, are sound, and well-explained to the public. Some provisions in this subchapter also help to promote administrative efficiency.

Section 707.501 concerns the Authority's initial action on applications and registrations and provides that all applications and registrations shall be stamped or marked "Received" by the docket clerk with the date of receipt clearly indicated. This section establishes consistency in connection with the receipt of applications and registrations by the Authority and ensure that accurate records are kept regarding the date on which an application or registration is received.

Section 707.502 concerns the Authority's initial review of applications and registrations for administrative completeness. It provides that such review shall generally be completed within 45 business days of the receipt of the application or registration and payment of applicable fees. The Authority believes that this time frame provides sufficient time for staff to conduct such a review and ensures that the permit process moves along at a reasonable pace. Further, in connection with applications for emergency permits, the rule provides that such review shall be conducted within ten business days. This shortened time frame reflects the urgent need that a successful applicant for an emergency permit might have. The rule also states the basic criteria that shall be used in conducting such a review and provides that upon completion of this review, the general manager shall notify the applicant and forward the registration or application to the docket clerk with a request that it be filed.

Section 707.503 concerns the general manager's return of applications and registrations that are deemed to be not administratively complete. It provides procedures to be followed by the general manager in such circumstances and provides procedures to be followed to allow an applicant to correct deficiencies. This rule assures that an applicant or registrant will receive appropriate notice where an application or registration is not complete and allows for the efficient correction of deficiencies.

Section 707.504 concerns the technical review of applications by the Authority. It provides procedures to be followed by Authority staff in conducting such review. In particular, it generally directs Authority staff to complete such review within 90 business days of the determination that an application is administratively complete. The Authority believes that this time frame provides sufficient time for staff to conduct such a review and ensures that the permit process moves along at a reasonable pace. It also provides procedural requirements regarding the providing of additional material that may be necessary for technical review. These requirements create a mechanism whereby applications may be efficiently supplemented when appropriate. It also provides that the general manager or his designee may enter public or private property for the purpose of inspecting, investigating or verifying conditions or information submitted in connection with an application or a registration. This provision provides Authority staff with the means necessary to investigate and verify information provided in an application.

Section 707.505 governs changes to applications and registrations. It provides procedures governing when and how non-substantive and substantive changes may be made to applications and registrations. This section allows for appropriate non-substantive changes to efficiently be made to applications. It also provides safeguards to ensure that substantive changes will be made only when directed by the applicant.

Section 707.506 pertains to extensions of time to process applications and provides procedures to be followed where Authority staff determines that technical review of an application cannot be completed within the normal time period. This section provides flexibility to allow Authority staff extra time, where appropriate, to complete their technical review.

Section 707.507 applies to all applications for groundwater withdrawal permits and provides procedures regarding the proposed permit and technical summary to be prepared by the general manager, including the providing of notice to the applicant. This section also directs the general manager to prepare a proposed permit. It thus assures that the applicant is notified of the terms of the permit proposed by the general manager and the basis for those terms. This section also provides procedures regarding the filing of a proposed permit with the docket clerk and its presentation to the Board and provides procedures applicable where the general manager recommends to deny an application. It also provides procedures regarding the technical summary and lists the appropriate contents of the technical summary. If the application is for an initial regular permit, the proposed rule specifies that the general manager shall issue the proposed permit or denial and technical summary within 90 days of the effective date of these rules. The Authority believes that this time frame provides sufficient time for the general manager to propose actions on permit applications and ensures that the permit process moves along at a reasonable pace.

Section 707.508 applies to all applications other than applications for groundwater withdrawal permits and provides procedures regarding the proposed approval and technical summary to be prepared by the general manager, including the providing of notice to the applicant. It directs the general manager to prepare a proposed permit unless the general manager recommends to deny the application. It provides procedures regarding the filing of a proposed approval with the docket clerk and its presentation to the Board. This section also provides procedures applicable where the general manager recommends to deny an approval. It also provides procedures regarding the technical summary and lists the contents of the technical summary.

Section 707.509 concerns the referral to docket clerk of a proposed permit, approval, authorization or denial, and technical summary. It provides that when administrative and technical review is complete, the completed appropriate documents shall be forwarded to the docket clerk for presentation to the Authority for action and publication, if appropriate. This section assures that actions on permits and other approvals are all channeled through a central office - that of the docket clerk - so that they can be presented to the board for final action in a organized and methodical manner.

Section 707.510 concerns the publication of a notice of the proposed permit and technical summary in the Texas Register and in local newspapers. It applies only to only to those types of applications that the Authority has determined are subject to contested case hearings. Those types are: (1) applications for initial regular permits; (2) applications for additional regular permits; (3) applications for term permits; (4) applications for aquifer recharge and storage permits; (5) applications for recharge recovery permits; (6) applications to transfer interim authorization status and amend application for initial regular permit where the location of the point of withdrawal is transferred from west of Cibolo Creek to east of Cibolo Creek; and (7) applications to transfer and amend permit where the location of the point of withdrawal is transferred from west of Cibolo Creek to east of Cibolo Creek. This section provides procedures for the publication of a proposed permit, approval, authorization or denial, and technical summary in the Texas Register and in local newspapers. It requires that such notice be published no later than 30 days following the referral of the proposed permit, approval, authorization or denial to the docket clerk. It also states the required contents of such notice. This section assures that interested parties are provided with sufficient notice of the terms of a proposed permit or denial and the general manager's basis for his proposed action on applications for which a contested case hearing may be requested within a reasonable time. This section also requires that the notice include information regarding the opportunity to file a request for a contest case hearing.

Section 707.511 concerns the supplementation of an application required by a change in any of the Authority's rules. It provides that if any pending application is affected by a change in rules before final action on the application is taken, the applicant shall have a right to submit information as necessary to comply with such change. This section assures that applicants are not prejudiced by any change in Authority rules regarding the contents or requirements of an application or the criteria for the granting of a permit.

Section 707.512 governs the withdrawal of an application by an applicant and provides procedures pertaining to the withdrawal of an application both with and without prejudice. This section provides definite procedures regarding the withdrawal of applications. The purpose of this rule is to allow an applicant to efficiently withdraw and application "with prejudice" while discouraging applicants from consecutively filing and withdrawing applications "without prejudice" thus increasing administrative burdens on the agency. It should be noted that because applications for initial regular permits must have all been on file by December 30, 1996, an application for initial regular permit cannot be effectively withdrawn "without prejudice."

Section 707.513 governs action by the Board on applications where there the Authority has determined there is no right to a contested case hearing. The Board takes final action on the following applications where there is no right to a contested case hearing: (1) an application for an agricultural conservation loan; (2) an application for a variance from the comprehensive management plan; (3) a decision of the Board regarding loss of exempt well status; (4) the denial of an applications for a well construction permit; (5) the denial of an application for exempt well status; (6) the denial of any application to install or modify meter or alternative measuring method; (7) the denial of an application to transfer interim authorization status and amend application for initial regular permit except where the location of the point of withdrawal is to be transferred from west of Cibolo Creek to east of Cibolo Creek; (8) the denial of any application to transfer and amend permit except where the location of the point of withdrawal is to be transferred from west of Cibolo Creek to east of Cibolo Creek. The section provides procedures for: the scheduling of a Board meeting following technical review and the referral of the proposed permit, approval, authorization or denial to the docket clerk; notice of such a Board meeting; the consolidation or severance of matters by the Board; oral presentations before the Board; public comment; and Board action. This section provides relatively streamlined procedures for decisions which, although they are important, do not have the potential to affect all users of the aquifer.

Section 707.514 governs action by the Board on applications where there is a right to a contested case hearing but none were requested or requests were withdrawn. It applies to actions for which a contested case hearing may be requested but, where, after the time for the filing of a hearing request has passed, no timely hearing request has been received, all timely hearing requests have been withdrawn, or the judge has remanded the application because of settlement. It provides procedures for: the scheduling of a Board meeting following technical review and the referral of the proposed permit, approval, authorization or denial to the docket clerk; notice of such a Board meeting; the consolidation or severance of matters by the Board; oral presentations before the Board; public comment; and Board action. This section provides relatively streamlined procedures for decisions which although they could have been the subject of a contested case hearings, they are not opposed.

Section 707.515 concerns actions on applications by the general manager. Its purpose is to delegate authority to the general manager to take action on behalf of the Board to for certain listed actions. Under this section, the general manager may, under certain circumstances, grant: (1) applications for well construction permits; (2) applications for exempt well status; (3) applications for permit to install or modify meter or alternative measuring method; (4) applications to transfer interim authorization status and amend application for initial regular permit in all instances except when the location of the point of withdrawal is to be transferred from west of Cibolo Creek to east of Cibolo Creek; (5) applications to transfer and amend permit in all instances except when the location of the point of withdrawal is to be transferred from west of Cibolo Creek to east of Cibolo Creek; (6) applications for conservation plan approval; and (7) applications for reuse plan approval. It also provides procedures applicable in such instances. Through this section, the Authority has delegated to the general manager the authority to "handle administratively" the granting of these types of applications. This rule is meant to provide for the streamlined and efficient processing of applications that are not likely to be controversial or affect other users. By contrast, the Authority is not willing to delegate authority to the general manager to deny any of these types of permits or to act on any initial, term, recharge and emergency permits, and other permits which may affect the withdrawal rights of all other users.

Section 707.516 concerns corrections to permits by the general manager. It provides procedures regarding when and how the general manager may make non-substantive corrections to permits. This section allows for appropriate non-substantive changes to efficiently be made to permits. It also provides safeguards to ensure that only appropriate corrections are made.

Section 707.517 provides special procedures regarding the loss of exempt well status. It covers situations were the Authority receives information from a person other than the well owner indicating that the well no longer qualifies as an exempt well. It provides for notice and an opportunity for the well owner to provide information indicating to the general manager why exempt well status should not be cancelled. The purpose of §707.517 is to provide the general manager with a administrative fact-finding device. The general manager has no authority to withdraw exempt well status, only to place such a recommendation before the Board.

Section 707.518 provides special procedures regarding applications for emergency permits. It provides that where the general manager finds that the issuance of an emergency permit is warranted, the general manager shall issue that permit for a term not exceeding 30 days. This section provides for notice to the applicant and public comment and directs the general manager to submit the permit to the Board following public comment for ratification, recission, granting, renewal or modification. These expedited procedures are designed to ensure that emergency permits, when necessary, are granted as quickly as possible.

Section 707.519 establishes a moratorium on the processing of applications for additional regular permits until a final determination has been made on all applications for initial regular permits. This section recognizes the fact that cumulative maximum historical use during any one calendar year during the historical period for all applicants exceeds the amount that is legally available for permitting and, therefore, there will not be additional groundwater legally available for permitting in the near future.

Subchapter G consists of twenty-six sections (§§707.601-.626) and establishes procedures to be used by the Authority in connection with contested case hearings. These rules are meant to establish an efficient mechanism by which certain persons may challenge the claims to permitted withdrawal rights of other persons and for those rights to be determined in a quasi-judicial proceeding.

Section 707.601 defines the applicability of subchapter G, which concerns contested case hearings on Authority applications. Under this section, contested case hearings may be requested and granted in connection with applications for initial regular permits, additional regular permits, term permits, aquifer recharge and storage permits, and recharge recovery permits. Contested case hearings may also be requested and granted in connection with applications to transfer groundwater withdrawal rights where the transfer of the point of withdrawal is from west to east of Cibolo Creek.

The Authority has decided to allow the opportunity for contested case hearings in the situations noted above for the following reasons. All of these situations involve either: (1) a request by a well owner to be allocated a portion of the finite total amount of water that the Legislature has declared is available for permitting; (2) a request for a type of permit that could, when cumulated with other permits of that type, result in the over-appropriation of groundwater in the Edwards Aquifer; or (3) a request by a well owner, that could, when accumulated with other requests of that type, result in the concentration of permitted withdrawals in areas near Comal and San Marcos springs. Decisions in these situations have the potential to affect all other applicants or permittees. All other applicants may be affected by decisions in category (1) because to the extent that historical use is attributed to any given applicant, the cumulative amount of maximum historical use during any one calendar year for all applicants will be higher, resulting in an increased need to adjust all applicants' maximum historical use (or statutory minimums) downward in order to meet the Legislature's limit on the total amount of permitted withdrawals.

Applicants and permittees may be affected by category (2) because over-appropriation of groundwater may result in the triggering of aquifer management programs which include interruptions in withdrawal rights or other required reductions in withdrawals. Certain transfers of water rights - where the point of withdrawal is proposed to be transferred from west to east of Cibolo Creek - fall under category (3). Such transfers, accumulated over time, have the potential to result in the concentration of withdrawals near San Marcos and Comal Spring. Such concentration will likely result in decreased springflows triggering aquifer management measures that have the potential to negatively affect permitted withdrawal rights and cause required reductions in withdrawals throughout the region thus affecting all applicants and permittees.

The Authority has therefore determined that decisions implicating such considerations should be subjected to the opportunity for a contested case proceedings. Accordingly, for such decisions, applicants may be required to prove their entitlement to the permit or transfer at issue in a quasi-judicial proceeding. Those potentially affected parties (defined in §707.602) will have the right to request such a proceeding and, if that request is granted, will have the right to present evidence which would tend to refute or defeat the applicant's claim to the permit or transfer at issue. This system will assure greater accuracy in the Authority's issuance of important permits and permitted withdrawal amounts and a more fair apportionment of permitted rights.

This rule is also consistent with the recently proposed substantive rules (Chapter 711, Subchapter L) governing transfers of groundwater rights. Specifically, §711.352 imposes stringent criteria for the approval of transfers where the point of withdrawal of a right to withdraw groundwater is transferred from west to east of Cibolo Creek.

Section 707.602 states the classes of persons that are entitled to request a contested case hearing. The persons who are entitled to request a contested case hearing are: the applicant for that permit or approval; an applicant for another groundwater withdrawal permit issued by the Authority; and any permittee holding a groundwater withdrawal permit issued by the Authority.

The purpose of the Authority's procedures with respect to initial regular permits is to determine who has statutory-based rights to withdraw a portion of the 450,000 acre-feet of Edwards Aquifer groundwater initially available for permitting. Accordingly, the process of issuing initial regular permits is a process by which a finite amount of water (as determined by the Legislature) is allocated to various persons possessing statutory rights to some of that water. The Authority has determined that the individual decisions that make up this process should be subject to the possibility of a quasi-judicial proceeding which is in the nature of water rights adjudication. Persons who have an interest in that proceeding are the applicant for a particular permit at issue; any other applicant seeking an allocation of the finite amount and any permittee already provided with an allocation. By the nature of the proceeding, these are the only parties that could possibly have an interest in the proceeding. Anyone else is simply a bystander, with no real interest, because no part of the allocation of the total finite amount could conceivably go to that person. Thus, the Authority has determined that citizens, business entities, and groups that are not applicants or permittees do not have standing to request a contested case hearing.

Moreover, such proceedings involving applications for initial regular permits may have only incidental effects on downstream users, springflows, habitat and endangered species. The Authority has other programs which are primarily designed to advance these goals. Accordingly, the Authority is justified in determining that contested case hearings on initial regular permits and in other matters should not be a forum for persons and groups who are not applicants to argue their individual interest or their version of the public interest.

Section 707.603 concerns the required form and contents of a request for a contested case hearing. It provides that a request for a contested case hearing must be in writing and be filed by United States mail, facsimile, or hand-delivery with the docket clerk within the time specified in §707.604 of these rules. This rule helps to ensure that requests for contested case hearings submitted to the Authority are submitted in a regularized format that will allow the Authority to efficiently assess and act on such requests.

Section 707.604 concerns the time for the filing of a request for a contested case hearing. It provides that, unless a different time limit is specified in the notice of the proposed permit and technical summary, a hearing request must be filed with the docket clerk within 30 days of the date of publication of that notice in the Texas Register . The Authority believes that 30 days is sufficient time for a person to assess whether they wish to file a request for a contested case hearing, collect any information necessary to support their request, and complete and submit their request. The Authority also believes that this time frame helps move the permitting process along quickly.

Section 707.605 provides procedures applicable to the processing of a request for a contested case hearing by the Authority. It states that hearing requests not filed within the time period specified in §707.604 shall not be processed and shall be returned by the docket clerk to the person filing the request. This section also directs the docket clerk to provide notice to the applicant, general manager and any persons making a timely hearing request at least 30 days prior to the first meeting at which the Board considers the request. It also provides that persons may submit written responses to the hearing request no later than 20 days before a Board meeting at which the board will evaluate the hearing request. It also provides for the opportunity to file replies to those responses. The Authority must move the permitting process along and promote certainty in its decision-making process. Objective criteria and firm deadlines regarding when an eligible person must file a request for a contested case hearing and pleadings serve these goals. Moreover, the time frames regarding notice of the Board meeting in which a request will be considered allows parties sufficient time to prepare for such a meeting.

Section 707.606 governs action by the Board on a request for a contested case hearing. It specifies that the determination of whether a hearing request should be granted is not, in itself, a contested case subject to the APA. It provides procedures applicable to the Board's consideration of the hearing request and states that the Board may: (1) determine that the hearing request does not meet the requirements of this subchapter and deny the hearing request; (2) determine that the hearing request does not meet the requirements of this subchapter, deny the hearing request, and refer the application to a public meeting to develop public comment before acting on the application; or (3) determine that a hearing request meets the requirements of this subchapter and direct the docket clerk to refer the application to SOAH for a contested case hearing. It also provides that a request for a contested case hearing shall be granted if the request: (A) is supported by competent evidence; (B) is submitted by a person entitled to request under §707.602 of these rules; (C) complies with the requirements set forth in §707.603 of these rules; and (D) is timely filed with the docket clerk. This section sets forth the possible actions that the Board may take in response to a request for a contested case hearing. This section also provides procedural standards that the Board is to apply to requests for contested case hearings.

Section 707.607 concerns the service of documents filed in a contested case. It specifies that a person filing the document must serve a copy on all parties to the contested case including the general manager at or before the time that the request is filed. It also requires the inclusion of a certificate of service. This rule helps to assure that parties to a contested case receive copies of all relevant documents filed with the Authority by any other party to the contested case.

Section 707.608 delegates the authority to conduct contested case hearings to SOAH. It also specifies that as supplemented by subchapter G of Chapter 707, the applicable rules of practice and procedure of SOAH govern any contested case hearing of the Authority conducted by SOAH. SOAH is uniquely qualified in terms of experience and manpower to conduct contested case hearings on behalf of the Authority. Moreover, SOAH has developed an extensive set of procedural rules governing SOAH proceedings. The Authority expects that SOAH will conduct such hearings in a much more efficient and expeditious manner than if the Authority had decided to attempt to conduct such proceedings on its own.

Section 707.609 provides procedures to be followed when the Board refers a contested case to SOAH. It specifies that the Authority shall provide to the judge a list of issues to be addressed. It also states the Board may identify additional issues to be addressed, or may limit issues or areas to be addressed, at any time. This rule promotes the efficient use of SOAH's resources by helping to focus the SOAH judge on issues that are important in any given proceeding.

Section 707.610 concerns the designation of parties at contested case hearings. It confers party status on: (1) the general manager; (2) the applicant; (3) the person who requested the contested case hearing that was granted; and (4) an applicant for an initial regular permit who files a notice of party status under §707.626. The general manager, being the person who has proposed a particular decision on a permit application is necessarily party to a contested case proceeding regarding that proposal. Likewise, the applicant is a necessary party. In cases where the person requesting a contested case hearing on an application is not the applicant associated with that application, naturally, the person requesting the contested case should participate in the hearing that he or she initiated.

Subsection (d) of §707.610 provides that "an applicant for an initial regular permit who files a notice of party status pertaining to §707.626 . . . is a party in all contested case hearings for which notice has been given." The purpose of this provision, in conjunction with §707.626, is to reduce administrative burdens of he Authority and on applicants who would like to obtain party status in several contested case hearings.

Persons entitled to make use of this rule are must also be qualified to request a contested case hearing. Under §707.602, the categories of such persons are: the applicant for that permit or approval; an applicant for another groundwater withdrawal permit issued by the Authority; and any permittee holding a groundwater withdrawal permit issued by the Authority. As discussed in more detail with respect to §707.602, the Authority has determined that these categories of persons, by nature of their status, have an interest in all applications sufficient to justify party status in a contested case hearing. As a result of §707.602, any applicant for an initial regular permit has the right to request a contested case hearing on every application for an initial regular permit and may gain party status in every resulting contested case hearing.

Rather than require such a person to file a request for a contested case hearing with respect to every application in which that person is interested, thus incurring for himself and imposing upon the Authority potentially significant costs and administrative burdens, this mechanism allows a person with standing to participate as a party in several contested case hearings where that hearing had been requested by another person and granted by the Authority. Thus, this provision, in conjunction with proposed §707.626, reduces administrative burdens on both applicants and the Authority by allowing an applicant, through one filing, to request party status in several or all contested case hearings. Moreover, this provision will likely result in a decreased total number of requests for contested case filed with the Authority.

Section 707.611 concerns the burden of proof at contested case hearings and provides that the burden of proof is on the applicant to establish by convincing evidence that he is entitled to an application for a groundwater withdrawal permit. The basis for this rule is that the applicant is in the best position to possess or have available evidence to prove the elements necessary to allow him to receive a groundwater withdrawal permit. The absence of such a rule would likely lead to a multitude of unsubstantiated, unsupportable, and fraudulent claims to groundwater withdrawal permits.

Section 707.612 concerns subpoenas at contested case hearings. It provides procedures concerning such subpoenas and specifies that requests for such subpoenas shall be in writing and directed to the Authority. This rule comports with a SOAH procedural rule (see Title 1, Texas Administrative Code, §155.43(e)), that states that requests for subpoenas shall be directed to the referring agency

Section 707.613 concerns the remand of contested case hearings to the Board. It provides that at the request of the applicant, a SOAH judge may remand an application to the Board if all timely hearing requests have been withdrawn or denied or, if parties have been named, all parties to a contested case reach a settlement so that no facts or issues remain controverted. It also states procedures regarding such a remand. This rule allows for the efficient removal of matters from SOAH and their return to the Board of Directors in cases in which there is no fact-finding or other useful role for SOAH to play.

Section 707.614 concerns certified questions in contested case hearings. It provides that a SOAH judge may certify a question to the Authority at any time during a contested case hearing. It lists types of issues that are appropriate for certification. It also provides procedures to be followed where a question is certified. This rule allows for legal or policy questions that arise during a contested case hearing, which are appropriately addressed by the Board, to be referred by SOAH back to the Board.

Section 707.615 concerns proposals for decision in contested case hearings. It specifies that a proposal for decision submitted to the Authority by a SOAH judge shall, where appropriate, include any recommended changes to the permit originally proposed by the general manager. This rule promotes the efficient communication of the results of the SOAH judge's recommendation to the Board.

Section 707.616 allows a party to waive the right to review and comment upon the SOAH judge's proposal for decision. It requires such waiver to be either in writing or stated on the record at the hearing. This rule allows the process by which a SOAH recommendation is acted on by the Board to be expedited in appropriate situations.

Section 707.617 concerns pleadings following the submittal of a proposal for decision. It provides that exceptions or briefs may be filed within 20 days after the date of the judge's submittal of the proposal for decision. It also specifies that replies to such exceptions or briefs, if any, must be filed within 30 days after the date of the judge's submittal of the proposal for decision. These time frames are designed to allow parties to sufficient time to prepare and file briefs in connection with a proposal for decision while moving the permitting process along at a fairly quick pace.

Section 707.618 governs the scheduling of a meeting of the Board in connection with a proposal for decision. It provides procedures applicable to such scheduling, including notice to parties of the date of the meeting and deadlines for the filings of exceptions and replies. It allows the Board to consolidate related matters or sever issues in a proceeding under certain circumstances. This rule allows for the efficient and regular scheduling of proposals for decision for consideration by the Board.

Section 707.619 concerns oral presentations to the Board regarding contested cases. It provides that any party to the contested case hearing may make an oral presentation at the Board meeting in which the proposal for decision in that case is presented to the Board. It limits such presentations to 15 minutes each, excluding time for answering questions, unless the chair or the general counsel establishes other limitations. This rule establishes general requirements concerning oral presentations to the Board on contested case hearings designed to move the process along quickly. Presumably, parties would have had more time to present their views to the SOAH judge. Exceptions to these requirements can be made where appropriate.

Section 707.620 concerns the reopening of the record in connection with a contested case hearing. It states that the Board may order the judge to reopen the record for further proceedings on specific issues and provides procedure applicable to such an order. This rule provides needed flexibility to allow parties to present additional evidence in appropriate situations.

Section 707.621 concerns the decision rendered by the Board in connection with a contested case hearing. It specifies that the Board shall render its decision upon the expiration of 30 days or later following service of the judge's proposal for decision, unless the parties have waived review. This section also specifies the Board's decision will be rendered no more than 90 days after the date the proposal for decision is presented to the Board, unless the Board determines that there is good cause for continuing the proceeding. It also provides that the decision, if adverse to any party, shall include findings of fact and conclusions of law separately stated. These time frames will allow parties sufficient time to present additional argument to the Board and are intended to ensure that decisions will be made on a fairly expeditious basis.

Section 707.622 concerns motion for rehearing on decisions in contested case hearings. It provides that only a party to the contested case may file a motion for rehearing. It also specifies that a motion for rehearing is a prerequisite to appeal. The rule also provides procedures applicable to the filing of, response to, and the ruling on such a motion for rehearing. A motion for rehearing is due within 20 days after the date the party seeking to file the motion or his attorney is notified of the decision or order. The reply to that motion for rehearing is due 30 days after the date a party or his attorney is notified of the decision or order. The Authority believes that this rule provides sufficient time for the reply while moving the permitting process along at a fairly quick pace. These procedures allow parties undertake an effort to convince the Authority to change its decision and provides the Authority with an opportunity to correct any errors.

Section 707.623 declares that in the absence of a timely motion for rehearing, a decision or order of the board is final on the expiration of the period for filing a motion for rehearing. It also provides that if a party files a motion for rehearing, a decision or order of the board is final and appealable on the date of the order overruling the motion for rehearing or on the date the motion is overruled by operation of law. This rule helps to define when an order of the Authority on a permit following a contested case hearing become "final" or "final and appealable."

Section 707.624 concerns the right to appeal a final decision in a decision in a contested case hearing. It provides that a person who was a party to a contested case before the Authority and is affected by a final decision or order of the Authority in that case may file a petition for judicial review within 30 days after the decision or order is final and appealable. It provides that procedures for appealing an order of the Board in contested cases are governed by provisions of the APA governing judicial review of contested case decisions. For the purposes of such an appeal, this section also defines the items to be included in the record in a contested case.

Section 707.625 concerns the payment of costs for preparing the record on appeal. It provides that a party who appeals a final decision in a contested case shall pay all costs of preparation of the record and that such a charge is considered to be a court cost and may be assessed by the court in accordance with the Texas Rules of Civil Procedure. This rule will allow the Authority to offset some of the costs involved in preparing a record in contested case proceedings that are subjected to judicial review.

Section 707.626 relates to notice of party status. This section states that any applicant for an initial regular permit may obtain party status in any or all contested cases by filing the requisite notice. The section provides that the notice must be in writing and filed with the docket clerk within the time provided by §707.604. In addition, the section lists the information that must be contained in the notice.

As noted above, §707.626 acts in conjunction with subsection (d) of §707.610. The purpose of these provisions, as described in more detail above, is to reduce administrative burdens of he Authority and on applicants who would like to obtain party status in several contested case hearings.

III. REGULATORY IMPACT ANALYSIS OF MAJOR ENVIRONMENTAL RULES.

Section 2001.0225 of the APA requires an agency to perform, under certain circumstances, a regulatory analysis of "major environmental rules." The Authority has determined that none of the Chapter 707 rules, as adopted, are "major environmental rules" as that term defined by §2001.0225(g)(3) of the APA. The basis for this determination is that the rules do not have the specific intent to "protect the environment" or "reduce risks to human health from environmental exposure." The rules establish procedures to be followed in Authority proceedings. Specifically, these set forth procedures: (1) regarding the computation of time and the filing of documents; (2) governing meetings before the Board; (3) pertaining to the filing of applications and registrations with the Authority; (4) to be followed by the Authority with respect to the processing and review of such applications and registrations; and (5) regarding contested case hearings on applications. The specific intent of these procedural rules is to allow the Authority to efficiently implement its powers and duties. For this reason, we find that these rules do not have a specific intent to "protect the environment" or "reduce risks to human health from environmental exposure." Accordingly, we find that none of the rules are "major environmental rules" and that, therefore, no further analysis is required by §2001.0225 of the APA.

IV. SUMMARY OF PUBLIC COMMENTS.

Five public hearings were held on proposed chapter 707 and other rules proposed by the Authority on: Wednesday, August 9, 2000 at 6:00 p.m. at the Conference Center of the Edwards Aquifer Authority, 1615 N. St. Mary's Street, San Antonio, Texas; Tuesday, August 15, 2000 at 6:00 p.m. at the New Braunfels Civic Center, 380 S. Seguin Avenue, New Braunfels, Texas; August 17, 2000 at 6:00 p.m. at St. Paul's Lutheran Church, 1303 Avenue M, Hondo, Texas; Tuesday, August 22, 2000 at 6:00 p.m. at the Sgt. Willie De Leon Civic Center, 300 E. Main Street in Uvalde, Texas; and Thursday August 24, 2000 at the San Marcos Activities Center, 501 E. Hopkins, San Marcos, Texas. Oral comments on these rules were provided by John Brigman; Louis Obdyke; Tom Wassenich; and Dianne Wassenich. Written comments on these rules were provided by San Antonio Water System ("SAWS"); Vinson & Elkins ("V&E"); Roger & Marvin Verstuyft Farms ("Verstuyft Farms"); Earl & Brown ("Earl & Brown"); Bickerstaff, Heath, Smiley, Pollan, Kever & McDaniel, L.L.P. on behalf of the Texas Farm Board ("TFB"); Inland Ocean, Inc. ("Inland"); Fulbright & Jaworski on behalf of Vulcan Materials Company ("Vulcan"); the City Public Service Board of San Antonio ("CPS"); and the Texas Department of Agriculture ("TDA").

Comments regarding Chapter 707 generally

TFB asserts that the Authority was required by the Texas Private Real Property Rights Preservation Act to prepare a "takings impact assessment" or "TIA" before providing notice of the proposed adoption of the Chapter 707 rules.

The Authority disagrees with the commenter. Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act," ("TPRPRA") requires governmental entities, under certain circumstances, to prepare a takings impact assessment ("TIA") in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the adoption of these rules. First, the Authority has made a "categorical determination" that rules of practice and procedure do not affect private real property. These proposed rules establish and describe the procedures to be followed in Authority proceedings and before the Board of Directors of the Authority. More specifically, these provisions would set forth procedures: (1) regarding the computation of time and the filing of documents; (2) governing meetings before the board; (3) pertaining to the filing of applications and registrations with the Authority; (4) to be followed by the Authority in connection with the processing and review of such applications and registrations; and (5) regarding contested case hearings on applications. As such, they have no direct affect on private real property and may not result in a taking. Second, the Authority's action in adopting these rules is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from TPRPRA under §2007.003(b)(4) of the Texas Government Code. See Act §§1.08(a), 1.11(a), 1.11(b), 1.11(d)(1), 1.11(h), 1.15(a), 1.15(b), 1.15(c), 1.16(a), 1.16(b), 1.16(c), 1.16(d), 1.17(a), 1.17(b), 1.18, 1.19(a), 1.20, 1.24(c), 1.29(f), 1.29(g), 1.33(a), 1.33(b), and 1.34; Texas Government Code Annotated, §2001.004(1) (Vernon 2000). It was held, in Edwards Aquifer Authority v. Bragg, 21 S.W.3d. 375 (Tex. App. - San Antonio 2000, pet. filed), that the Act expressly mandates the adoption of substantive and procedural rules and that such actions are therefore excepted from the TPRPRA. The holding in that case controls here. Third, it is the position of the Authority that all valid actions of the Authority are excluded from the TPRPRA under §2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the adoption of these rules.

TDA comments generally that the Authority should have prepared a "small business effects statement" prior to proposing the adoption of the Chapter 707 rules, pursuant to §2006.002(d) of the Texas Government Code.

The Authority disagrees with the commenter for the following reason. Chapter 2006 of the Texas Government Code, subchapter A, requires state agencies to prepare a small business effects statement (SBES) prior to proposing a rule that would have an adverse economic effect on small businesses. By the statute's express terms, this requirement applies only to a "state agency." The term "state agency" is defined, for the purposes of Chapter 2006, subchapter A, as "a department, board, bureau, commission, division, office, council or other agency of the state." Texas Government Code Annotated, §2006.001(3).

Section 2006.002 does not apply to the Authority because the Authority does not meet the definition of the term "state agency" as set out forth in Chapter 2006. Section 1.02(a) of the Act creates the Authority as a "conservation and reclamation district" under Article XVI, §59 of the Texas Constitution. Conservation and reclamation districts created under this authority have long been considered to be "political subdivisions" of the State of Texas. See, e.g., Guaranty Petroleum , 609 S.W.2d at 530. In Guaranty Petroleum , the Texas Supreme Court explained the difference between political subdivisions and state agencies as follows:

A political subdivision differs from a department, board or agency of the State. A political subdivision has jurisdiction over a portion of the State; a department, board or agency of the State exercises its jurisdiction throughout the State. Members of the governing body of a political subdivision are elected in local elections or are appointed by locally elected officials; those who govern departments, boards or agencies of the State are elected in statewide elections or are appointed by State officials.

Guaranty Petroleum , 609 S.W.2d at 531 (emphasis added).

Guaranty Petroleum makes clear that state agencies are characterized by having statewide jurisdiction and are governed by persons who are elected in statewide elections or are appointed by state officials. Political subdivisions like the Authority, on the other hand, have jurisdiction over only a portion of the state and are governed by persons who are elected in local elections or are appointed by locally elected officials. These principles have been reiterated by the Texas Supreme Court in Lohec v. Galveston County Commissioners Court, 841 S.W.2d 361, 364 (Tex. 1992) (noting that "statewide jurisdiction" is "a trait required of entities recognized as department, boards, or agencies of the state") and Monsanto Company v. Cornerstones Municipal Utility District, 865 S.W.2d 937, 939-40 (Tex. 1993).

Because the Authority has jurisdiction over only a portion of the State and because the members of its governing body are elected in local elections or are appointed by locally elected officials, the Authority is a political subdivision and not a state agency, and is not subject to the SBES requirement found in Chapter 2006 of the Government Code.

Section 707.103(h)

Section 707.103 sets forth general procedures applicable to the filing of documents with the Authority. Subsection (h) states that "the Authority may waive one or more of the requirements of this section or impose additional filing requirements."

SAWS proposes changing §707.103(h) so that it reads:

(h) The Authority may waive one or more of the requirements of this section or impose additional filing requirements after notification of affected applicants or other interested parties.

The Authority disagrees with the commenter. The purpose of §707.103(h) is to allow the Authority some flexibility in the filing of documents. For example, subsection (d) of §707.103 requires that an original and one copy of all documents shall be filed. It may be appropriate, in some cases to waive this requirement without prior notification to "affected applicants or other interested parties." Likewise, for some particular types of filings, it may be appropriate to impose additional filing requirements. In such a case, the Authority has every intention of providing sufficient notice to persons who would be required to comply with that additional requirement. The Authority has no intention of imposing additional filing requirements with insufficient notice. In light of the above discussion, the Authority has not modified §707.103(h).

Section 707.103(c) and §707.104(b)

Section 707.103(b) concerns the filing of documents with the Authority. It provides that "if a person files a document by facsimile, he or she must file with the docket clerk the appropriate number of copies by mail or hand delivery within three days. " (Emphasis added.) Section 707.104(b) concerns the service of documents required to be filed under the Authority's rules. It provides that "service by facsimile must be followed by serving an extra copy in person, by mail or by carrier-receipted delivery within one day ." (Emphasis added.) SAWS suggests that for the sake of consistency, the time in which service by facsimile must be followed by serving an extra copy in person, by mail or by carrier receipted delivery be changed from one to three days.

The Authority disagrees with the commenter. This difference noted by SAWS finds its basis in the fact that the Authority's rule regarding the service of documents contains a "mailbox rule" (see §707.104(b) (stating that service by mail shall be complete upon deposit of the document, enclosed in a postage-paid properly addressed wrapper, in a post office of official depository under the case and custody of the United States Postal Service")) while the Authority's rule regarding the filing of documents contain no "mailbox rule." Accordingly, when §707.103(c) requires a party filing by facsimile to file a copy of the document by mail within three days, the docket clerk of the Authority must actually receive the document within three days. On the other hand, since service by mail is complete upon deposit with the U.S. Postal service, a party serving a document by facsimile may simply deposit a copy of the document already served by facsimile in the mail on the day following the day that service by facsimile is made. In light of the above discussion, the Authority has not modified §707.103(c) and §707.104(d).

Section 707.201(f)

Section 707.201 provides general information and procedures concerning meetings of the Board of Directors of the Authority. Subsection (f) of that section, as proposed, states as follows:

The Parliamentarian shall decide issues of parliamentary procedure, but may be overruled by majority vote of the board. The Parliamentarian is appointed to that position by the chair pursuant to the Bylaws of the Authority.

Inland comments that where the Parliamentarian is a director, such director should not vote in a matter where an issue regarding parliamentary procedure is at hand.

The Authority agrees, in part, and disagrees, in part, with the commenter. Under §707.201(f), as proposed, the Parliamentarian is always a director. The Authority disagrees with the commenter in that the Authority declines to relieve a voting director of his or her right to vote on any matter before the Authority. However, to avoid any conflict with Robert's Rules of Order in these rules, the Authority has modified §707.201(f) to allow for the appointment of a Parliamentarian who is not a director, as follows:

The Parliamentarian shall decide issues of parliamentary procedure, but may be overruled by majority vote of the board. The Parliamentarian is appointed to that position by the chair pursuant to the Bylaws of the Authority.

Section 707.203

Section 707.203 concerns the deadline for the filing of comments on matters set for a meeting of the Board. This section, as proposed, provides as follows:

The board or the general counsel may set deadlines for the public to file written comments on matters set for a meeting of the board. The general counsel, whether by agreement of the interest persons and any judge assigned to the matter, or the general counsel's own motion, may extend a filing deadline.

SAWS expresses concern over the general counsel alone making a determination as to such deadlines. SAWS maintains that in certain parts of the rules, the Board clearly delegates activities to the General Manager, but no such delegation to general counsel has been recognized. SAWS recommends changing §707.203 to provide only that the Board my extend deadlines for the public to file written comments on matters set for a meeting of the Board.

The Authority agrees, in part, and disagrees, in part, with the commenter. The Authority agrees that the authority to extend the deadline to file written comments on matters set for a meeting of the Board should not be delegated to the general counsel. However, the Authority believes that it is appropriate to delegate such authority to the general manager. The Authority has therefore modified §707.203 as set forth below.

The board or the general manager may set deadlines for the public to file written comments on matters set for a meeting of the board. The general manager , whether by agreement of the interest persons and any judge assigned to the matter, or the general manager's own motion, may extend a filing deadline.

Section 707.204(b)

Section 707.204 concerns the continuance of a matter set for a board meeting. Subsection (b) of that section, as proposed, allows the general counsel, either by agreement of the parties and any judge assigned to the matter, or by the general counsel's own motion, to reschedule the presentation of a matter at a board meeting.

SAWS expresses concern over the general counsel alone making a determination as to such continuances. SAWS maintains that in certain parts of the rules, the Board clearly delegates activities to the General Manager, but no such delegation to general counsel has been recognized. SAWS proposes eliminating the general counsel's authority to reschedule the presentation of a matter at a board meeting and modifying the rule so that only the board could reschedule the presentation of a matter at a board meeting.

In response to the public comments, the Authority has elected not to adopt §707.204 at this time and hereby withdraws the rule from consideration for permanent adoption.

Section 707.303

Section 707.303 attempts to clarify who is the proper applicant, registrant, or declarant for an application, registration or declaration. This rule states, in part, that "if there is more than one owner, a joint application, registration, or declaration shall be filed by those owners." Vulcan suggests a modification to this rule that would clarify that lessees, assignees, and easement holders are not joint owners. Joint ownership, according to Vulcan, only occurs if the interest holder is entitled to divided or undivided shares in the withdrawals from the well at any given time.

The Authority agrees with Vulcan's interpretation that lessees, assignees and easement holders are not joint owners of wells and need not be parties to a joint application. The Authority adds the following language to the end of §707.303 to clarify that lessees, assignees and easement holders need not be parties to a joint application: "For the purposes of this rule, a lessee or assignee of the surface estate, or an easement holder, is not considered an owner of a well."

Section 707.304

Section 707.304, as proposed, states the requirement that "any person seeking to withdraw groundwater from the aquifer, unless exempted from the permit requirement by §1.16(c) and §1.33 of the Act and §711.20 of this title (relating to Groundwater Withdrawal Permits), must file with the Authority an application for a groundwater withdrawal permit. SAWS recommends removing what it contends is an inadequate rule reference to "§711.20 of this title . . ."

The Authority agrees, in part, and disagrees, in part, with the commenter. The rule referenced in §§707.304-711.20 - relates to "Eligibility for Exempt Well Status" (not to "Groundwater Withdrawal Permits"). The Authority has revised §707.304 accordingly.

Section 707.306 and §707.308

Section 707.306 states the requirement that the owner of an existing or exempt well must register the well with the Authority. Section 707.308 states the requirement that an owner of a well that believes the well to be exempt from permitting requirements file an application for exempt well status. TFB questions whether an exempt well owner should be required to register a well and file an application for a exempt well status and pay both fees. TFB asserts that these requirements are redundant and unnecessary. TFB urges that all that is required is well registration.

The Authority disagrees with the commenter. The requirements to register a well and to file an application for exempt well status are completely independent. All existing wells including those requiring a groundwater withdrawal permit and exempt wells must be registered with the Authority. It is only through this requirement that the Authority can keep track of all points of withdrawal of groundwater from the Edwards Aquifer. On the other hand, only those well owners who claim to be exempt from the requirements to obtain a groundwater withdrawal permit are required to file an application for exempt well status. It is through this requirement that a person presents the Authority with information that would allow the Authority to validate the person's claim of exemption. Accordingly, both requirements are necessary. Moreover, because these are separate and independent requirements, separate filing fees are appropriate.

Section 707.308

As noted above, §707.308 states the requirement that an owner of a well who believes the well to be exempt from permitting requirements file an application for exempt well status. Earl & Brown urge the addition of a subsection (c) to §707.308 which would read as follows:

If an owner of an existing or proposed well submits a properly completed application for exempt well status, the Authority must provide the applicant with a written notice of the Authority's decision to approve or disapprove the exempt well status within 30 days from the date the application is received by the Authority. In the event the Authority fails to take such action on an application for exempt well status within 30 days, the application shall be deemed approved as a matter of law.

Earl & Brown assert that this addition is necessary for the purpose of avoiding unnecessary delays in processing applications for exempt well status. In support of this suggested addition, they also argue that it is imperative that applicants have the opportunity to obtain groundwater withdrawal rights before their well construction permits expire.

The Authority disagrees with the commenter. Procedures applicable to actions on applications for exempt well status are provided by §§707.501.-707.509, and 707.515, and 707.516 of these rules. The Authority believes that these procedures are necessary and appropriate for the consideration of applications for exempt well status. It is through these procedures that the Authority can assure the efficacy of the results of its determinations on exempt well status. The Authority notes that it seriously intends to process and act on applications in a timely manner. To shortcut the Authority's procedures by providing that an application will "deemed approved as a matter of law" following the expiration of a specified time would most likely lead in inaccurate results.

Section 707.309

Section 707.309 states the requirement that any person seeking to install a new meter or modify an existing meter file an application for a permit to install or modify a meter. Earl & Brown suggest adding a new provision to §707.309 which would state as follows:

In the event an existing meter is damaged to the extent that it is no longer properly functioning, the requirement to file an application with the Authority for a permit to install a new meter shall be waived provided the well owner can sufficiently demonstrate to the authority that an emergency condition existed in which the existing meter was no longer functioning.

The Authority disagrees with the commenter. If an existing meter is damaged to the extent that it is no longer properly functioning, then, under the Authority's substantive meter rules, subchapter M of Chapter 711, the meter would have to be repaired or replaced. If the meter was to be replaced, the well owner would be required to file an application pursuant to §707.309. If the meter needed repairs such that the repairs would constitute a "modification" for the purposes of §707.309, then the well owner would likewise be required to file an application pursuant to §707.309. The Authority does not understand or foresee what emergency condition might require the waiver of these requirements.

SAWS urges that the term "modify" as used in §707.309 not include standard maintenance. SAWS suggests that the following italicized language be added to the last sentence of §707.309:

For the purpose of this chapter, the term "modify" in connection with a meter means to make any physical change to the meter other than standard maintenance.

The Authority agrees with the commenter. The language of §707.309 has been modified as suggested.

Section 707.310

Section 707.310 states the requirement that an owner of an existing well equipped with a meter register the meter with the Authority by filing a meter registration no later than 180 days from the effective date of these rules. SAWS urges the addition language that would provide that meters registered with the Authority prior to the effective date of these rules through the filing of forms previously prescribed by the Authority need not be registered again.

The Authority agrees with the commenter. The Authority has added the following language to the end of §707.309.

Meters registered with the Authority prior to the effective date of these rules through the filing of forms previously prescribed by the Authority need not file another meter registration.

Section 707.311

Section 707.311 concerns the requirement to file a Declaration of Historical Use. It provides, in part, that "a declaration of historical use (application for an initial regular permit) must have been filed with the Authority pursuant to § 1.16(a) of the Act by December 30, 1996 . . . ." SAWS recommends removing what it contends is an inadequate rule reference to "§711.20 of this title . . ."

The Authority agrees, in part, and disagrees, in part, with the commenter. The rule referenced in §§707.311-711.20 - relates to "Eligibility for Exempt Well Status" (not to "Groundwater Withdrawal Permits"). The Authority has revised §707.311 accordingly.

Earl & Brown maintains that §707.311 should state that the time to file a declaration of historical use should be stated as "on or before March 1, 1994" in accordance with the language of §1.16(a) of the Act. Earl & Brown agrees that the deadline was changed to December 30, 1996, but contends that the change was not made pursuant to the Act.

The Authority agrees, in part, and disagrees, in part, with the commenter. Although the Act, on its face, does not establish December 30, 1996, as the deadline for filing declarations of historical use, but instead mentions March 1, 1994, that deadline was changed to December 30, 1996, by decision of the Supreme Court of Texas in Barshop v. Medina County Underground Water District, 925 S.W.2d 618, 628-630 (Tex. 1996). In order to clarify the legal basis for the December 30, 1996 deadline, the Authority has added the indicated language to §707.311

A declaration of historical use (application for an initial regular permit) must have been filed with the Authority pursuant to §1.16(a) of the Act and the decision of the Texas Supreme Court in Barshop v. Medina County Underground Water District, 925 S.W.2d 618, 628-630 (Tex. 1996) by December 30, 1996 . . . .

Section 707.312

Section 707.312, as proposed, provides that "declarations of historical use received by the Authority before the effective date of this subchapter need not be resubmitted." CPS notes that the terms "declaration of historical use" and "application for an initial regular permit" are used sometimes used interchangeably, as in §707.311. CPS also notes that the text of §707.405 makes it appear that a declaration of historical use is just one part of an application for an initial regular permit. CPS requests clarification as to whether §707.312 applies to an application for an initial regular permit or whether the Authority will require re-submission of the initial permit application after the effective date of the rules.

The Authority agrees that §707.312 should be clarified. Accordingly, the Authority has modified §707.312 to clarify that applications for an initial regular permit received by the Authority before the effective date of this subchapter need not be resubmitted.

Section 707.403

Section 707.403 provides, in part, as follows:

For all applications other than for an agricultural conservation loan, a non-refundable application fee of $25 must accompany that application in order for it to be considered by the Authority.

TFB asserts that §709.11, as proposed, contradicts §707.403. Section 709.11 states, in part, as follows:

The general manager shall impose a $25 fee to file with the Authority an application for a regular, term, or an emergency groundwater withdrawal permit, a well construction permit, monitoring well permit, aquifer recharge and storage permit, and recharge recovery permit.

The Authority agrees with the commenter that §709.11, as proposed, seems to contradict §707.403. To address this apparent contradiction, and as additionally noted in the Final Order Adopting Rule for its Chapter 709 rules, the Authority has modified §709.11 as set forth below:

The general manager shall impose a $25 fee to file with the Authority any application, including but not limited to, an application for a regular, term, or an emergency groundwater withdrawal permit, a well construction permit, monitoring well permit, aquifer recharge and storage permit, and recharge recovery permit.

Section 707.405 generally

Section 707.405 lists the contents of an application for an initial regular permit/declaration of historical use. V&E submitted comments to §707.405 generally, contending that the rule retroactively creates requirements for permit applications that were required to be filed by December 30, 1996, and that these new requirements were not reflected in the Authority's prior rule. Furthermore, V&E asserts that even seemingly innocuous problems with this rule are made significant given §711.98(j) which states as follows:

Subject to the duty of the board to determine the amount groundwater that may be withdrawn under an initial regular permit, the board shall grant an application for an initial regular permit if the following elements are established . . . (14) the application is in compliance with the rules of the Authority.

V&E believes these rules could cause an application to fail due to the retroactive application of these rules and recommends that the rules allow the applicant some time to supplement an application in order to meet the new requirements.

The Authority disagrees with the commenter. The rules Authority's rules allow an applicant to supplement an application in order to meet any new requirements. Specifically, §707.511 (relating to Supplementation of Application Required by Change in Rules) states that "if any pending application is affected by a change in these rules before final action on the application is taken by the Authority, the applicant shall have a right to submit information as necessary to comply with such change."

Section 707.405(3)

Paragraph (3) of §707.405, as proposed, requires that applications for an initial regular permit contain the amount of groundwater proposed to be withdrawn - stated in acre-feet per year - by the well that is the subject of the application. SAWS urges that an application for an initial regular permit should indicate historic use, not future or intended use. Accordingly, SAWS suggests the deletion of Paragraph (3) from §707.405. V&E also points to Paragraph (3) as irrelevant for the purposes of establishing historical use on which initial permits are based.

The Authority agrees with the commenters that an application for initial regular permit should focus on historic as opposed to intended or future uses. Moreover, most of the subjects in paragraph (3) of §707.405, as they relate to historical use, are covered in paragraph (6)(A) and (6)(C) of §707.405. Accordingly, the Authority has modified §707.405 by deleting paragraph (3) and renumbering the remaining paragraphs in the section.

Section 707.405(4)

Paragraph (4) of §707.405, as proposed, requires that applications for an initial regular permit contain the proposed maximum rate of withdrawal in gallons per minute or cubic feet per second.

SAWS contends because applications for initial permits are for existing, not proposed, wells and that paragraph (4) should be amended to read as follows:

Rate of Withdrawal. The maximum rate of withdrawal in gallons per minute or cubic feet per second each well is capable of producing shall be stated.

As noted above, the Authority agrees with the commenter that an application for initial regular permit should focus on historic as opposed to intended or future uses. Accordingly, the Authority has modified paragraph (4) of §707.405, as suggested, to make it clear that the application for initial regular permit requests historical information. In addition, the Authority has made a similar change to paragraph (5) of §707.405.

Section 707.405(6)(A)

Paragraph (6) of §705.405, as proposed (now paragraph (5)), requires that applications for an initial regular permit include a declaration of historical use. Subparagraph (A) of that paragraph requires the declaration to state "the total amount of water from the aquifer that the applicant or his contract user, prior user or former existing user withdrew and beneficially used without waste during each calender year of the historical period."

Earl & Brown urges that an applicant should be required to submit the total amount of water withdrawn from the Aquifer by a "prior user or former existing user" only if the applicant is able to obtain such information using reasonable efforts. Furthermore, Earl & Brown assert that such information should be verifiable and reliable or supported by affidavit.

The Authority disagrees with the commenter. It is the Authority's position that all applicants must document the beneficial use of underground water from the aquifer during the historical period, including use made by prior users. For any year in which an applicant fails to document or otherwise submit evidence of the amount of such prior use, the Authority will assume that usage for that year was zero.

Section 707.405(6)(E)

Subparagraph (E) of paragraph (6) (now paragraph (5)), of §707.405, as proposed, requires the declaration of historical use to state "the number and location of each well owned by the applicant and for which the applicant claims groundwater from the aquifer was withdrawn and placed to beneficial use during the historic period and the amount of water withdrawn from each well during each year of the historical period."

SAWS asserts that reporting production by individual wells is too cumbersome for an integrated pumping system. SAWS suggests amending this provision so that it reads as follows:

(E) the number and location of each well owned by the applicant and for which the applicant claims groundwater from the aquifer was withdrawn and placed to beneficial use during the historic period;

The Authority agrees with the commenter. This provision, as proposed, imposes a burdensome requirement. The Authority agrees that the burden of collecting and submitting the information at issue is not outweighed by the Authority's need for that information. The Authority has therefore modified this provision as suggested by the commenter.

Section 707.405(6)(G)

Subparagraph (G) of paragraph (6) (now paragraph (5)) of §707.405 requires the declaration of historical use to state (if the groundwater was withdrawn from the well or placed to a beneficial use by a contract user, prior user or former existing user), "the name, address and telephone number of each contract user, prior user or former existing user, the year of withdrawals, purpose of use, place of use and amount of withdrawals, including copies of the legal documents establishing the legal right of the contract user to withdraw and/or place groundwater from the aquifer to beneficial use."

Earl & Brown urge that this section should be changed to require such information only when the applicant is able to obtain it with "reasonable effort" and the information obtained is accurate and reliable. Additionally, Earl & Brown urge that if the applicant cannot obtain the information, a notation should be added to the application and no penalty should be suffered by the applicant.

The Authority disagrees with the commenter. It is the Authority's position that all applicants must document the beneficial use of underground water from the aquifer during the historical period, including use made by contract users, prior users, or former existing users. The information required in this subparagraph is necessary in order for the Authority or a party protesting a proposed permit to investigate and verify an applicant's claims of historical use of a contract user, prior user or former existing user. For any year in which an applicant fails to document or otherwise submit evidence of the amount of such prior use and the identity of such contracts user, prior user or former existing user, the Authority will assume that usage for that year was zero. However, the Authority has modified this provision to add the missing comma.

Section 707.405(6)(I)

Subparagraph (I) of paragraph (6) (now paragraph (5)) of §707.405 requires a declaration of historical use to provide - in instances where the groundwater is to be sold on a wholesale or bulk basis - "a description of how the groundwater will be sold, transported or transferred, the name address, and telephone number of every person to whom water will be delivered, the location to which the groundwater will be delivered, and the purpose for which the groundwater will be used . . . ."

SAWS comments that to require the identification of other than contracting parties is not only cumbersome, but ridiculous. SAWS suggests that §707.405(6)(I) read as follows:

. . . a description of how the groundwater will be sold, transported or transferred, the location . . . .

The Authority disagrees with the commenter. The requirement in subparagraph I to list "the name, address and telephone number of every person to whom water will be delivered" applies on its face to only where "the groundwater is to be sold on a wholesale or bulk basis." There is no requirement for an applicant (including SAWS) to list all the name, address and telephone of all retail water customers.

Section 707.405(6)(K)

Subparagraph (K) of paragraph (6) (now paragraph (5)) of §707.405 requires a declaration of historical use to contain "any other information that the general manager may require." Earl & Brown urge the deletion of this provision asserting that it may allow the General Manager to unfairly require supplemental information from one applicant when other applicants may not be called on to submit the same information. Earl & Brown contend that any information required in the declaration of historical use should be clearly delineated in the rules and required of all applicants.

The Authority disagrees with the commenter. The Authority, acting through its general manager, will need to exercise flexibility in its processing and review of applications for initial regular permits. The processing and review of many applications will be straight-forward, presenting a generic and well-defined set of issues to be examined. Other applications, however, are unique and will present special issues and will raise questions that are particular to that application. This rule, as written, provides the Authority with some flexibility in dealing with unique applications.

Section 707.410 generally

Section 707.410 concerns the contents of a well registration. SAWS asserts generally that the well registration requirements are too burdensome. The Authority disagrees with the commenter. The Authority has developed the list of items required in a well registration in order to provide the Authority with necessary baseline information. It is through such well registrations that the Authority collects information that is vital to the development and implementation of a variety of its statutorily-mandated programs.

Section 707.410(3)(B) and (C)

Subparagraphs (3)(B) and (3)(C) of §707.410 require well registrations to contain a map showing, respectively, the location of "the three nearest wells within a quarter of a mile of the well and the names and addresses of the owners of the nearby wells" and "any possible sources of contamination such as existing and proposed livestock or poultry yards, septic system absorption fields, underground or above ground petroleum storage tanks."

SAWS contends the Authority is in a position to maintain records of other wells and be knowledgeable of pollution sources. Therefore, SAWS contends that paragraphs (3)(B) and 3(C) of §707.410 should be eliminated as they are not appropriate for well registration.

The Authority agrees, in part, and disagrees, in part, with the commenter. While the Authority agrees that it should maintain records of wells and be knowledgeable of pollution sources, it needs to be able to collect information regarding those subjects. The well registration requirement is one of the primary ways in which the Authority is able to gather such information. Accordingly, the Authority declines to modify §707.410(3)(B) and (C).

Section 707.411

Section 707.411 concerns the contents of applications for well construction permits. Earl & Brown propose that a new paragraph - paragraph (14) - be added to §707.411 that would read as follows:

In the event the Authority approves an application for a well construction permit, the permit shall be valid for a period of 180 days from the time the Authority approves said permit. General Manager shall reserve the right to authorize an extension of the 180 day period provided that the applicant for a well construction permit submits a written request for an extension prior to the termination of the 180 day period. In the event the General Manager authorizes such extension, the extended time shall in no event exceed 60 days from the date the original 180 day period would have terminated.

The Authority agrees in part, and disagrees, in part, with the commenter. Earl & Brown's proposed addition to §707.411 refers to a requirement, found in §711.108(a) of the Authority's rules which was proposed concurrently with Chapter 707. That requirement states as follows:

A well constructed pursuant to a well construction permit must be completed within 180 days of issuance of the permit. Upon expiration of the term, the permit is automatically expires and is canceled.

The Authority realizes that due to the potential unavailability of water well drillers, sometimes the 180 day period in which to construct a well is not sufficient. In response to Earl & Brown's comment, and in response to other comments received in response to §711.108, as proposed, the Authority will modify §711.108(c) so that it reads as follows:

(c) A well constructed pursuant to a well construction permit must be completed within 180 days of the issuance of the permit. The permit term may be extended by one additional 180-day extension period by the general manager. In order to obtain such an extension, the holder of a well construction permit must submit a written request to the general manager explaining the need for the extension. If the holder of the well construction permit demonstrates a need for an extension and demonstrates that the permit holder's failure to complete the well within the original 180-day term is not due to the permit holder's own lack of diligence, then the general manager may authorize the extension. Upon expiration of the term, including any extension granted, the permit automatically expires and is canceled.

Section 707.411(3)(C)

Subparagraph (3)(C) of §707.411, as proposed, requires that applications for a well construction permit include a map showing the location of "any possible sources of contamination such as existing and proposed livestock or poultry yards, septic system absorption fields, underground or above ground petroleum storage tanks."

SAWS expresses concern over the difficulty of complying with identification of potential sources of well contamination. SAWS recommends that a specific radius of concern for the identification of potential sources of well contamination be established and proposes that §707.411(3)(C) read as follows:

any possible sources of contamination within a quarter of a mile of the proposed location, such as . . . .

The Authority agrees, in part, and disagrees, in part, with the commenter. Although the Authority needs to be able to collect information regarding possible sources of contamination to Edwards Aquifer groundwater (e.g., livestock or poultry yards, septic system absorption fields, underground or above ground petroleum storage tanks), it is the Authority's intent to assure that its application requirements are reasonable. The Authority has therefore agreed to modify §707.411(3)(C) as follows.

(C) any possible sources of contamination within 500 feet of the well ...

Earl & Brown urge that the word "known" be inserted into subparagraph (C) of §707.411(3) so that it requires the submittal of a map showing the location of:

. . . (C) any possible sources of known contamination such as existing and proposed livestock or poultry yards, septic system absorption fields, underground or above ground petroleum storage tanks;

The Authority agrees, in part, and disagrees, in part, with the commenter. While the Authority agrees with the commenter that there should be some limit on an applicant's duty to investigate the existence and location of sources of possible contamination, the commenter's suggested revision to this rule does not provide a clear standard. In an effort to provide a more workable standard, the Authority has modified this provision to require the submittal of a map showing the location of:

. . . (C) any possible sources of contamination that are known or should be known to the applicant such as existing and proposed livestock or poultry yards, septic system absorption fields, underground or above ground petroleum storage tanks;

Section 707.412(6)(N)

Section 707.412 concerns the contents of meter registrations. Subparagraph (6)(N) of that section, as proposed, requires the description of the meter contained in the registration to include "the maximum period of time and maximum amount that the totalizer may record the cumulative amount of groundwater withdrawn from the aquifer."

SAWS urges that the above language be amended because a meter totalizer records the cumulative amount pumped, not the time. SAWS suggests that the section should be amended so that it reads as follows:

the maximum amount that the totalizer may record of groundwater withdrawn from the aquifer.

The Authority agrees, in part, and disagrees, in part, with the commenter. The Authority agrees that regarding the capacity of the totalizer, the rule should require only the maximum cumulative amount of groundwater withdrawn from the aquifer that the meter is capable of measuring. However, the Authority disagrees that the commenters suggested revisions are the best way to achieve this goal. Accordingly, the Authority will amend the rule to read as follows:

the maximum cumulative amount of groundwater withdrawn from the aquifer that the totalizer is capable of measuring.

Section 707.413

Section 707.413 concerns the required contents for an application for a permit to install or modify a meter. Earl & Brown proposes the addition of the italicized language to §707.413:

Subject to those limitations set forth in §707.310, in addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Application and Registrations), an application for a permit to install or modify meter shall contain the following . . . .

The Authority disagrees with the commenter. Section 707.413 concerns the required contents of an application for a permit to install or modify a meter. Under §707.309, only persons seeking to install a new meter or modify an existing meter must file an application for a permit to install or modify a meter. Section 707.310 states the requirement that owners of existing wells equipped with meter register the meter with the Authority. Section 707.310 also clarifies that the requirement to register a meter does not apply to any meter owned by the Authority. The requirement to file a meter registration and the requirement to file an application to install or modify a meter are separate and independent from each other. Accordingly, it would make no sense to make the terms of the rule listing the required contents of an application for a permit to install or modify a meter subject to any of the limitations set forth in the rule that requires certain well owners to register a meter.

Section 707.414

Section 707.414 concerns the contents of an application to transfer interim authorization status and amend application for initial regular permit.

SAWS suggests an amendment to the title and text of §707.414 to clarify that a transfer of groundwater withdrawal rights under interim authorization does not modify or amend an application for an initial regular permit to read as follows:

Applications to Transfer Interim Authorization Status

In addition . . . , an application to transfer interim authorization status shall contain . . . .

The Authority disagrees with the commenter. Anytime a groundwater withdrawal right under interim authorization is transferred, this transfer results in a change to the application for initial regular permit that serves as the basis for the interim authorization right transferred. The application should therefore be amended in conjunction with the transfer.

Earl & Brown propose the addition of new paragraph (10) at the end of §707.414 which would require the following item to be included in an application to transfer interim authorization status and amend application for initial regular permit :

The meter reading taken in the last day of the month that immediately proceeds the month in which the application to transfer interim authorization status and amend application for initial regular permit is being submitted to the Authority.

The Authority agrees, in part, and disagrees, in part, with the commenter. The Authority agrees that a provision similar to the one that Earl & Brown suggest will be useful in minimizing and allowing the resolution of conflicts regarding the amount of aquifer management fees that are to be assessed against the transferee versus the transferor. The Authority has modified §707.414 by adding paragraph (9) as set forth below, and has renumbered the remaining subsections accordingly.

(9) A meter reading taken on the last day of the month immediately preceding the month in which the application to transfer interim authorization status and amend application for initial regular permit is submitted to the Authority.

The Authority has added the same requirement to §707.415.

Section 707.414(8) and §707.415(8)

Paragraphs (8) of §707.414 and §707.415 require that applications to transfer interim authorization status and amend application for initial regular permit and applications to transfer and amend permit contain the price per acre-foot paid for the water right transferred.

Earl & Brown contend that these provisions should be deleted because the price per acre foot paid for the transfer of a groundwater withdrawal right is privileged and confidential. Further, Earl & Brown assert that the Authority has no statutory authority to require such information and the price per acre foot is irrelevant to the legal merits of a proposed transfer of groundwater withdrawal rights. Finally, Earl & Brown state such disclosure is not required by §1.34 of the Act or any other provision of the Act.

SAWS expresses concern that the Authority can only demand disclosure of transaction prices from public entities. SAWS predicts that many prices will be listed as "$10 and other consideration." To reflect what SAWS believes the Authority can require, SAWS suggests that the italicized language be added to §707.414(8) and

707.415(8):

(8) The price per acre-foot for transactions involving a public entity.

The Authority disagrees with the commenters. While §1.34 of the Act governs the ability of permit applicants or permit holders to transfer their rights, only certain types of transfers are allowed by that section. Accordingly, the Authority may require persons who seek to transfer water rights to file an application with the Authority so that the Authority can approve or disapprove the proposed transfer. Such an approval or disapproval is not a legally binding determination regarding the ownership of property equivalent to a judicial decision declaring the respective rights to property. Rather, it is an administrative function that the Authority must perform in order to effectively manage its permit program and keep track of permitted groundwater withdrawal rights.

The Authority is not aware of any law that makes the price paid for Edwards Aquifer groundwater rights privileged and confidential. Moreover, in requiring such an application, the Authority may require persons to submit information that would enable and assist the Authority in performing its statutorily-mandated duties. In fulfilling some of those duties, the Authority may be required to pay market prices for the purchase, proportional adjustment, or "buy down" of water rights. To do so, the Authority must have the means to determine the market prices of groundwater withdrawal rights within the Edwards Aquifer region. Requiring the inclusion of prices in such applications allows the Authority to develop such information.

However, comments on §707.414(8) and §707.415(8) have caused the Authority to re-examine these provisions. Specifically, the Authority now realizes that some transfers of water rights may not involve a price (e.g., a gift). To allow for such situations, the Authority has modified §707.414(8) and §707.415(8) to read as follows:

(8) The price per acre-foot or other consideration.

These changes are not meant to relieve persons filing an application to transfer from the requirement to disclose a price where a price was actually paid.

Section 707.416(6)

Section 707.416 concerns the contents of an application for exempt well status. Paragraph (6) of §707.416, as proposed, requires such an application to contain "the maximum rate of withdrawal of groundwater that the well (or proposed well) is (or will be) is capable of in gallons per minute or cubic feet per second."

SAWS suggests a clarification of "rate of withdrawal" through the addition to Paragraph (6) of the italicized language indicated below:

Rate of Withdrawal. The maximum rate of withdrawal of groundwater that the well (or proposed well) is (or will be) ...is capable of producing in gallons per minute . . . .

Although SAWS references Paragraph (5) of §707.416, an examination of the substance of the comment itself indicates that SAWS probably meant to comment on Paragraph (6).

The Authority agrees with the commenter. The omission of the word "producing" was inadvertent. The Authority has modified §707.416(6) accordingly.

Section 707.416(11)

Paragraph (11) of §707.416 requires an application for exempt well status to contain "a statement as to whether the well (or proposed well) is within a subdivision requiring platting pursuant to Chapter 711, subchapter C, of this title."

SAWS suggests that the Authority eliminate paragraph (11) because it considers it to be a duplicate entry in the list of items in an application for exempt well status.

The Authority disagrees with the commenter. The Authority suspects that SAWS believed that paragraphs (11) and (12) of §707.416 to be duplicates. While they are similar, they are not duplicates. Paragraph (11) requires an application for exempt well status to contain "a statement as to whether the well (or proposed well) is within a subdivision requiring platting pursuant to Chapter 711, subchapter C, of this title." (Emphasis added.) Paragraph (12), on the other hand, requires such an application to contain "a statement as to whether the well (or proposed well) serves (or will serve ) a subdivision requiring platting pursuant to Chapter 711, subchapter C, of this title." (Emphasis added.)

Section 707.416(14)

Paragraph (14) of §707.416 requires an application for exempt well status to contain "any other information as may be required by the general manager." Earl & Brown urge the deletion of paragraph (14) because of their concern that it allows the General Manager discretion in requiring certain information from some applicants but not others. All required information, Earl & Brown argue, should be specified in the rules and required of all applicants.

The Authority disagrees with the commenter. The Authority, acting through its general manager, will need to exercise flexibility in its processing and review of applications for exempt well status. The processing and review of many applications will be straight-forward, presenting a generic and well-defined set of issues to be examined. Other applications, however, will be unique and will present special issues and will raise question that are particular to that application. This rule, as written, provides the Authority with some flexibility in dealing with unique applications.

Section 707.422(10)(E)

Section 707.422 concerns the contents of an application for an agricultural conservation loan. Subparagraph (E) of paragraph (10) of §707.422, as proposed, requires that the applicant to agree that the "that the applicant is current on all Edwards Aquifer aquifer management fees payable to the Authority and has a property installed and functioning meter on any Edwards Aquifer well related to the equipment to be financed."

SAWS points out a typographical error in this subparagraph. The rule, according to SAWS, should require the applicant to agree "that the applicant is current on all Edwards Aquifer aquifer management fees payable to the Authority and has a properly installed and functioning meter on any Edwards Aquifer well related to the equipment to be financed."

The Authority agrees with the commenter. The Authority has modified §707.422(10)(E) as set forth above to correct this error.

Section 707.424

Section 707.424 concerns the contents of an application for declaration of abandonment of a groundwater withdrawal permit. Earl & Brown contend that §707.424 should include a brief description explaining what constitutes abandonment of a groundwater withdrawal permit. At a minimum, Earl & Brown suggest the rules should delineate the amount of time that must elapse before a well may be deemed abandoned.

The Authority disagrees with the commenter. The Authority recently proposed Subchapter H of Chapter 711 of the Authority's rules. Subchapter H expressly governs the abandonment and cancellation of Edwards Aquifer permitting groundwater withdrawal rights. Proposed §711.196 of subchapter H clarifies what constitutes abandonment of a groundwater withdrawal permit. These concerns are thus addressed elsewhere in the Authority's rules.

Section 707.424(4)

Paragraph (4) of §707.424 requires an application for declaration of abandonment of a groundwater withdrawal permit to contain "any other information as may be required by the general manager."

Earl & Brown assert that this paragraph gives the general manager too much discretion, allowing the general manager to require information from some applicants but not others, and therefore should be deleted. Earl & Brown assert that the Authority should require uniform information of all applicants and should clearly state what information is required in the rules.

The Authority disagrees with the commenter. The Authority, acting through its general manager, will need to exercise flexibility in its processing and review of applications for declaration of abandonment of a groundwater withdrawal permit. The processing and review of many applications will be straight-forward, presenting a generic and well-defined set of issues to be examined. Other applications, however, will be unique and will present special issues and will raise questions that are particular to that application. This rule provides the Authority with some necessary flexibility in dealing with unique applications.

Section 707.426

Section 707.426 concerns the contents of an application to cancel a groundwater withdrawal permit.

In connection with §707.425, SAWS states that it believes it is unnecessary for the Authority to try to give meaning to every action in §1.16(g) of the Act. SAWS does not want to see unused permitted rights canceled by the Authority because SAWS contends these unused rights serve a conservation purpose and should not be canceled. Accordingly, SAWS recommends deleting §707.426 in its entirety.

The Authority disagrees with the commenter. Section 707.426 only lists the contents required for the an application to cancel a groundwater withdrawal permit. The substantive rules that deal with cancellation are found in the Chapter 711, Subchapter H, rules, recently proposed by the Authority. Comments as to the meaning assigned by the Authority to the term "cancelled" as used in §1.16(a) of the Act are more properly directed at the Subchapter H rules. Moreover, contrary to SAWS' suggestion, the cancellation of permitted rights does not does not defeat the Authority's conservation purpose. The cancellation of a permitted right does not mean that the right will necessarily be reallocated.

Inland asserts that non-use is an insufficient reason for the cancellation of a permit. Inland contends that this provision promotes waste of a natural resource and believes that it will be found unconstitutional. Inland recommends deleting this section in its entirety.

The Authority disagrees with the commenter. First, it is unclear what criteria in addition to non-use Inland is suggesting should be considered necessary to justify the cancellation of a permitted right. Second, the Authority does not understand how a rule stating the required contents of an application to cancel a groundwater withdrawal permit promotes waste. In any event, as stated above, substantive comments regarding the meaning of "cancelled" as used in the §1.16(g) Act are more properly directed at the Subchapter H rules. Third, and as noted above, the cancellation of permitted rights does not does not defeat the Authority's conservation purpose. Finally, although the Authority does not believe its substantive rules regarding cancellation of permitted rights are unconstitutional, if and when they are held unconstitutional, those rules will be voided and repealed.

Section 707.426(2)

Paragraph (2) of §707.426 requires that an application to cancel a groundwater withdrawal permit contain "a detailed description of all facts demonstrating that all or part of the groundwater authorized to be withdrawn pursuant to a groundwater withdrawal permit issued by the authority has not been put to beneficial use at any time during the 10-year period immediately preceding the filing of an application to cancel a groundwater withdrawal permit."

Verstuyft Farms explains that weather conditions may cause an irrigator to use more water one year and less the next. Verstuyft maintains that irrigators should not be penalized for not using all permitted water within a 10 year period. Rather, Verstyuft recommends that the unused portion of the permitted water should either be considered conservation of a natural resource or the permit holder should be allowed to lease that unused amount.

The Authority disagrees with the commenter. Section 707.426 only lists the contents required for the an application to cancel a groundwater withdrawal permit. The substantive rules that deal with cancellation are found in the Chapter 711, Subchapter H, rules, recently proposed by the Authority. Specifically, proposed §711.202 provides substantive standards regarding the cancellation of groundwater withdrawal permits. Comments regarding whether and under what conditions a permitted right should be cancelled are properly directed toward the Subchapter H rules.

Section 707.426(3)

Paragraph (3) of §707.426 requires that an application to cancel a groundwater withdrawal permit contain "any other information as may be required by the general manager." Earl & Brown assert that this paragraph gives the general manager too much discretion, allowing the general manager to require information from some applicants but not others and therefore should be deleted. Earl & Brown assert that the Authority should require uniform information of all applicants and should clearly state what information is required in the rules.

The Authority disagrees with the commenter. The Authority, acting through its general manager, will need to exercise flexibility in its processing and review of applications to cancel a groundwater withdrawal permit. The processing and review of many applications will be straight-forward, presenting a generic and well-defined set of issues to be examined. Other applications, however, will be unique and will present special issues and will raise question that are particular to that application. This rule provides the Authority with some necessary flexibility in dealing with unique applications.

Section 707.428

Section 707.428 concerns the contents of applications to convert base irrigation groundwater. SAWS asserts that the term "base irrigation" should be deleted in favor of more generic language based on the possibility that the restriction on transfer of "base irrigation" groundwater is challenged or overturned. SAWS recommends that §707.428 be amended to read as follows:

Application to Transfer Irrigation Groundwater.

In addition . . . an application to transfer irrigation shall contain...

(2) . . . to place irrigation groundwater to beneficial use at...

The Authority disagrees with the commenter. The Authority declines to assume that its rules or its interpretation of the Act will be challenged and overturned. If and when the Authority's interpretations concerning the transferability of groundwater under §1.34 of the Act are successfully challenged, the Authority will, at that time, revise its rules as necessary.

Section 707.428(3)(F)

Paragraph (3) of §707.428 requires the inclusion of certain items in an application to convert base irrigation groundwater if the proposed conversion is based on conservation (as opposed to physical impossibility). Subparagraph (F) of paragraph (3), as proposed, requires an application to include "a statement describing the accuracy of the water conservation equipment."

SAWS recommends that the language in subparagraph (F) be modified so that it reads as follows:

(F) Efficiency. A statement describing the efficiency of the water conservation equipment and supporting documentation from a recognized source.

The Authority agrees, in part, and disagrees, in part with the commenter. First, the Authority agrees that the term "efficiency" more appropriately describes the information sought by the Authority. Accordingly, the Authority has modified §707.428(3)(F) as shown below:

(F) Efficiency. A statement describing the efficiency of the water conservation equipment.

Second, the Authority disagrees that it is appropriate to add an express requirement for supporting documentation from a recognized source in this subparagraph. There are many instances in these rules where items required to be included in an application may need to be supported by various types of documentation. The rules do not specify what types of documentation are appropriate in each instance. Section 707.302 of these rules requires that "any person who wishes to obtain a permit, authorization, or other approval from the Authority shall submit a written application to the Authority on a form provided by the general manager." The Authority expects that the form provided by the general manager, and its associated instructions, will provide information on the appropriate supporting documentation for each type of application.

Earl & Brown request that a brief explanation be added to §707.428 describing the conditions or circumstances under which an applicant may submit an application to convert base irrigation groundwater (i.e., physical impossibility and/or conservation).

The Authority disagrees with the commenter. Substantive rules dealing with the transfer of permitted rights and the conversion of base irrigation groundwater (Chapter 711, subchapter L) have recently been proposed. Specifically, §711.342 describes the conditions or circumstances under which the Authority will allow the conversion of base irrigation groundwater. The substance of these rules may satisfy the concern expressed by the commenter.

Earl & Brown propose adding a subsection to §707.428 that would be titled Economic and Practicability and would read:

If the application is based on Economic and Practicability, a detailed description of all facts demonstrating that it is no longer economically and practicable the owner of a regular permit, or an applicant for a regular permit for a well qualifying for interim authorization status, to place base irrigation groundwater to beneficial use at the place of use identified in the regular permit for the application for an initial regular permit.

The Authority disagrees with the commenter. The Authority has determined in its proposed substantive rules governing transfers of groundwater withdrawal rights (Chapter 711, Subchapter L) that the only grounds for conversion of base irrigation groundwater are physical impossibility and conservation. This determination is set forth in proposed §711.342 which is the substantive rule governing conversion of base irrigation groundwater. Therefore, comments urging an additional ground for the conversion or base irrigation groundwater are properly directed toward that substantive rule.

Section 707.502(b)(1)

Section 707.502 provides procedures relating to the general manager's review of applications and registrations for administrative completeness. Paragraph (b)(1) of §707.502 provides that "in reviewing an application or registration for administrative completeness, the general manager shall assess whether the application or registration contains the necessary information in legible form which will allow . . . the general manager to forward the application or registration to the docket clerk to be filed and maintained in the permanent records of the Authority."

Earl & Brown assert that this statement is grammatically incorrect and should possibly read:

"The General Manager is to forward the Application of Registration to the Docket Clerk to be filed and maintained in the permanent records of the Authority."

The Authority disagrees with the commenter. The Authority believes that §707.502(b)(1), as written, is grammatically correct.

Section 707.504

Section 707.504 provides procedures related to the technical review, by Authority staff, of applications. Earl & Brown propose to add a new subsection to §707.504 - subsection (d) - to read as follows:

In the event the Authority staff fails to complete its technical review of an application within 90 business days of the determination, by the General Manager, of the applications administrative completeness, applications shall be administratively deemed approved as a matter of law.

The Authority disagrees with the commenter. First, the result of the staff's completion of the technical review is not an "approval" of an application as the above language suggests. Rather, the result of completing the technical review is that the general manager can then prepare a proposed permit and technical summary based on that technical review. See §707.507. Second, the technical review process cannot be side-stepped by operation of law. Without completion of the technical review, there can be no basis for the issuance of a proposed permit or proposed denial.

Section 707.504(b)

Subsection (b) of §707.504, as proposed, states, in part, that "the applicant shall be promptly notified of any additional material necessary for a complete technical review."

Earl & Brown suggest that the first sentence of §707.504(b), should be clarified so that it specifies that "the applicant shall be promptly notified in writing of any additional material necessary for a complete technical review." The Authority agrees with the commenter. Accordingly, the Authority has modified §707.504(b) as indicated by the above underscored language.

Sections 707.507, .508, .509, .510 and .515

Sections 707.507, .508, .509, .510, and .515, provide procedures pertaining to the proposed permit and technical summary, referral to docket clerk, publication of notice of proposed permit and technical summary in the Texas Register and local newspapers, and actions by the general manager, respectively.

Regarding these sections generally, Inland states that while it is appropriate for the Board to vote on all initial regular permit applications, any future withdrawal permit applications, including term, recharge and emergency permits, should be handled administratively. Inland urges that the rules should be changed to provide "consistency and certainty and to have all applications handled administratively."

The Board disagrees with the commenter. The Authority is willing to delegate to the general manager the authority to "handle administratively" only the granting of those applications listed in §707.515(b). The Authority is not willing to delegate authority to the general manger to act or term, recharge and emergency permits, and other permits which may affect the withdrawal rights of all other users.

Section 707.507(b)

Section 707.507 provides procedures regarding the preparation of a proposed permit and technical summary by the general manager. Subsection (b) of §707.507 provides various details regarding what the general manager is to do with the proposed permit and technical summary or proposed denial.

Earl & Brown assert that subsection (b) of §707.507 should contain a statement explaining that after the completion of a technical review, the general manager shall provide the applicant with a copy of the proposed permit. Earl & Brown urge that the sentence in §707.507(b) which reads, in part: "the proposed permit shall be filed with the Docket Clerk . . ." should read "the proposed permit shall be mailed to the applicant and filed with the docket clerk."

The Authority disagrees with the commenter. Such a modification to subsection (b) is not necessary in light of the fact that subsection (d) of §707.507 states that "the general manager will notify the applicant by mail that technical review of the application is complete and provide the applicant with a copy of the proposed permit (or denial) and the technical summary."

Earl & Brown urge that the word "detailed" be added to the last sentence of §707.507(b) so as to specify that if the general manager recommends to deny an application, "the general manager shall prepare a proposed denial stating the detailed reasons for that recommendation."

The Authority disagrees with the commenter. The Authority believes that it is sufficient to require the general manager to state the "reasons" for the denial.

Section 707.515(b)(4)(A)

Section 707.515 delegates authority to the general manager to take action on behalf of the Board of Directors of the Authority for certain actions and provides procedures regarding such actions. Subsection (b) of §707.515 lists the types of permits that the general manager may grant. Among those types, subparagraph (4)(A) of subsection (b) states that the general manager may grant "applications to . . . transfer interim authorization status and amend application for initial regular permit" in certain circumstances.

SAWS contends that a transfer of water rights under interim authorization does not modify or amend an application for an initial regular permit. Accordingly, SAWS suggests deleting the language "and amend application for initial regular permit" from § 707.515(4)(A):

application to: (A) transfer interim authorization status and. . . .

The Authority disagrees with the commenter. Anytime a groundwater withdrawal right under interim authorization is transferred, this transfer results in a change to the application for initial regular permit that serves as the basis for the interim authorization right transferred. The application should therefore be amended in conjunction with the transfer.

Section 707.517

Section 707.517 provides "special procedures regarding loss of exempt well status." TFB contends that the procedure set forth in this section by which the Authority may cancel exempt well status, after the Authority has received notice that the well no longer qualifies as exempt, inappropriately places the burden on the well owner to demonstrate that the well should not lose exempt status. TFB asserts that there seems to be no requirement calling for the Authority to confirm information it receives despite the possibility that the information could be false or maliciously submitted. Additionally, according to TFB, if the well owner fails to submit information showing that he is entitled to exempt status, the general manager is required to submit a proposed denial of that status to the Board. TFB suggests removing the section or refining it so as not to place the regulatory burden on the exempt well owner without further Authority verification of the received information.

The Authority disagrees with the commenter. First, it should be noted that the general manager has no power to cancel or revoke exempt well status. The general manager is only entitled to submit a proposal for presentation to the Board of Directors that exempt well status be withdrawn. With regard to the consideration of such a matter by the Board, there is no suggestion that the well owner has the burden to show that exempt well status should not be revoked. Rather, the general manager would have the burden of showing that a revocation of exempt well status is appropriate. The overall purpose of §707.517 is to provide the general manager with a administrative fact-finding device. The failure of well owner to submit information in response to an inquiry by the general manager does not result in a final decision revoking exempt well status, but only in a referral of the matter to the Board of Directors.

John Brigman stated that §707.517 should be written better to require the Authority to have proof that a well no longer qualifies as an exempt well. The Authority disagrees with the commenter. As explained above, the general manager has no power to cancel or revoke exempt well status but may only submit a proposal for presentation to the Board of Directors that exempt well status be withdrawn. If and when such a matter comes before the Board, the general manager would have to demonstrate to the Board that revocation of exempt well status is appropriate.

Section 707.601

Section 707.601 sets forth the types of applications on which contested case hearings may be requested and granted. Earl & Brown propose deleting the portions of this section that allow the right to request a contested case hearing on a transfer of groundwater withdrawal rights (either interim authorization or permitted rights) where the location of the point of withdrawal to which the transfer is proposed is east of Cibolo Creek. Earl & Brown contend that the Act does not provide the Authority the power to treat the transfer of rights to points east of Cibolo Creek, in a way that is different and inconsistent from other transfers.

The Authority disagrees with the commenter. This procedural rule is consistent with the recently proposed substantive rules (Chapter 711, Subchapter L) governing transfers of groundwater rights. Specifically, §711.352 imposes stringent criteria for the approval of transfers where the point of withdrawal of a right to withdraw groundwater is transferred from west to east of Cibolo Creek. To the extent that the Authority treats transfers that propose to move water rights from west to east of Cibolo Creek differently from other transfers, it would be appropriate to comment on the substantive rule that imposes the more stringent criteria on such transfers (as opposed to the procedural rule). Moreover, the Authority has the discretion to treat transfers of water rights from west to east of Cibolo Creek differently in order to fulfill its duty to protect springflows at San Marcos and Comal Springs as well as habitat and endangered and threatened species in those areas.

However, Earl & Brown's comment on §707.601 has led the Authority to discover some inconsistencies between its procedural and substantive rules. To achieve greater consistency with §711.352, the Authority has modified §§707.510, 707.515, and 707.601 so that they read as follows:

Section 707.510. Publication of Notice of Proposed Permit and Technical Summary in the Texas Register and in Local Newspapers.

(a) Applicability. . . . This section also applies to:

(1) applications to transfer interim authorization status and amend application for initial regular permit where the right to withdraw groundwater is to be transferred from west of Cibolo Creek to east of Cibolo Creek; and

(2) applications to transfer and amend permit where the right to withdraw groundwater is to be transferred from west of Cibolo Creek to east of Cibolo Creek.

Section 707.515. Actions on Applications by the General Manager. . . .

(b) The general manager may grant the following: . . .

(4) applications to:

(A) transfer interim authorization status and amend application for initial regular permit; or

(B) transfer and amend permit in all instances other than where the right to withdraw groundwater is to be transferred from west of Cibolo Creek to east of Cibolo Creek;

Section 707.601. Applicability

. . . Contested case hearings may also be requested and granted in connection with:

(1) applications to transfer interim authorization status and amend application for initial regular permit where the right to withdraw groundwater is to be transferred from west of Cibolo Creek to east of Cibolo Creek; and

(2) applications to transfer and amend permit, where the right to withdraw groundwater is to be transferred from west of Cibolo Creek to east of Cibolo Creek.

Section 707.602

Section 707.602 lists those persons who are entitled to request a contested case hearing. They are: the applicant for that permit or approval; an applicant for another groundwater withdrawal permit issued by the Authority; and any permittee holding a groundwater withdrawal permit issued by the Authority. Tom Wassenich states that he is concerned that a citizen or citizens group cannot request a contested case hearing unless they have a permit. He objects to this and believes there are many interested parties with good intentions who should be able to contest an application.

The Authority disagrees with the commenter. The Authority has determined that citizens and groups that are not applicants or permittees do not have standing to request a contested case hearing. The purpose of the Authority's procedures regarding initial regular permits is to determine who has statutory-based rights to withdraw groundwater from the Edwards Aquifer. These procedures have only incidental protective effects on downstream users, springflows, habitat and endangered species. The Authority has other programs which are primarily designed to advance these goals.

The process of issuing initial regular permits is a process by which a finite amount of water (as determined by the Legislature) is allocated to various persons possessing statutory rights to some of that water. If a person is not an applicant for an initial regular permit, that person has no interest in the determination of the amount of water that may be allocated to a particular applicant. Accordingly, the Authority is justified in determining that contested case hearings on applications for initial regular permits should not be a forum for persons and groups who are not applicants to argue their individual interest or their version of the public interest.

Louis Obdyke states that he would like the right to comment on permits and applications without being required to be an applicant or permittee. To the extent that Mr. Obdyke means that he would like to be a party to contested case hearings, the Authority disagrees with the commenter. As noted above, the Authority has determined that non-applicants and non-permittees do not have such standing. However, to the extent that Mr. Obdyke means that he would like to offer public comment on any permit or application being considered by the Authority at a meeting of the Board of Directors of the Authority, Mr. Obdyke may, consistent with Subchapter C, Chapter 707 of the Authority's rules, do so.

Section 707.604

Section 707.604, as proposed, states that "unless a different time limit is specified in the notice of the proposed permit and technical summary, a hearing request must be filed with the docket clerk on or before the 30th day following the date of publication of that notice in the Texas Register ."

SAWS expresses concern about a possible arbitrary decrease in the time allowed to request a contest case hearing. SAWS believes a period shorter than 30 days should not be considered and recommends that the rule be amended so that it reads as follows:

Unless a longer time limit is specified in the notice of proposed permit and technical summary . . . .

The Authority agrees with the commenter that a period shorter than 30 days should not be considered. Accordingly, the Authority has modified §707.604 as indicated above.

With respect to §707.604, Dianne Wassenich states that ordinary citizens do not read the Texas Register and that it makes more sense to publish the proposed permit and technical summary in the town in which the permit is being applied for. The Authority disagrees with the commenter. Section 707.510(b) of the Authority's rules already requires the Authority to publish a notice of a proposed permit and technical summary in a newspaper of general circulation throughout the Authority's jurisdiction and at least five other newspapers within the jurisdiction of the Authority, in addition to the Texas Register . The reference to publication in the Texas Register in §707.604 concerns only the date on which the period to file a hearing request begins.

Section 707.605

Section 707.605 provides the procedures applicable to the processing of a request for a contested case hearing by the Authority. As proposed, this section directs the docket clerk to provide notice to the applicant, general manager and any persons making a timely hearing request at least 20 days prior to the first meeting at which the Board considers the request. Although the Authority did not receive comments on this rule, the Authority has noticed a typographical error in the rule as proposed. The Authority meant to propose that the docket clerk provide notice of hearing request at least 30 days prior to the first meeting at which the board considers the request. Thirty days notice provides a person with an opportunity to submit a written response pursuant to §707.605(d). The Authority has modified §707.605 accordingly.

Section 707.606(c)(1)

Section 707.606 provides procedures regarding action by the Board of Directors of the Authority on a request for a contested case hearing. Subsection (c) states criteria which, if met, shall result in the granting of a request for a contested case hearing. Paragraph (1) of subsection (c) requires that a request for a contested case hearing be "supported by competent evidence."

TFB asserts that before September 1, 1999, §5.115(a) of the Texas Water Code articulated a similar standard but that in 1999, the Legislature deleted the "competent evidence" requirement from §5.115. TFB asserts that this phrase was hard to define and the TNRCC encountered difficulty in its implementation. TFB urges the Authority to define "competent evidence" in a way that provides flexibility and curtails confusion.

The Authority disagrees with the commenter. The Authority does not believe there is a need to provide a rule defining the term "competent evidence." Numerous other statutes governing administrative agency proceedings employ this term. See, e.g., Texas Natural Resources Code, Annotated, §51.189(c) (Vernon Supp. 2000). If a problem predicted by TFB is indeed encountered, the Authority may reconsider this decision.

Section 707.610(d)

Section 707.610 provides procedures regarding the designation of parties in contested case hearings. Subsection (d) of §707.610 provides that "an applicant for an initial regular permit who files a notice of party status pertaining to §707.626 (relating to Designation of Party Status) is a party in all contested case hearings for which notice has been given."

Earl & Brown argue that this section should be deleted because it may violate other statutes and, seemingly, only serves the San Antonio Water System ("SAWS"). According to Earl & Brown, as a pre-requisite to obtaining party status, a person must demonstrate an interest in the application being heard. Earl & Brown therefore urge that all parties, including SAWS, must provide convincing evidence showing a vested interest in each and every application they wish to protest. Earl & Brown objects to blanket protests which would allow parties to obtain party status in all pending groundwater applications.

The Authority disagrees with the commenter. First, although SAWS advocated the inclusion of this provision, there is no reason why other parties could not take advantage of it. Second, the Authority is not aware of any statute that this rule would violate. Third, contrary to Earl & Brown's assertions there is no requirement that a party "demonstrate an interest in the application being heard" - in order to obtain party status. Rather, party status is conferred on: (1) the general manager; (2) the applicant; (3) the person who requested the contested case hearing that was granted; and (4) an applicant for an initial regular permit who files a notice of party status under §707.626. Under §707.602, the categories of persons who may request a contested case hearing are: the applicant for that permit or approval; an applicant for another groundwater withdrawal permit issued by the Authority; and any permittee holding a groundwater withdrawal permit issued by the Authority. The Authority has determined that those categories of persons, by nature of their status, have an interest in all applications sufficient to justify party status in a contested case hearing. As a result of §707.602, any applicant for an initial regular permit has the right to request a contested case hearing on every application for an initial regular permit and may gain party status in every resulting contested case hearing. Subsection (d) of §707.610, in conjunction with §707.626, reduces administrative burdens on both applicants and the Authority by allowing an applicant, through one filing, to request party status in several or all contested case hearings.

Section 707.611

Section 707.611 states that in a contested case hearing, "the burden of proof is on the applicant to establish by convincing evidence that he is entitled to have an application for a groundwater withdrawal permit granted." Earl & Brown propose that the following sentence be added to the end of §707.611:

However, once an applicant has presented convincing evidence that they are entitled to have an application for groundwater withdrawal permit granted, the burden of proof shall then shift to the protestant to establish convincing evidence that the applicant is not entitled to a groundwater withdrawal permit either in the amount originally applied for or as a complete denial of a permit

The Authority disagrees with the commenter. If and when an applicant shows by convincing evidence that they are entitled to a groundwater withdrawal permit, the contested case is over. It makes no sense for the burden to then shift to the protestant to prove otherwise.

Section 707.614(b)(1)

Section 707.614 provides procedures related to a State Office of Administrative Hearings (SOAH) judge certifying a question to the Authority. Subsection (b) of §707.614 enumerates the type of issues or questions that appropriate for certification. Under paragraph (1) of subsection (b), policy questions that are appropriate for certification include "the Authority's interpretation of its rules and applicable statutes."

Earl & Brown assert that if this rule is adopted by the Authority, motions should be filed with the Authority requesting that a court certify a question to the Authority asking the Authority to interpret Article I, §1.34 Item C, of the Act.

The Authority disagrees with the commenter. Earl & Brown seem to misunderstand the subject and purpose of §707.614. This section does not enable or encourage the Authority to request that a court certify a question to the Authority. Rather, this rule is meant to provide guidance to a SOAH Administrative Law Judge who has been assigned to hear a contested case referred to SOAH by the Authority pursuant to §§707.606, 707.608, and 707.609, as to when it is proper to certify a question to the Authority. In such a case, the decision to certify the question lies with the SOAH judge, although a motion to certify may be filed by the general manager.

Section 707.621(b)

Section 707.621 provides procedures relating to decisions by the Board of Directors of the Authority in a contested case hearing following the filing of a proposal for decision (PFD) by a SOAH judge. Subsection (b) of §707.621 provides that "the board's decision will be rendered no more than 90 days after the date of that the proposal for decision is presented to the board, unless the board determines that there is good cause for continuing the proceeding."

Earl & Brown assert that a grammatical error exists in §707.621(b) and suggest the sentence was meant to read as follows: "The Board's decision will be rendered no more than ninety (90) days after the date that the proposal for decision is presented to the Board . . . ."

The Authority disagrees with the commenter. The Authority does not believe that §707.621(b) contains a grammatical error. The Authority does not consider using a numeral instead of spelling a number and including the numeral in parentheses to be a grammatical error.

Earl & Brown recommend adding the following sentence to the end of §707.621(b):

In the absence of a showing of good cause, if the Board fails to render a decision 90 days after the date that the proposal for decision is presented to the Board, the proposal for decision shall be deemed administratively approved as a matter of law.

The Authority disagrees with the commenter. To allow a permit to be granted as a matter of law through the expiration of a 90-day deadline would delegate too much authority to the SOAH Administrative Law Judge presiding at the contested case hearing. It is the Authority's responsibility to issue and deny permits and to act on applications, not SOAH's. While the Authority is serious about reviewing and acting on all proposals for decisions in a timely manner, circumstances may arise that would necessitate a delay in the Board's schedule.

Section 707.622(b)

Section 707.622 provides procedures related to motions for rehearing in matters which have been referred to a contested case hearing. Subsection (b) of that section provides, in part, that "a reply to a motion for rehearing must be filed with the docket clerk within 30 days after the date a party or his attorney of record is notified of the decision or order. A party or attorney of record is presumed to have been notified on the date that the decision or order is mailed by first-class mail."

Earl & Brown recommend that the 30 day time line should not activate until a party or his attorney of record is notified "of the motion for rehearing," rather than from the date of the decision or order.

The Authority disagrees with the commenter. Under §707.622, a motion for rehearing is due within 20 days after the date the party seeking to file the motion or his attorney is notified of the decision or order. The reply to that motion for rehearing is due 30 days after the date a party or his attorney is notified of the decision or order. This time line provides the party seeking to respond to a motion for rehearing with approximately 10 days to prepare and file a reply. The Authority believes that this rule provides sufficient time for the reply. The party filing the reply will have been a party to and would have participated in the contested case. Thus, that party will most likely be very familiar with the issues raised in the contested case and in the motion for rehearing. As a precedent, the Authority also notes that the Texas Natural Resource Conservation Commission utilizes the same time line for motions for rehearing and replies in 30 TAC, §80.272.

Section 707.626

Section 707.626 allows any applicant for an initial regular permit to obtain party status in any or all contested cases by filing a notice thereof. It also provides procedures applicable to such a notice and the required contents of such a notice. Earl & Brown propose the omission of this entire section based on reasons stated in their comments to §707.610(d).

The Authority disagrees with the commenter. The Authority declines to delete this rule for the reasons stated in its response to Earl & Brown's comments to §707.610(d).

V. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rules governing procedures of the board and the authority." This section directs the Board to adopt rules as necessary to implement the various substantive programs set forth in the Act related to the Edwards Aquifer, including, in particular, administrative procedures to be used before the Board and the Authority.

Section 1.11(b) of the Act requires the Authority to "ensure compliance with permitting, metering, and reporting requirements and shall regulate permits." This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to establish procedures related to the filing and processing of various applications and registrations with and by the Authority.

Section 1.11(d)(1) of the Act empowers the Authority to issue and administer grants, loans, or other financial assistance to water users for water conservation and water reuse. Section 1.24(c) of the Act allows the Authority to issue grants or make loans to finance the purchase or installation of equipment or facilities for water conservation. These sections, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, empower the Authority to establish procedures related to the filing and processing of applications for agricultural conservation loans with and by the Authority.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. Pursuant to this section, the Authority is required to comply with the APA in connection with its rulemaking, even though the Authority is not a state agency and would therefore otherwise not generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.15(a) of the Act directs the Authority to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by this Act. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that would allow the Authority to fulfill these mandates.

Section 1.15(b) of the Act states that "except as provided by §1.17 and §1.33 of this article, a person may not withdraw water from the aquifer or begin construction of a well or other works designed for the withdrawal of water from the aquifer without obtaining a permit from the authority." This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will implement this limitation.

Section 1.15(c) of the Act allows the Authority to issue regular permits, term permits, and emergency permits. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, empowers the Authority to establish procedures related to the filing and processing of applications for initial and additional regular permits, term permits and emergency permits.

Section 1.16(a) of the Act allows an existing user to apply for an initial regular permit by filing a declaration of historical use. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules governing the filing and processing of such applications or declarations.

Section 1.16(b) of the Act sets forth certain requirements concerning an existing user's declaration of historical use and an applicant's payment of application fees required by the Board. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will implement these requirements.

Section 1.16(c) of the Act provides that an owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under §1.33 of the Act is not required to file a declaration of historical use. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will implement this exemption.

Section 1.16(d) of the Act requires the Board to grant an initial regular permit to an existing user who: (1) files a declaration and pays fees as required by this section; and (2) establishes by convincing evidence beneficial use of underground water from the aquifer. This section, in conjunction with §1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to fulfill this mandate.

Section 1.17(a) of the Act provides that a person who, on the effective date of this article, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the Authority, if: (1) the well is in compliance with all statutes and rules relating to well construction, approval, location, spacing, and operation; and (2) by March 1, 1994, the person files a declaration of historical use on a form as required by the Authority. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to determine who may continue to withdraw water under such authority.

Section 1.17(b) of the Act specifies that use under "interim authorization" may not exceed on an annual basis the historical, maximum, beneficial use of water without waste during any one calendar year as evidenced by the person's declaration of historical use, unless otherwise determined by the Authority. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to implement this condition.

Section 1.18 of the Act allows the Authority, in certain circumstances, to issue additional regular permits. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, empowers the Authority to establish procedures related to the filing and processing of applications for such permits.

Section 1.19(a) of the Act allows the Authority to issue term permits and places certain limitations and conditions on the right to withdraw water under such a permit. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to issue term permits and to implement the limitations and conditions stated in §1.19.

Section 1.20 of the Act allows the Authority to issue emergency permits under certain circumstances and subject to certain conditions. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to issue emergency permits when appropriate and to implement the conditions stated in §1.20.

Section 1.29(f) of the Act requires the Authority to impose a permit application fee of not more than $25. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to fulfill this mandate.

Section 1.29(g) of the Act empowers the Authority to impose a registration application fee of not more than $10. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, allows the Authority to adopt procedural rules that will allow the Authority to collect such a fee.

Section 1.33(a) of the Act provides that a well that produces 25,000 gallons of water a day or less for domestic or livestock use is exempt from metering requirements. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to determine who may qualify for such an exemption.

Section 1.33(b) of the Act requires that exempt wells be registered with the Authority or with an underground water conservation district in which the well is located. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to implement this requirement.

Section 1.34(a) of the Act provides that a place of use for Edwards Aquifer groundwater may not be outside the boundaries of the Authority. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to implement these requirements.

Section 1.34(c) of the Act provides that a holder of a permit for irrigation use may not lease more than 50 percent of the irrigation rights initially permitted and that the user's remaining irrigation water rights must be used in accordance with the original permit and must pass with transfer of the irrigated land. This section, in conjunction with §1.11(a) and (h) of the Act, and §2001.004(1) of the APA, requires the Authority to adopt procedural rules that will allow the Authority to implement these requirements.

Subchapter A. DEFINITIONS

31 TAC §707.1

The new sections are adopted pursuant to §§1.08(a), 1.11(a), 1.11(b), 1.11(d)(1), 1.11(h), 1.15(a), 1.15(b), 1.15(c), 1.16(a), 1.16(b). 1.16(c), 1.16(d), 1.17(a), 1.17(b), 1.18, 1.19(a), 1.20, 1.24(c), 1.29(f), 1.29(g), 1.33(a), 1.33(b), 1.34(a), and 1.34(c) of the Act and §2001.004(1) of the Texas Administrative Procedure Act (Texas Government CODE Annotated, §§2001.001-.902 (Vernon 2000)) ("APA").

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007343

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter B. GENERAL PROVISIONS

31 TAC §§707.101-707.106

The new sections are adopted pursuant to §§1.08(a), 1.11(a), 1.11(b), 1.11(d)(1), 1.11(h), 1.15(a), 1.15(b), 1.15(c), 1.16(a), 1.16(b). 1.16(c), 1.16(d), 1.17(a), 1.17(b), 1.18, 1.19(a), 1.20, 1.24(c), 1.29(f), 1.29(g), 1.33(a), 1.33(b), 1.34(a), and 1.34(c) of the Act and §2001.004(1) of the Texas Administrative Procedure Act (Texas Government CODE Annotated, §§2001.001-.902 (Vernon 2000)) ("APA").

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007344

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter C. MEETINGS OF THE BOARD

31 TAC §§707.201, 707.203, 707.205-707.208

The new sections are adopted pursuant to §§1.08(a), 1.11(a), 1.11(b), 1.11(d)(1), 1.11(h), 1.15(a), 1.15(b), 1.15(c), 1.16(a), 1.16(b). 1.16(c), 1.16(d), 1.17(a), 1.17(b), 1.18, 1.19(a), 1.20, 1.24(c), 1.29(f), 1.29(g), 1.33(a), 1.33(b), 1.34(a), and 1.34(c) of the Act and §2001.004(1) of the Texas Administrative Procedure Act (Texas Government CODE Annotated, §§2001.001-.902 (Vernon 2000)) ("APA").

§707.201.Meetings.

(a)

The board shall meet as necessary for the conduct of business at times and places necessary for the performance of the Authority's duties. Meetings shall be scheduled in accordance with the Bylaws of the Authority. The Authority is subject to the Open Meetings Act, including any existing or future exceptions that may be provided by law.

(b)

Meetings of the board shall be presided over by the chair, or in the chair's absence, the vice chair, or in the absence of both the chair and the vice chair, the secretary, or in the absence of all three, the treasurer. In the absence of all four such officers, the voting directors present shall elect a temporary chair for that meeting.

(c)

Business may be considered in accordance with Robert's Rules of Order or other standard rules of procedure as may be adopted by the directors from time to time. Directors may also, to the extent permitted by applicable laws, suspend by a majority vote any such rules.

(d)

Non-voting directors may participate in and comment on any matter before the board in the same manner as a voting director. A non-voting director may not vote on any matter before the board.

(e)

Members of the South Central Texas Water Advisory Committee (SCTWAC) may participate in board meetings to represent downstream water supply concerns and assist in solutions to those concerns. SCTWAC members may request the chair to permit them to address the board on such matters. SCTWAC members may not vote on matters before the board.

(f)

The Parliamentarian shall decide issues of parliamentary procedure, but may be overruled by majority vote of the board. The Parliamentarian is appointed to that position by the chair pursuant to the Bylaws of the Authority.

§707.203.Deadline to File Comments on Matter Set for a Meeting.

The board or the general manager may set deadlines for the public to file written comments on matters set for a meeting of the board. The general manager, either by agreement of the interested persons and any judge assigned to the matter, or on the general manager's own motion, may extend a filing deadline.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007345

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter D. REQUIREMENTS TO FILE APPLICATIONS AND REGISTRATIONS

31 TAC §§707.301-707.315

The new sections are adopted pursuant to §§1.08(a), 1.11(a), 1.11(b), 1.11(d)(1), 1.11(h), 1.15(a), 1.15(b), 1.15(c), 1.16(a), 1.16(b). 1.16(c), 1.16(d), 1.17(a), 1.17(b), 1.18, 1.19(a), 1.20, 1.24(c), 1.29(f), 1.29(g), 1.33(a), 1.33(b), 1.34(a), and 1.34(c) of the Act and §2001.004(1) of the Texas Administrative Procedure Act (Texas Government CODE Annotated, §§2001.001-.902 (Vernon 2000)) ("APA").

§707.303.Proper Applicant, Registrant, or Declarant.

If a well or a proposed well has one owner, that owner shall file the application, registration or declaration. If there is more than one owner, a joint application, registration, or declaration shall be filed by those owners. In such an instance, the owners shall select one among them to act for and represent the others in the filing the application, registration or declaration. Written documentation of such a selection satisfactory to the Authority shall be filed with the application, registration or declaration. For the purposes of this section, a lessee or assignee of the surface estate, or an easement holder, is not considered an owner of a well.

§707.304.Requirement to File an Application for a Groundwater Withdrawal Permit.

Any person seeking to withdraw groundwater from the aquifer, unless exempted from the permit requirement by §1.16(c) and §1.33 of the Act and §711.20 of this title (relating to Eligibility for Exempt Well Status), must file with the Authority an application for a groundwater withdrawal permit.

§707.309.Requirement to File Application for Permit to Install or Modify Meter.

Any person seeking to install a new meter or modify an existing meter must file with the Authority an application for a permit to install or modify a meter. Any person seeking to employ an alternative measuring method or modify an existing alternative measuring method must file with the Authority an application for a permit to install or moAdify a meter as well. For the purpose of this chapter, the term "modify" in connection with a meter means to make any physical change to the meter other than standard maintenance. Meters registered with the Authority prior to the effective date of these rules through the filing of forms previously prescribed by the Authority need not file another meter registration.

§707.311.Requirement to File Declaration of Historical Use.

A declaration of historical use (application for an initial regular permit) must have been filed with the Authority pursuant to §1.16(a) of the Act and the decision of the Texas Supreme Court in Barshop v. Medina County Underground Water District, 925 S.W.2d 618, 628-630 (Tex. 1996) by December 30, 1996, for each well from which groundwater from the aquifer has been withdrawn and placed to beneficial use during the historical period. An owner of an well exempt from the requirement to obtain a groundwater withdrawal permit under §1.16(c) and §1.33 of the Act and §711.20 of this title (relating to Eligibility for Exempt Well Status) is not under a requirement to file a declaration of historical use.

§707.312.Declarations Received Before Effective Date of These Rules.

Applications for initial regular permits/declarations of historical use received by the Authority before the effective date of this subchapter need not be resubmitted.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007347

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter E. REQUIREMENTS FOR APPLICATIONS AND REGISTRATIONS

31 TAC §§707.401-707.417, 707.422, 707.424, 707.426, 707.428

The new sections are adopted pursuant to §§1.08(a), 1.11(a), 1.11(b), 1.11(d)(1), 1.11(h), 1.15(a), 1.15(b), 1.15(c), 1.16(a), 1.16(b). 1.16(c), 1.16(d), 1.17(a), 1.17(b), 1.18, 1.19(a), 1.20, 1.24(c), 1.29(f), 1.29(g), 1.33(a), 1.33(b), 1.34(a), and 1.34(c) of the Act and §2001.004(1) of the Texas Administrative Procedure Act (Texas Government CODE Annotated, §§2001.001-.902 (Vernon 2000)) ("APA").

§707.405.Applications for Initial Regular Permits/Declarations of Historical Use.

In addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Applications and Registrations), an application for an initial regular permit shall contain the following:

(1)

Name and Address of Owner. The full name, post office address and telephone number of the well owner, if different from that of the applicant.

(2)

Source of Supply. The applicant shall clearly state whether the Edwards Aquifer is the source of groundwater from the well.

(3)

Rate of Withdrawal. The proposed maximum rate of withdrawal in gallons per minute or cubic feet per second each well is capable of producing shall be stated.

(4)

Method of Withdrawal. The method to be used to withdraw groundwater shall be described.

(5)

Declaration of Historical Use. A declaration of historical use containing:

(A)

the total amount of water from the aquifer that the applicant or his contract user, prior user or former existing user withdrew and beneficially used without waste during each calendar year of the historical period;

(B)

the maximum number of acres irrigated during any one calendar year of the historical period;

(C)

the purpose(s) for which the groundwater was used during each year of the historical period;

(D)

the amount of groundwater the applicant claims as the maximum beneficial use of water without waste during any one calendar year of the historical period;

(E)

the number and location of each well owned by the applicant and for which the applicant claims groundwater from the aquifer was withdrawn and placed to beneficial use during the historical period;

(F)

the place of use of groundwater withdrawn from each well;

(G)

if the groundwater was withdrawn from the well or placed to a beneficial use by a contract user, prior user or former existing user, then the name, address and telephone number of each contract user, prior user or former existing user, the year of withdrawals, purpose of use, place of use and amount of withdrawals, including copies of the legal documents establishing the legal right of the contract user to withdraw and/or place groundwater from the aquifer to beneficial use;

(H)

any facts upon which the applicant requests equitable adjustment on the grounds that the applicant's historic use was affected by a requirement of or participation in a federal program;

(I)

if the groundwater is to be sold on a wholesale or bulk basis, whether metered or un-metered, transported or transferred, a description of how the groundwater will be sold, transported or transferred, the name, address and telephone number of every person to whom the water will be delivered, the location to which the groundwater will be delivered, and the purpose for which the groundwater will be used, including copies of the legal documents establishing the right for the groundwater to be sold, transported or transferred;

(J)

a separate Well Information Sheet prescribed by the general manager or a registration form from a groundwater district or other entity with the same data as the Well Information Sheet for each well accompanied by a photograph of the well taken approximately 100 feet from the well head; and

(K)

any other information that the general manager may require.

§707.411.Applications for Well Construction Permits.

In addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Applications and Registrations), an application for a well construction permit shall contain the following:

(1)

Name and Address of Owner. The full name, post office address, and telephone number of the owner of the proposed well, if different from the applicant.

(2)

Location. A legal description of the location of the proposed well, including: the county; section, block and survey; labor and league; the number of feet to the two nearest non-parallel property lines (legal survey lines); or other adequate legal description approved by the Authority.

(3)

Map. A map showing the location of:

(A)

the proposed well;

(B)

the three nearest wells within a quarter of a mile of the proposed location, and the names and addresses of the owners of the nearby wells; and

(C)

any possible sources of contamination within 500 feet of the well that are known or should be known to the applicant such as existing and proposed livestock or poultry yards, septic system absorption fields, underground or above ground petroleum storage tanks.

(4)

Purpose of Use. The proposed purpose of use stated in definite terms. If the groundwater is to be used for more than one purpose, the approximate amount to be used for each purpose shall be stated.

(5)

Amount of Withdrawal. The total amount of groundwater proposed to be withdrawn from the aquifer and beneficially used on an annual and monthly basis, stated in number of acre-feet.

(6)

Rate of Withdrawal. The maximum rate of withdrawal that the proposed well would be capable of, in gallons per minute or cubic feet per second, shall be stated.

(7)

Depth. The proposed depth of the well and proposed depth of cement casing.

(8)

Pump. The size of the proposed pump and pumping method.

(9)

Proposed Construction Date. The approximate date that well construction operations are proposed to begin.

(10)

Identity of Well Drilling Contractor. The name, address, telephone number and license number of the well drilling contractor.

(11)

Other Permits. A list of all other permits applied for or issued by the Authority to the applicant.

(12)

Legal Basis of Right to Withdraw Groundwater. The applicant shall identify the claimed legal basis under which groundwater will be withdrawn from the aquifer.

(13)

Any other information as may be required by the general manager.

§707.412.Meter Registrations.

In addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Applications and Registrations), a meter registration shall contain the following:

(1)

Name and Address of Owner. The full name, post office address, and telephone number of the owner of the well on which the meter is installed, if different from that of the registrant.

(2)

Location. A legal description of the location of the well on which the meter is installed including: the county, section, block and survey, labor and league; the number of feet to the two nearest non-parallel property lines (legal survey lines); or other adequate legal description approved by the Authority;

(3)

Map. A map showing the location of the well on which the meter is installed;

(4)

Status of Well. Whether the well on which the meter is installed is an exempt well or a permitted well.

(5)

Purpose of Use. The purpose of use of groundwater withdrawn from the well on which the meter is installed stated in definite terms. If the groundwater is used for more than one purpose, the approximate amount to be used for each purpose shall be stated.

(6)

Description of the Meter. A description of the meter or alternative measuring method including:

(A)

a description of the method used to measure the flow rate;

(B)

a description of the method used to measure the cumulative amount of groundwater withdrawn from the aquifer;

(C)

its size;

(D)

the units in which the measurements will be recorded;

(E)

a statement describing its accuracy;

(F)

a description of the manufacturer's quality control and assurance program;

(G)

its normal operating range;

(H)

its pressure rating;

(I)

a description of its construction materials;

(J)

a description of its design;

(K)

a description of its mechanical operation;

(L)

a statement of whether the totalizer is resettable;

(M)

the date that the meter was last calibrated and who calibrated it;

(N)

the maximum cumulative amount of groundwater withdrawn from the aquifer that the totalizer is capable of measuring;

(O)

a description of its instantaneous readout capabilities for flow rate and total quantity measured; and

(P)

a statement that the meter was installed according to the manufacturer's specifications.

(7)

Date Installed. The date or approximate date that the meter was installed or the alternative measuring method was first implemented.

(8)

Any other information as may be required by the general manager.

§707.413.Applications for Permits to Install or Modify Meter.

In addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Applications and Registrations), an application for a permit to install or modify meter shall contain the following:

(1)

Name and Address of Owner. The full name, post office address, and telephone number of the owner of the well on which the meter is proposed to be installed if different from the applicant.

(2)

Location. A legal description of the location of the well on which the meter is to be installed including: the county; section, block and survey; labor and league; the number of feet to the two nearest non-parallel property lines (legal survey lines); or other adequate legal description approved by the Authority.

(3)

Map. A map showing the location of the well on which the meter is to be installed.

(4)

Status of Well. Whether the well on which the meter is to be installed is an exempt well or a permitted well.

(5)

Purpose of Use. The purpose of use of groundwater withdrawn from the well on which the meter is to be installed stated in definite terms. If the groundwater is used for more than one purpose, the approximate amount to be used for each purpose shall be clearly stated.

(6)

Description of the Meter. A description of the meter or alternative measuring method including:

(A)

a description of the method used to measure the flow rate;

(B)

a description of the method used to measure the cumulative amount of groundwater withdrawn from the aquifer;

(C)

its size;

(D)

the units in which the measurements will be recorded;

(E)

a statement describing its accuracy;

(F)

a description of the manufacturer's quality control and assurance program;

(G)

its normal operating range;

(H)

its pressure rating;

(I)

a description of its construction materials;

(J)

a description of its design;

(K)

a description of its mechanical operation;

(L)

a statement of whether the totalizer is resettable;

(M)

the maximum cumulative amount of groundwater withdrawn from the aquifer that the totalizer is capable of measuring; and

(N)

a description of its instantaneous readout capabilities for flow rate and total quantity measured.

(7)

any other information as may be required by the general manager.

§707.414.Applications to Transfer Interim Authorization Status and Amend Application for Initial Regular Permit.

In addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Applications and Registrations), an application to transfer interim authorization status and amend application for initial regular permit shall contain the following with respect to both the well which currently has interim authorization status and the well (or proposed well) to which the transfer is proposed:

(1)

Names and Addresses of Owners. The full name, post office address and telephone number of the person who seeks to transfer his or her interim authorization status and the name and address of the person to whom that status is proposed to be transferred as well as the name, address, and telephone numbers of any contact persons, if different from the transferor or transferee.

(2)

Locations. A legal description of two locations of the two wells including: the county; section, block and survey, labor and league; the number of feet to the two nearest non-parallel property lines (legal survey lines); or other adequate legal description approved by the Authority.

(3)

Purposes of Use. The purpose of use for the well which has current interim authorization status and the proposed purpose of use for the well to which the transfer is proposed stated in definite terms. If the groundwater is used (or is proposed to be used) for more than one purpose, the approximate amount used for each purpose shall be clearly stated.

(4)

Withdrawal amounts. The amount of groundwater which is proposed to be withdrawn at the well to which the transfer is proposed.

(5)

Place of Use. The place of use of groundwater withdrawn from the well under interim authorization status and the place of use of groundwater withdrawn from the well to which the transfer is proposed.

(6)

Term of Transfer. The period of time for which the transfer is proposed;

(7)

A copy of the transfer agreement and any supporting documents.

(8)

The price per acre-foot or other consideration.

(9)

A meter reading taken on the last day of the month immediately preceding the month in which the application to transfer interim authorization status and amend application for initial regular permit is submitted to the Authority.

(10)

Any other information as may be required by the general manager.

§707.415.Applications to Transfer and Amend Permit.

In addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Applications and Registrations), an application to transfer and amend a permit shall contain the following with respect to both the currently permitted well and the well (or proposed well) to which the transfer is proposed:

(1)

Names and Addresses of Owners. The full name, post office address and telephone numbers of the person who seeks to transfer his or her permitted right and the name and address of the person to whom those rights are proposed to be transferred as well as the name, address, and telephone numbers of any contact persons, if different from the transferor or transferee.

(2)

Locations. A legal description of the locations of the two wells including: the county, section, block and survey, labor and league; the number of feet to the two nearest non-parallel property lines (legal survey lines); or other adequate legal description approved by the Authority.

(3)

Purpose of Use. The purpose of use for the currently permitted well and the proposed purpose of use for the well to which the transfer is proposed stated in definite terms. If the groundwater is used (or is proposed to be used) for more than one purpose, the approximate amount used for each purpose shall be clearly stated.

(4)

Withdrawal amounts. The amount of groundwater proposed to be withdrawn at the well to which the transfer is proposed.

(5)

Places of use. The place of use of groundwater withdrawn from the permitted well and the place of use of groundwater withdrawn from the well to which the transfer is proposed.

(6)

Term of Transfer. The period of time for which the transfer is proposed.

(7)

A copy of transfer agreement and any supporting documents.

(8)

The price per acre-foot or other consideration.

(9)

A meter reading taken on the last day of the month immediately preceding the month in which the application to transfer permit is submitted to the Authority.

(10)

Any other information as may be required by the general manager.

§707.416.Applications for Exempt Well Status.

In addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Applications and Registrations), an application for exempt well status shall contain the following:

(1)

Name and Address of Owner. The full name, post office address and telephone number of the owner of the well (or proposed well) if different from that of the applicant.

(2)

Location. A legal description of the location of the well (or proposed well), including: the county, section, block and survey, labor and league; the number of feet to the two nearest non-parallel property lines (legal survey lines); or other adequate legal description approved by the Authority.

(3)

Map. A map showing the location of the well (or proposed well).

(4)

Purpose of Use. The purpose (or proposed purpose) of use stated in definite terms. If the groundwater is used (or is proposed to be used) for more than one purpose, the approximate amount used (or proposed to be used) for each purpose shall be clearly stated.

(5)

Maximum Amount of Withdrawal Per Day. The maximum amount of groundwater that the well (or proposed well) is (or will be) capable of withdrawing per day stated in gallons.

(6)

Rate of Withdrawal. The maximum rate of withdrawal of groundwater that the well (or proposed well) is (or will be) is capable of producing in gallons per minute or cubic feet per second.

(7)

Depth. The depth or proposed depth of the well, the depth of the cement casing, and other well specifications.

(8)

Pump. The size of the pump and pumping method.

(9)

Date of Construction. The approximate date that the well was constructed (or will be constructed).

(10)

Other Permits. A list of all other permits applied for or issued by the Authority to the applicant.

(11)

A statement as to whether the well (or proposed well) is within a subdivision requiring platting pursuant to Chapter 711, Subchapter C, of this title (relating to Groundwater Withdrawal Permits).

(12)

A statement as to whether the well (or proposed well) serves (or will serve) a subdivision requiring platting pursuant to Chapter 711, Subchapter C, of this title.

(13)

Plat. If the well (or proposed well) is within or serves a subdivision requiring platting pursuant to Chapter 711, Subchapter C, of this title, the applicant shall include a copy of any plat prepared for that subdivision.

(14)

Any other information as may be required by the general manager.

§707.428.Applications to Convert Base Irrigation Groundwater.

In addition to the information specified in §707.401 of this title (relating to Contents of and Requirements for All Applications and Registrations), an application to convert base irrigation groundwater shall contain the following:

(1)

Names and Addresses of Owners. The full name, post office address and telephone numbers of the person who owns a regular permit.

(2)

Physical Impossibility. If the application is based on physical impossibility, a detailed description of all facts demonstrating that it is physically impossible for the owner of a regular permit, or an applicant for a regular permit for a well qualifying for interim authorization status, to place base irrigation groundwater to beneficial use at the place of use identified in the regular permit or the application for an initial regular permit.

(3)

Conservation. If the application is based on conservation:

(A)

A statement that groundwater from the aquifer has been conserved after the installation of water conservation equipment;

(B)

Location. A legal description of the location of the water conservation equipment including: the county, section, block and survey, labor and league; the number of feet to the two nearest non-parallel property lines (legal survey lines); or other adequate legal description approved by the Authority;

(C)

Map. A map showing the location of the water conservation equipment;

(D)

Description of the Water Conservation Equipment. A description of the water conservation equipment:

(E)

Measurement Method. A description of the method used to measure the amount of groundwater from the aquifer cumulatively conserved on an annual basis;

(F)

Efficiency. A statement describing the efficiency of the water conservation equipment;

(G)

Quality Control. A description of the manufacturer's quality control and assurance program;

(H)

Operating Range. A description of the water conservation equipment's normal operating range;

(I)

Materials. A description of the water conservation equipment's construction materials;

(J)

Design. A description of the equipment's design;

(K)

Mechanical Operation. A description of the equipment's mechanical operation;

(L)

Operational Life. An estimate of the maximum period of time that the equipment will be reasonably functional in conserving groundwater from the aquifer;

(M)

Factory Specifications. A statement that the equipment was installed according to the manufacturer's specifications.

(N)

Date Installed. The date that the equipment was installed.

(O)

Any other information as may be required by the general manager.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007348

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter F. ACTIONS ON APPLICATIONS AND REGISTRATIONS BY THE AUTHORITY

31 TAC §§707.501-707.519

The new sections are adopted pursuant to §§1.08(a), 1.11(a), 1.11(b), 1.11(d)(1), 1.11(h), 1.15(a), 1.15(b), 1.15(c), 1.16(a), 1.16(b). 1.16(c), 1.16(d), 1.17(a), 1.17(b), 1.18, 1.19(a), 1.20, 1.24(c), 1.29(f), 1.29(g), 1.33(a), 1.33(b), 1.34(a), and 1.34(c) of the Act and §2001.004(1) of the Texas Administrative Procedure Act (Texas Government CODE Annotated, §§2001.001-.902 (Vernon 2000)) ("APA").

§707.504.Technical Review.

(a)

After an application is determined by the general manager to be administratively complete, Authority staff shall commence a technical review of the application as necessary and appropriate. Authority staff shall complete the technical review of an application within 90 business days of the determination, by the general manager, of the application's administrative completeness. For applications for emergency permits, such review shall be conducted within 20 business days.

(b)

The applicant shall be promptly notified in writing of any additional material necessary for a complete technical review. If the applicant provides the information within the period of time noted in subsection (a) of this section, Authority staff will complete the technical review of the application within the original technical review period extended by the number of days from the request to the submittal of the additional information. If the necessary additional information is not received by the general manager before expiration of the technical review period and the information is considered essential by the general manager, the general manager may return the application to the applicant. In no event, however, will the applicant have fewer than 30 days to provide the technical data before an application is returned. Decisions to return an application to the applicant during the technical review will be made on a case-by-case basis.

(c)

The general manager or his designee is entitled to enter public or private property at any reasonable time and upon reasonable notice for the purpose of inspecting, investigating or verifying conditions or information submitted in connection with an application or a registration.

§707.510.Publication of Notice of Proposed Permit and Technical Summary in the Texas Register and in Local Newspapers.

(a)

Applicability. This section applies to applications for initial regular permits, additional regular permits, term permits, aquifer recharge and storage permits, and recharge recovery permits. This section also applies to:

(1)

applications to transfer interim authorization status and amend application for initial regular permit where the location of the point of withdrawal is proposed to be transferred from west of Cibolo Creek to east of Cibolo Creek; and

(2)

applications to transfer and amend permit where the location of the point of withdrawal is proposed to be transferred from west of Cibolo Creek to east of Cibolo Creek; and

(b)

Upon receipt of the proposed permit, approval, authorization or denial, and the technical summary from the general manager, the docket clerk shall arrange for publication of a notice of the proposed permit, approval, authorization or denial, and technical summary in:

(1)

the Texas Register ;

(2)

a newspaper of general circulation throughout the Authority's jurisdiction; and

(3)

at least five other newspapers within the jurisdiction of the Authority.

(c)

Time of Publication. The notice referred to in subsection (b) of this section shall be published no later than 30 days following the referral of the proposed permit, approval, authorization or denial to the docket clerk.

(d)

Such notice shall contain:

(1)

a description of the proposed permit, authorization or approval including any conditions;

(2)

a brief description of the technical summary; and

(3)

a statement that a copy of the proposed permit or approval, technical summary, and application are available for inspection by the public at the offices of the Authority;

(4)

if the proposal is that the application be denied, a summary of the reasons for denial;

(5)

a statement that the proposed permit, approval, authorization or denial will be presented to the Board for action within 60 days unless a request for hearing is submitted within 30 days pursuant to §§707.601-707.604 of this title (relating to Procedures for Contested Case Hearings on Applications); and

(6)

a statement that the applicant, another applicant for a groundwater withdrawal permit, or a permittee holding a groundwater withdrawal permit may request a hearing on this application by filing with the docket clerk, on or before the 30th day after the publication of the notice of the proposed permit, authorization, approval or denial, and technical summary, in the Texas Register , in accordance with §§707.601-707.604 of this title.

§707.515.Actions on Applications by the General Manager.

(a)

The purpose of this section is to delegate authority to the general manager to take action on behalf of the board for the actions listed in subsection (b) of this section.

(b)

The general manager may grant the following:

(1)

applications for new well construction permits;

(2)

applications for exempt well status

(3)

applications for permit to install or modify meter or alternative measuring method installation;

(4)

applications to:

(A)

transfer interim authorization status and amend application for initial regular permit; or

(B)

transfer and amend permit in all instances other than when the location of the point of withdrawal is proposed to be transferred from west of Cibolo Creek to east of Cibolo Creek;

(5)

applications for operation of monitoring well;

(6)

applications for conservation plan approval; and

(7)

applications for reuse plan approval.

(c)

Following technical review, the general manager may grant a permit, authorization or approval under this section if:

(1)

the application meets all relevant statutory and administrative criteria; and

(2)

the application does not raise new issues that require the interpretation of Authority policy.

(d)

The general manager shall inform the applicant of his or her decision, where appropriate, by sending a copy of such permit, authorization or approval along with the technical summary to the applicant by certified mail/return-receipt requested.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007349

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter G. PROCEDURES FOR CONTESTED CASE HEARINGS ON APPLICATIONS

31 TAC §§707.601-707.626

The new sections are adopted pursuant to §§1.08(a), 1.11(a), 1.11(b), 1.11(d)(1), 1.11(h), 1.15(a), 1.15(b), 1.15(c), 1.16(a), 1.16(b). 1.16(c), 1.16(d), 1.17(a), 1.17(b), 1.18, 1.19(a), 1.20, 1.24(c), 1.29(f), 1.29(g), 1.33(a), 1.33(b), 1.34(a), and 1.34(c) of the Act and §2001.004(1) of the Texas Administrative Procedure Act (Texas Government CODE Annotated, §§2001.001-.902 (Vernon 2000)) ("APA").

§707.601.Applicability.

The provisions of this subchapter apply to contested case hearings on applications before the board. Contested case hearings may be requested and granted in connection with applications for initial regular permits, additional regular permits, term permits, aquifer recharge and storage permits, and recharge recovery permits. Contested case hearings may also be requested and granted in connection with:

(1)

applications to transfer interim authorization status and amend application for initial regular permit where the location of the point of withdrawal is proposed to be transferred from west of Cibolo Creek to east of Cibolo Creek; and

(2)

applications to transfer and amend permit, where the location of the point of withdrawal is proposed to be transferred from west of Cibolo Creek to east of Cibolo Creek.

§707.604.Time for Filing of Request for Contested Case Hearing.

Unless a longer time limit is specified in the notice of the proposed permit and technical summary, a hearing request must be filed with the docket clerk on or before the 30th day following the date of publication of that notice in the Texas Register .

§707.605.Processing of Hearing Request.

(a)

Applicability. The requirements in this section apply only to hearing requests that are filed within the time period specified in §707.604 of this title (relating to Time for Filing of Request for Contested Case Hearing). Hearing requests not filed within the time period specified in §707.604 of this title shall not be processed and shall be returned by the docket clerk to the person filing the request.

(b)

After a hearing request is filed, the docket clerk shall schedule the hearing request for a board meeting.

(c)

The docket clerk shall provide notice to the applicant, general manager and any persons making a timely hearing request at least 30 20 days prior to the first meeting at which the board considers the request. The docket clerk shall explain how the person may submit public comment, explain that the board may hold a public meeting, and explain the requirements of this subchapter.

(d)

Persons may submit written responses to the hearing request no later than 20 days before a board meeting at which the board will evaluate the hearing request. Responses shall be filed with the docket clerk and served on the same day to the general manager, the applicant and any persons filing hearing requests.

(e)

The person who filed the hearing request may submit a written reply to a response no later than six days before the scheduled board meeting at which the board will evaluate the hearing request. A reply may also contain additional information responding to the notice by the docket clerk required by subsection (d) of this section. A reply shall be filed with the docket clerk and served on the same day to the general manager, the applicant, and any person filing hearing requests.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007350

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Chapter 709. FEES

I. INTRODUCTION.

The Edwards Aquifer Authority ("Authority") adopts new 31 TAC, §§ 709.1, 709.3, 709.5, 709.7, 709.9, 709.11, 709.13, 709.15, 709.17, 709.19, 709.21, 709.23, 709.25, 709.27, 709.29, 709.31, 709.33, and 709.35, consisting of rules relating to the fee structure of the Authority. Sections 709.11, 709.19, and 709.21 are adopted with changes to the proposed text as published in the August 11, 2000, issue of the Texas Register (25 TexReg 7533-7548). Sections 709.1, 709.3, 709.5, 709.7, 709.9, 709.13, 709.15, 709.17, 709.23, 709.25, 709.27, 709.29, 709.31, 709.33, and 709.35 are adopted without changes to the proposed text and will not be republished.

These rules have been written to establish the Authority's procedures for implementing and collecting fees.

II. SUMMARY OF THE FACTUAL BASIS FOR THE ADOPTED RULES; AND CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The Authority is required by the Edwards Aquifer Authority Act (Act of May 30, 1993, 73rd Legislature, Regular Session, Chapter 626, 1993 Texas General Laws 2350, 2358-59, as amended by Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 261, 1995 Texas General Laws 2505, Act of May 16, 1995, 74th Legislature, Regular Session, Chapter 524, 1995 Texas General Laws 3280, and Act of May 6, 1999, 76th Legislature, Regular Session, Chapter 163, 1999 Texas General Laws 634 ("Act")), to implement Edwards Aquifer management programs relating to, among other things, fees, exempt wells, interim authorization, permitted wells, permit conditions, groundwater available for permitting, proportional adjustment, equal percentage reduction, abandonment and cancellation of permits, aquifer recharge, storage and recovery, additional groundwater supplies available for permitting, transfers, meters and alternative measuring methods, groundwater trust, water quality, and comprehensive water management plan implementation. In order to generate revenue to fund the implementation of these programs and to regulate the use of the aquifer, the Authority must establish a uniform fee system. In these rules, the Authority is establishing rules setting forth the various types of fees imposed by the Authority and providing procedures for the adoption and assessment, as well as the billing and collection, of those fees.

The new sections are adopted pursuant to §§ 1.08(a), 1.11(a), (b), (d)(2), (f), and (h), 1.15(a), 1.16(b) and (d)(1), 1.29(a), (b), (c), (d), (e), (f), (g), and (h), 1.36(b), 1.44(c)(2) of the Act; § 2001.004(1) of the Texas Administrative Procedure Act (Texas Government Code Annotated, §§ 2001.001-.902 (Vernon 2000)) ("APA"); and § 36.205 of the Texas Water Code (Texas Water Code Annotated, § 36.205 (Vernon 2000)). The Authority interprets these sections as authorizing the Authority to adopt rules establishing a fee structure for the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rules governing procedures of the Board and the authority." This section directs the Board to adopt rules as necessary to implement the various substantive programs set forth in the Act related to the Edwards Aquifer, which includes application, registration, aquifer management, and regular permit special retirement fees, and in particular, administrative procedures to be used before the Board and the Authority.

Section 1.11(b) of the Act requires the Authority "ensure compliance with permitting, metering, and reporting requirements and shall regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, empowers the Authority to establish procedures related to the filing and processing of various applications and registrations with and by the Authority.

Section 1.11(d)(2) of the Act provides, among other things, that the Authority may enter into contracts.

Section 1.11(f) of the Act provides the Authority may contract with a person who uses water from the aquifer for the Authority or that person to construct, operate, own, finance, and maintain water supply facilities which include a dam, reservoir, treatment facility, transmission facility, or recharge project. This section further provides management fees or special fees may not be used for purchasing or operating these facilities.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. Pursuant to this section, the Authority is required to comply with the APA in connection with its rulemaking, even though the Authority is not a state agency and would therefore otherwise not generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.15(a) of the Act directs the Authority to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by this Act.

Section 1.16(b) of the Act sets forth certain requirements concerning an existing user's declaration of historical use and an applicant's payment of application fees required by the Board.

Section 1.16(d)(1) of the Act requires the Board to grant an initial regular permit to an existing user who, among other things, files a declaration and pays fees as required by this section.

Section 1.29(a) of the Act relates to fees. This section provides that the allocation of the cost of reducing withdrawals or permit retirements must be borne: solely by users of the aquifer for reducing withdrawals from the level on the effective date of this article to 450,000 acre-feet a year, or the adjusted amount determined under § 1.14(b) for the period ending December 31, 2007; and equally by downstream water rights holders for permit retirements from 450,000 acre-feet a year, or the adjusted amount determined under § 1.14(d) for the period ending December 31, 2007, to 400,000 acre-feet a year, or the adjusted amount determined under §1.14(d) for the period beginning January 1, 2008.

Section 1.29(b) of the Act provides for the assessment of aquifer management fees based on aquifer use under the water management plan to finance the Authority's authorized administrative expenses and programs. This section also allows water districts governed by Chapter 52 of the Texas Water Code and within the Authority's boundaries, to contract with the Authority to pay the Authority's expenses through taxes in lieu of user fees, to be paid by water users in the district. This section provides the Authority with the power to assess fees in order to generate revenue to finance the operation of the Authority in its regulation of the aquifer, however, the Authority may not collect a total amount of fees and taxes that is more than is reasonably necessary for the administration of the Authority.

Section 1.29(c) of the Act provides that the Authority shall assess an equitable special fee based on permitted aquifer water rights to be used only to finance the retirement of rights necessary to meet the goals of the Authority for reducing the maximum annual volume of water withdrawals from the aquifer. The section further provides the Authority shall set the fees on permitted aquifer users at a level sufficient to match the funds raised from the assessment of equitable special fees on downstream water rights holders.

Section 1.29(d) of the Act provides for the assessment of equitable special fees by the Commission on all downstream water rights holders in the Guadalupe River Basin to be used to finance the retirement of aquifer rights necessary to meet the goals of the Authority for reducing the maximum annual volume of water withdrawals from the aquifer. This section further provides that downstream water rights holders shall pay the assessed fees to the Authority. This section prohibits the assessment of fees by the Commission on contractual deliveries of water stored in Canyon Lake that may be diverted downstream of the San Marcos Springs or Canyon Dam.

Section 1.29(e) of the Act provides for the development of an equitable fee structure under § 1.29 and authorizes the Authority to establish different fee rates on a per acre-foot basis for different types of use. The fees must be equitable between types of uses and shall be assessed on the amount of water a permit holder is authorized to withdraw under the permit. Aquifer management fee rates for agricultural use shall be based on the volume of water withdrawn and may not be more than 20 percent of the fee rate for municipal use. Aquifer management fees rates for non-agricultural users are to be based on the face value of a permittee's initial regular permit or the amount authorized to be withdrawn under interim authorization status.

Section 1.29(f) of the Act requires the Authority to impose a permit application fee of not more than $25.

Section 1.29(g) of the Act empowers the Authority to impose a registration application fee of not more than $10.

Section 1.29(h) of the Act states that special fees collected under subsection (c) or (d) of §1.29 may not be used to finance a surface water supply reservoir project.

Section 1.36(b) of the Act provides the Authority with enforcement power and states that Authority shall provide for the suspension of a permit of any class for failure to pay a required fee or for a violation of a permit condition, order of the Authority, or rule adopted by the Authority.

Section 1.44(c)(2) of the Act relates to cooperative contracts for artificial recharge and states the political subdivision causing artificial recharge of the aquifer is entitled to withdraw during any 12-month period the measured amount of water actually injected or artificially recharged during the preceding 12-month period, as demonstrated and established by expert testimony, less an amount determined by the Authority to account for that part of the artificially recharged water discharged through springs, and to compensate the Authority in lieu of users' fees.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This proposed rulemaking is in furtherance of this legislative mandate. These proposed rules are rules of practice that state the procedures applicable to the fee setting process of the Authority.

Section 36.205 of the Texas Water Code authorizes groundwater conservation districts to set fees for administrative acts of the districts. Such fees may not unreasonably exceed the cost to the district of performing the administrative function for which the fee is charged.

Subchapter A

Subchapter A consists solely of § 709.1 which contains the definitions of eleven terms that are central to the establishment and management of a uniformly understandable multi-tiered fee system. These terms are used in substantive sections here and throughout other chapters in this rulemaking. The definitions are necessary to provide a factually accurate short-form elaboration of elements (terms) that are necessary for the rational implementation of a fee system that is consistent with the intent of the Act.

Although the term "agricultural use" is used in § 1.29(e) of the Act, it is not defined in the Act. The Authority has defined "agricultural use" in § 709.1(1) as the "the use of water for irrigation use." Irrigation use is defined in § 1.03(12) of the Act as "the use of water for the irrigation of pastures and commercial crops, including orchards." There are numerous facts that support the Authority's definition of "agricultural use." A review of the legislative history of the Act reveals there is no reference by the Legislature to a specific definition of agricultural use, even though such definitions exist in other Texas statutes. The Authority interprets this lack of reference as some evidence that the Legislature did not intend to bind the Authority to an existing definition; rather it intended a definition be created by the Authority consistent with the Act.

Additional facts supporting the definition of agricultural use are derived from § 1.29(e) of the Act and § 709.19 in Chapter 709 which provide that agricultural users pay aquifer management fees at an amount no more than 20 percent of the fee for non-agricultural users (the "20 percent rule"). It is the Authority's position that the 20 percent rule is designed for those water users who cannot pass on the added cost of aquifer management fees to consumers, such as irrigators. There are many users who may qualify as an agricultural user under other law, yet may be able to pass on the additional overhead due to the assessment of an aquifer management fee because they control their pricing structure. These users are not intended to have the benefit of the 20 percent rule and are therefore not included in the definition.

Additional support for the definition of agricultural use is found in the categories of beneficial use specifically identified in the Act. Under the Act, there are three types of beneficial use subject to permitting rules: municipal use, industrial use and irrigation use. Of these three types of use, only irrigation use is reasonably close in nature to agricultural use. As such, defining agricultural use to be the use of water for irrigation use is logical and supported by the Act.

Section 709.1(2) defines "annual operating revenue requirement" as the total revenues reflected in an annual budget adopted by the board that are reasonably required to adequately meet all the projected costs of aquifer management by the Authority. Section 1.29(b) of the Act authorizes aquifer management fees to finance the Authority's administrative expenses and programs. The section further provides that the Authority may not collect an amount of fees that is more than is reasonably necessary for its administration. In order to establish rules implementing an aquifer management fee program within the boundaries authorized by the Act, certain definitions had to be written. The definition of "annual operating revenue requirement" is the benchmark used for the aquifer management fee program. This definition establishes the figure that will be reflected in the Authority's annual budget that will serve as the basis for the calculation and assessment of aquifer management fees.

"Aquifer use" is defined in § 709.1(3) as the withdrawal of groundwater from the aquifer under interim authorization status or under a permit issued by the board. The definition is necessary because "aquifer use" would generally be considered to be the "end use" of the groundwater for its ultimate beneficial use. On the other hand, it could mean the volume of withdrawals of groundwater from the aquifer. There is a difference between the amount of "withdrawals" and the amount of "beneficial use." For purposes of aquifer management fees, the Authority's point of compliance is at the meter on the wellhead, not at the ultimate place of use. The volume of groundwater that is withdrawn is what the aquifer management fee should be assessed against, not the amount that is applied at the place of use for beneficial use. A definition of "aquifer use" is required to clarify that the aquifer management fee is assessed against the volume of groundwater withdrawn rather than the volume that may be applied to beneficial use.

"Cash needs approach" is defined in § 709.1(4) of Chapter 709 and provides the basis for how the annual operating revenue requirement (§709.1(2)) of the Authority is determined. The definition is required to more clearly define what costs and cash needs are considered by the Authority when determining the annual operating revenue requirement.

The definition of "costs of aquifer management" in § 709.1(5) is required because that term is used in the definition of annual operating revenue requirement in § 709.1(2) above. It is necessary to clarify what costs are contemplated by the Authority when determining the annual operating revenue requirement.

The definition of "downstream water right holder" in § 709.1(6) is based on § 1.29(d) of the Act which states that equitable special fees shall be assessed on "all downstream water rights holders in the Guadalupe River Basin." This term is not defined by the Act, however, it is necessary to include this definition so the water right holders included in the category and subject to permit retirement special fees, are clearly defined. The orifices of the springs are the point of reference for determining which water users are "downstream" for purposes of assessment of the permit retirement special fees.

The definition of "fiscal year" in § 709.1(7) is necessary to clearly define the period of time that is the basis of the Authority's fee programs and budgetary and administrative process.

"Non-agricultural use" is defined in § 709.1(8). This definition is necessary to define the beneficial use that is not considered "agricultural use" and, therefore, not entitled to the 20 percent rule under § 709.19. In addition, this definition is necessary to determine how the Authority will calculate and assess the aquifer management fee. Section 1.29(e) of the Act authorizes the Authority to establish different fee rates for different types of use. In order to implement this provision in the rules, it is necessary to define "non-agricultural use."

Section 709.1(10) contains the definition of "permit retirement special fee" which is based on § 1.29(c) of the Act. This provision in the Act allows the Authority to assess an equitable special fee based on permitted aquifer water rights to be used to finance the retirement of rights. In order to implement § 1.29(c) of the Act, a definition was necessary to clearly establish what the fee contemplated in that provision would be called and how it would be defined. This eliminates confusion with other fees authorized by the Act and makes clear the statutory basis for the fee.

Section 709.1(11) defines a "unit cost basis" as "the amount of a fee expressed in dollars per acre-foot per annum." Because the Act and the rules refer to water in increments of "acre-feet" such a definition is required in order to apply a fee amount to each increment on an annual basis.

Finally, all the definitions contained in § 709.1 provide the basis for a common regulatory language which enables regulated persons and entities and the general public to communicate effectively with the Authority.

Subchapter B

Subchapter B consists of three sections (§§ 709.3 -709.7) that address the establishment of a $10.00 fee for registration applications. Establishment of the registration fee is consistent with § 1.29(g) of the Act which states that the "Authority may impose a registration application fee not to exceed $10." Although the Act does not require a registration fee, the Authority has determined that it is fiscally reasonable and prudent to assess the fee for filing any registration application. While the registration process is relatively simple, it nonetheless, has an administrative cost and has a cumulative impact on the Authority's budget. The registration fee helps offset that cost.

Section 709.7 dealing with Enforcement for Nonpayment, states that the general manager may refuse to accept for filing, or otherwise process, a registration application if the fee is not paid. Other actions authorized by law also may be used to enforce the fee requirement in this subchapter. This section is consistent with § 1.36 of the Act relating to Enforcement which states the Authority "may enter orders to enforce the terms and conditions of permits, orders, or rules issued or adopted under this article." Collection of these fees is central to the ability of the Authority to finance its operations pursuant to the requirements of the Act. As such, a uniform system of enforcement is necessary to ensure collection of the fees.

Subchapter C

Subchapter C consists of three sections (§§ 709.9 - 709.13) that address the establishment of a $25 fee for filing with the Authority any application, including but not limited to, an application for a regular, term, or an emergency groundwater withdrawal permit, a well construction permit, monitoring well permit, aquifer recharge and storage permit and recharge recovery permits. Establishment of the permit application fee is in compliance with § 1.29 (f) of the Act which states the Authority "shall impose a permit application fee not to exceed $25."

Although the Act states the fee shall not exceed $25, the Authority has determined that it is fiscally reasonable and prudent to assess the full amount allowed by the Act for filing any permit. The permit application process has an administrative cost and has a cumulative impact on the Authority's budget. The permit application fee helps offset the cost.

Section 709.13 dealing with Enforcement for Nonpayment, states that the general manager may refuse to accept for filing, or otherwise process, a permit application if the fee is not paid. This section is consistent with § 1.36 of the Act relating to Enforcement which states the Authority "may enter orders to enforce the terms and conditions of permits, orders, or rules issued or adopted under this article." Collection of these fees is central to the ability of the Authority to finance its operations pursuant to the requirements of the Act. As such, a uniform system of enforcement is necessary to ensure collection of the fees.

Subchapter D

Subchapter D consists of eleven sections (§§ 709.15 -709.35) relating to aquifer management fees. Section 709.15 sets forth the purpose of rules in this subchapter which is to establish the basis for calculation, assessment, billing and collection of aquifer management fees in a manner that is consistent with §§ 1.11 (f) and 1.29 (b) and (e) of the Act. Section 1.29(b) of the Act states that the "Authority shall assess equitable aquifer management fees based on aquifer use under the water management plan to finance its administrative expenses and programs . . .."

Section 709.17 is a direct reflection of the fact that the Authority has determined that a fair, balanced and fiscally responsible fee system should be applicable to all aquifer use except for withdrawals of groundwater from wells which are exempt under §§ 1.16 (c) and 1.33 of the Act. Section 1.16(c) of the Act states that the "owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under § 1.33 of this article is not required to file a declaration of historical use." Section 1.33 of the Act provides that a "well that produces 25,000 gallons of water a day or less for domestic or livestock use is exempt from metering requirements." These provisions in the Act have been properly incorporated into the Authority's rules regarding aquifer management fees.

Section 1.29 of the Act requires that the Authority develop, assess, bill, and collect an aquifer management fee. However, the Act does not set out the procedures for these various processes. A typical approach in the development of a regulatory fee such as the aquifer management fee, would be for the agency to develop and adopt a budget in order to identify their revenue requirements for the appropriate fiscal year. Generally, once a budget is developed, the fee may be determined by dividing into the budget the number of acre-feet that are anticipated to be withdrawn or authorized to be withdrawn, as appropriate, in a fiscal year. Section 709.19 describes step-by-step procedures for the adoption and assessment of an aquifer management fee for the succeeding year. The fee is based on aquifer use consistent with § 1.29 (e) of the Act which authorizes the Authority to establish different fee rates on a per acre-foot basis for different types of use. In order to implement the intent of the Act, the Authority has established two user blocks:

Block 1: non-agricultural users; and

Block 2: agricultural users.

In order to establish an equitable fee structure under § 1.29(e) of the Act, the Authority developed a framework based on its annual operating revenue requirements, the total volume of annual aquifer use for Block 1 users, carryover funding from the previous fiscal year, calculated revenue from Block 2 users and other sources of potential revenue. After the net annual operating revenue requirement is determined, it is divided by the total authorized or contracted aquifer use for Block 1 (non-agricultural) users. Subsequently, under §709.19(d) as modified, the Authority calculates the aquifer management fee for Block 2 (agricultural) users at $3.00 per acre-foot for base irrigation groundwater and at an amount not more than 20 percent of the Block 1 unit cost per year for unrestricted irrigation groundwater. The unit cost is expressed in dollars per acre-foot per year. The intended effect of this approach is to provide for an equitable fee structure by establishing a uniform average unit cost of groundwater by type of use, regardless of quantity withdrawn, and bifurcating the aquifer management fee for agricultural use between base and unrestricted irrigation groundwater as discussed above.

Section 1.29 of the Act requires that the Authority develop, assess, bill, and collect an aquifer management fee. However, the Act does not set out the procedures for these various processes. Section 709.21 provides procedures for billing and collection of aquifer management fees for all persons authorized for aquifer use under interim authorization status pursuant to § 1.17 of the Act and rules of the Authority, or under a final groundwater withdrawal permit issued by the Board. The rule implements the requirements of § 1.29 (e) by establishing a billing system that charges agricultural users for the actual volume of groundwater withdrawn from the aquifer in a calendar year. Non-agricultural user fees are assessed on either the historical maximum beneficial use (for interim status under § 1.17 of the Act) or total groundwater authorized to be withdrawn in a final permit issued by the Board, irrespective of whether groundwater was withdrawn in either case.

The balance of the discussion in § 709.21 describes invoicing, payment schedules, collection mechanisms, late fees and other details essential to developing and maintaining an orderly and predictable system for collecting aquifer management fees from the two Blocks of users, unless subject to a user contract under § 709.25 of the rules. The basis for the rule is the establishment of an understandable and reasonable framework for billing and effectively collecting aquifer management fees.

Section 709.23 states that the Authority may not collect a total amount of aquifer management fees that is more than reasonably necessary for the annual operating revenue requirements for the administration of the Authority as reflected in its adopted annual fiscal year budget. The basis for this rule is the limitation on fees and taxes found in § 1.29 (b) of the Act which states that the amount collected may not be "more than is reasonably necessary for the administration of the Authority."

Section 709.25 encourages water conservation by allowing the general manager to contract with any non-agricultural user for the user to commit to aquifer use that is less than the amount to which the user would otherwise be authorized. The incentive for non-agricultural users to contract for a lower volume of groundwater withdrawal from the aquifer is the assessment by the Authority of a proportionately lower aquifer management fee. In order to retain long-term flexibility for water planning by the Authority, the rule provides a maximum term of one year for user contracts. The basis for the rule, conservation incentives for Block 1 users, is consistent with planned reductions in withdrawals from the aquifer consistent with the Act.

Section 709.27 establishes an effective period of one calendar year for aquifer management fees calculated and assessed by the general manager. The annual basis of the aquifer management fee is tied to the Authority's need to meet its annual operating revenue requirements. The use of a calendar year for the calculation and assessment of the aquifer management fee allows the Authority to manage the aquifer management fee system in conjunction with its annual budgetary process.

Section 709.29 prohibits the Authority from expending aquifer management fee revenues for the purchase or operation of water supply facilities. The aquifer management fee system is specifically linked to the Authority's need to meet its annual operating revenue requirements. Expenditures based on aquifer management fee revenues for other purposes are not contemplated by the rule. This rule will ensure that aquifer management fee revenues collected by the Authority are used as intended by the Act.

Section 709.31 allows the Authority, under conditions spelled out in the rule, to waive fees in the form of an offset if an aquifer user is required to pay aquifer management fees to the Authority and the Authority owes money to the user. The basis of the waiver is an attempt to simplify, by contract, the transfer of money between the Authority and regulated users.

Section 709.33, Enforcement for Nonpayment, states that the general manager may suspend the processing of any application if there is a determination that the applicant is delinquent on payment of an aquifer management fee. In addition, the general manager may take other actions authorized by law to enforce the fee requirement in this subchapter. This section is consistent with § 1.36 of the Act relating to Enforcement which states the Authority "may enter orders to enforce the terms and conditions of permits, orders, or rules issued or adopted under this article." Uniform enforcement of the collection of aquifer management fees is central to the ability of the Authority to finance its operations pursuant to the requirements of the Act.

Section 709.35 prohibits withdrawal of groundwater from the aquifer by any person if the person, or his predecessor in interest, is delinquent in the payment of an aquifer management fee that is due and payable to the Authority. Uniform enforcement of this prohibition works in concert with § 709.33, Enforcement for Nonpayment, to protect the aquifer from unauthorized withdrawals and assure collection of aquifer management fees. Collection of these fees is central to the ability of the Authority to finance its operations pursuant to the requirements of the Act.

III. REGULATORY IMPACT ANALYSIS OF MAJOR ENVIRONMENTAL RULES.

Section 2001.0225 of the Texas Government Code requires an agency to perform, under certain circumstances, a regulatory analysis of "major environmental rules." The Authority has determined that none of the rules are "major environmental rules" as that term is defined by §2001.0225(g)(3) of the Texas Government Code. The basis for this determination is that the rules do not have the specific intent to "protect the environment" or "reduce risks to human health from environmental exposure." The specific intent of these rules is to provide an outline of procedures for implementing and collecting fees by the Authority, resulting in the development of a uniform fee system that generates revenue for the Authority. This revenue is used by the Authority to regulate the use of the aquifer. For this reason, the Authority finds that none of the rules are "major environmental rules" and that, therefore, no further analysis is required by § 2001.0225 of the Texas Government Code.

IV. TEXAS PRIVATE REAL PROPERTY RIGHTS PRESERVATION ACT.

Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act," requires governmental entities, under certain circumstances, to prepare a takings impact assessment ("TIA") in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the adoption of these rules. First, the Authority has made a "categorical determination" that rules establishing procedures for implementing and collecting fees do not affect private real property. These rules set forth the various types of fees imposed by the Authority and provide procedures for the adoption and assessment, as well as the billing and collection, of those fees. They have no direct affect on private real property and may not result in a taking. Second, the Authority's action in adopting these rules is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from the Texas Private Real Property Rights Preservation Act under § 2007.003(b)(4) of the Texas Government Code. See Act §§ 1.08(a), 1.11(a), (b), (d)(2), (f), and (h), 1.15(a), 1.16(b) and (d)(1), 1.29(a), (b), (c), (d), (e), (f), (g), and (h), 1.36(b), 1.44(c)(2) of the Act; § 2001.004(1) of the APA; and § 36.205 of the Texas Water Code . It was held in Edwards Aquifer Authority v. Bragg, 21 S.W.3d. 375 (Tex. App. -- San Antonio 2000, pet. filed), that the Edwards Aquifer Act expressly mandates the adoption of substantive and procedural permitting rules and that such actions are therefore excepted from the Texas Private Real Property Rights Preservation Act. The holding in that case controls here. Third, it is the position of the Authority that all valid actions of the Authority are excluded from the Texas Private Real Property Rights Preservation Act under § 2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the adoption of these rules.

V. SUMMARY OF PUBLIC COMMENTS.

Five public hearings were held on these and other rules proposed by the Authority on: Wednesday, August 9, 2000 at 6:00 p.m. at the Conference Center of the Edwards Aquifer Authority, 1615 N. St. Mary's Street, San Antonio, Texas; Tuesday, August 15, 2000 at 6:00 p.m. at the New Braunfels Civic Center, 380 S. Seguin Avenue, New Braunfels, Texas; Thursday, August 17, 2000 at 6:00 p.m. at St. Paul's Lutheran Church, 1303 Avenue M, Hondo, Texas; Tuesday, August 22, 2000 at 6:00 p.m. at the Sgt. Willie De Leon Civic Center, 300 E. Main Street in Uvalde, Texas; and Thursday August 24, 2000 at the San Marcos Activities Center, 501 E. Hopkins, San Marcos, Texas. Oral and/or written comments on these rules were provided by Paul Aelvoet; Harold Weiblen; Thomas C. Trautner for Aldridge Nursery, Inc.; Herb Faseler; Richard Frenzel for the Bexar County Water Control and Improvement District #10 in Windcrest; Rafael Pineda; Susan Combs for the Texas Department of Agriculture; Eddy D. Edmondson for the Texas Nursery & Landscape Association; Vinson & Elkins L.L.P.; P J Ellison Kalil for Ellison's Greenhouses, Inc.; Bickerstaff, Heath, Smiley, Pollan, Kever & McDaniel, L.L.P. for the Texas Farm Bureau; David Sabalka for Color Spot Nurseries; Scott Peck, AIFD TME; Judy Rutledge for Allied Florists of Houston; Fohn Farm Inc., Joe M. Fohn, for Bobby Fohn and David Fohn; Ralph and Allen Gilliam, Gilliam Ranch; Gregory and Cora Rothe; John Persyn; Mark Lamon for the Medina County Farm Bureau; Glenn Bragg, JoLynn Bragg, and David Bragg for Bragg Pecan Farms, Inc.; Curtis Boehme, Nelson Boehme and Dorothy Boehme for S.J. Boehme & Sons Inc.; Earl & Brown; San Antonio Water System; Ken Horton for the Texas Pork Producers Association, Inc.; Ross Wilson for the Texas Cattle Feeders Association, Inc.; Jeane M. Funkhouser for Eden Etc. Florists; Jim and Ellen Ellison for Ellison's Greenhouses, Inc.; Jimmy Klepac for Klepac Greenhouses, Inc.; Gayle Johnson for the Texas State Florists' Association; M.M. McWilliam; Frank Mechler, Jr.; Glen Kriewald; Ernie Schreiner; Rudy Botello; Jerry (surname illegible); Carroll T. Keller; Edgar H. Alzlnot, Jr.; G.J. Boehme; William R. Fewell; Ralph Kohlleppel, Jr.; R.Q. Stinson; Lynn F. Boehme; Ralph Kohlleppel; Chris Schuele; David B. Carter; Gail F. Boehme; Harry Lee Keller; Tim Schott; Morris Salazar; Kye Mash; Wm. Terry (surname illegible); Marshall Persyn; (first name illegible) Haby; Raymond T.(surname illegible); Jeff Tickner; George (surname illegible); Ted Kohlleppel; David Kohlleppel; David M. (surname illegible); James G. Wernette; Gilbert Eryeso; Alvin Santlelonso; Tylar J. (surname illegible); Aubrey Freeman; David Villarreal; Pamela Gardner; Mark Mendosa; Jacinto Sala; Alex Nieto; John Mueller; Edward Moore; (first name illegible) Villarreal; (first name illegible) Vogt; Jay Rogers; J. Lyon Argell; D.A. Villarreal; John Persyn; Melvin M. Zinsmeyer; Roger T. Graff; Deborah Cox; Karen Bain; Thomas Chautner; P. Gregory; Wm. Bain; Keith Taylor; (first name illegible) A. Neumann; Robert Neumann; Glenn Weiblen; Maurice DeCork, Jr.; (first name illegible) Boehme; Harold J. Bemos; (first name illegible) Besh; Stanley Riker; William H. Reus; Austin A. Clary; Fred Schueling, Jr.; Joe M. Fohn for Fohn Farm; Donald Bush for Hidden Valley; Ronnie Muennik; Tom Verstuyft; Richard S. Sterling; Calvin Bendell; Edwin L. Yanta; Chuck (surname illegible); Deon E. Stewart; Scott Noell; (first name illegible) Wurzbach; Charles L. Noonan, Jr.; Sarah L. Tracy; Rebecca D. Faseler; Roy Reyes; Ricky Robles; Melissa Ackermann; Derek Boehme; Julie Boehme; Niesso Boehme; Pat Wylach; Kathleen D. Carskaddin; Thomas Boehme; Authur Weiblen; Corinne Davenport; Harvey Boehme; Darlene Boehme; Jeanette Boehme; (first name illegible) Keller; Cindy Hawkins; C. Ray Hawkins; Elva Hawkins; Arthur G. Isle "Tootie"; Dale K. Saatek, Jr.; Robert DeLeo, Jr.; (first name illegible) W. Banner; Mark Vish; Staci S. Boehme; Vicki Boehme; Allison Boehme; George James; Russell Meyer; Clarence Mumme; Annette Billings; Wade Swanson; Geneviere Aelvoet; Amy Soltos; (first name illegible) Linderman; Rick Aelvoet; Robert Fohn; David Fohn; Jared Boehme; Fred Weiblen; Adele Boehme; Derek M. (surname illegible); Melissa Boehme; Leah Boehme; Morris Faseler; Cordell Bohlen; Jay E. Muennik; Franklin Muennik; Malvern Jesk; Jimmy Stewart; Thomas H. Carskadden; Rebecca C. Janysek; Roy Lee Bippert; Eloise Bippert; Shawn Noonan; Lucille Bippert; Leonard Bippert; Michele D. Bippert; Troy Bippert; Kris Noonan; Wm Reichert; Bernard Echtle; Margaret M. Echtle; Michael E. Echtle; Ashley Echtle; George M. Echtle; Alfred Keller, Jr.; Agnes E. Echtle; Marcella Keller; William Echtle; Michael Weiblen; Kathy Eaton; Joy M. Persyn; Brad Haby; Rebecca J. Haby; Gary Grantham; Marsha Lanham; Jeffrey Lanham; Gladys Gembler for the Bexar County Farm Bureau; and other individuals whose first and last names were illegible on the written comments. (The Authority has made every effort to interpret the names contained in this list as accurately as possible based on the oral and written comments received).

Section 709.1(1)

Proposed § 709.1(1) sets forth the definition for "agriculture use" as "the use of water for irrigation use."

Public Comment No. 1:

Eddy D. Edmondson, Texas Nursery and Landscape Association ("TNLA"), Jeane M. Funkhouser, Eden Etc. Florists, PJ Ellison Kalil, Ellison's Greenhouses, Inc. (T.S.F.A. Grower Director), Scott Peck, AIFD TME, Judy Rutledge, TMF, Allied Florists of Houston, Jim and Ellen Ellison, Ellison's Greenhouse, Jimmy Klepac, Klepac Greenhouses Incorporated, Gayle Johnson, AAF TMF, Texas State Florists' Association, and David Sabalka, Color Spot Nurseries

propose that the definition of "agriculture use" be expanded to include nursery products so that those in the nursery business are treated as agricultural users and not industrial users under the rules. The proposed change to § 709.1(1) reads as follows:

Agricultural use- The use of water for irrigation use, "or for watering nursery products by a nursery grower as those terms are identified in the Texas Agricultural Code, Subtitle B, Chapter 71, Subchapter A, § 71.041."

Authority's Response:

The Authority staff received the above-referenced comments, and disagrees with the comments. The basis for this determination is that according to the Edwards Aquifer Authority Act (the "Act"), aquifer management fees for agricultural use are to be no more than 20% of the rate charged to municipal and industrial users. The purpose of this break in the fee structure is to protect industries having an inelastic demand for their products. There is no evidence the Act intended nurseries be included in that category. In light of the above discussion, the Authority has not modified §709.1(1) accordingly.

Public Comment No. 2:

John Riley with Vinson & Elkins, L.L.P., commented that the definition of "agricultural use" is too narrow and contrary to the intent of the Act. He maintains that restricting the definition of "agricultural use" to that of "irrigation use" makes agricultural activities more expensive. Riley believes the Legislature intended the reduced agricultural fee to be applied more broadly that just in regards to the water that is used for irrigation. Accordingly, Riley requests a clarification or change in the rule to reflect this.

Authority's Response:

The Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that according to the Act, aquifer management fees for agricultural use are to be no more than 20% of the rate charged to municipal and industrial users. The purpose of this break in the fee structure is to protect industries having an inelastic demand for their products. There is no evidence the Act intended a broader definition of "agricultural use" be used. In light of the above discussion, the Authority has not modified §709.1(1) accordingly.

Public Comment No. 3:

Douglas Caroom with Bickerstaff, Heath, Smiley, Pollan, Kever & McDaniel, L.L.P., for the Texas Farm Bureau ("TFB."), asserts that the definition omits nurseries, aquaculture, feedlot operations, and other agricultural-type operations that may use Aquifer water, denying these types of agricultural operations the benefit of the 20% fee limitation imposed by the Act. The TFB recommends that the Authority use the definition of "Agriculture" as provided in § 2.001 of the Texas Agriculture Code.

Authority's Response:

The Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that according to the Act, aquifer management fees for agricultural use are to be no more than 20% of the rate charged to municipal and industrial users. The purpose of this break in the fee structure is to protect industries having an inelastic demand for their products. There is no evidence the Act intended the operations listed by the TFB be included in that category. In light of the above discussion, the Authority has not modified §709.1(1) accordingly.

Public Comment No. 4:

Susan Combs, Commissioner of the Texas Department of Agriculture ("TDA"), asserts the Texas Legislature did not intend for the definitions "irrigation use" and "agricultural use" to have identical definitions. TDA proposes that "agricultural use" include nurseries and feedlot operations.

Authority's Response:

The Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that according to the Act, aquifer management fees for agricultural use are to be no more than 20% of the rate charged to municipal and industrial users. The purpose of this break in the fee structure is to protect industries having an inelastic demand for their products. There is no evidence the Act intended nurseries or feedlot operations be included in that category. In light of the above discussion, the Authority has not modified §709.1(1) accordingly.

Public Comment No. 5:

Ross Wilson, Vice President of the Texas Cattle Feeders Association and Ken Horton, Executive Vice President of the Texas Pork Producers Association, Inc., proposed that livestock production and the consumption of water by livestock be included in the definition of "agricultural use" and thereby entitled to the "agricultural user" fee.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that according to the Act, aquifer management fees for agricultural use are to be no more than 20% of the rate charged to municipal and industrial users. The purpose of this break in the fee structure is to protect industries having an inelastic demand for their products. There is no evidence the Act intended livestock production be included in that category. Moreover, most groundwater for raising livestock in the region is used by wells that are exempt from the Authority's permit requirement and therefore is not subject to any aquifer management fee. In light of the above discussion, Authority staff has not modified §709.1(1) accordingly.

Public Comment No. 6:

Earl & Brown proposes changing § 709.1(1) so that it reads: "the use of groundwater for irrigation use and/or for agricultural industrial use." Earl & Brown also proposes the addition of a definition for "agricultural industrial use" which reads: "beneficial use of groundwater for the production of food or fiber or for any other use that may be deemed agricultural as that term is commonly defined."

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that the recommended definitions are too broad. There is no evidence the Act intended the definition of agricultural use be defined as proposed. In light of the above discussion, Authority staff has not modified §709.1(1) accordingly.

Section 709.1(4)

Proposed § 709.1(4) sets forth the definition for "cash needs approach" and states in part:

the method of determining annual operating revenue requirement of the Authority based on, and sufficient to cover, all cash needs for administrative and program expenses, including but not limited to . . ..

Public Comment No. 7:

Earl & Brown proposed changing § 709.1(4) so that it reads:

the method of determining the annual operating revenue requirements of the Authority based on, and sufficient to cover, all "reasonable and necessary" cash needs for administrative and program expenses . . ..

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that the board of directors adopts an annual budget it believes to be appropriate for the Authority's administrative and programmatic needs. Therefore, implicit in this "cash needs approach" is the assumption that the Authority's expenses are reasonable and necessary. In light of the above discussion, Authority staff has not modified §709.1(4) accordingly.

Section 709.1(8)

Proposed § 709.1(8) sets forth the definition for "non-agricultural use" as "the beneficial use of groundwater withdrawn from the aquifer for any use other than irrigation use."

Public Comment No. 8:

Susan Combs, Commissioner of the TDA, proposes the word "irrigation" be changed to "agriculture" so that the definition reads: "the beneficial use of groundwater withdrawn from the aquifer for any use other than agriculture use."

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is the proposed definition is too broad and would have to be defined. The purpose of the Act's break in the fee structure between irrigation and municipal use is to protect industries having an inelastic demand for their products. There is no evidence that any other sector of the agricultural industry is subject to this price inelasticity. In light of the above discussion, Authority staff has not modified §709.1(8) accordingly.

Public Comment No 9:

Earl & Brown proposes changing § 709.1(8) to read as follows:

Beneficial use of groundwater withdrawal from the aquifer for any use other than irrigation or agricultural industrial use.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is the proposed definition is too broad and would have to be defined. The purpose of the Act's break in the fee structure between irrigation and municipal use is to protect industries having an inelastic demand for their products. There is no evidence that any other sector of the agricultural industry is subject to this price inelasticity. In light of the above discussion, Authority staff has not modified §709.1(8) accordingly.

Section 709.11

Proposed § 709.11 establishes the permit application fees and states:

The general manager shall impose a $25 fee to file with the Authority an application for a regular, term, or an emergency groundwater withdrawal permit, a well construction permit, monitoring well permit, aquifer recharge and storage permit, and recharge recovery permits. The fee must be paid at the time the application is filed.

Public Comment No. 10:

Earl & Brown recommends adding the following sentence to the end of § 709.11:

Permit application fee shall be waived by the Authority on all applications submitted prior to the adoption of these rules.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that the permit application fee is specifically authorized by the Act. Moreover, the majority of permit application fees were received in 1996. In light of the above discussion, Authority staff has not modified §709.11 accordingly.

Public Comment No. 11:

TFB states that proposed § 709.11 contradicts § 707.403. Section 707.403 states, in part, as follows:

For all applications other than for an agricultural conservation loan, a non-refundable application fee of $25 must accompany that application in order for it to be considered by the Authority.

Authority's Response:

Authority staff received the above-referenced comment, and agrees with the comment. To address this apparent contradiction, the Authority staff has modified §709.11 as set forth below:

The general manager shall impose a $25 fee to file with the Authority any application, including but not limited to, an application for a regular, term, or an emergency groundwater withdrawal permit, a well construction permit, monitoring well permit, aquifer recharge and storage permit, and recharge recovery permits. The fee must be paid at the time the application is filed.

Section 709.13

Proposed § 709.13 deals with Enforcement for Nonpayment and states:

If the applicant has failed to pay the permit application fee or is delinquent to the Authority with respect to any other fee that is due and owing from the applicant to the Authority, the general manager may refuse to accept for filing, or otherwise process, a permit application.

Public Comment No. 12:

SAWS states that it doubts the Authority has the ability to stall processing of any application that is not in arrears or found to be in violation of EAA rules.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that Article 1, § 1.36 of the Act, expressly provides that the Authority "may enter orders to enforce the terms and conditions of permits, orders, or rules issued or adopted under this article." Further, the Authority by rule "shall provide for the suspension of a permit of any class for a failure to pay a required fee or a violation of a permit condition or order of the authority or a rule adopted by the authority." In light of the above discussion, Authority staff has not modified §709.13.

Section 709.19(d)(3)

Proposed § 709.19(d)(3) provides as follows:

By December 20th, the general manager shall calculate the aquifer management fee that may be assessed against Block 1 non-agricultural use on a unit cost basis by dividing the net annual operating revenue requirements by the total authorized aquifer use of Block 1 non-agricultural users.

Public Comment No. 13:

SAWS proposes amending the rule to recognize the contracted permit amount as follows:

By December 20th, the general manager shall calculate the aquifer management fee that may be assessed against Block 1 non-agricultural use on a unit cost basis by dividing the net annual operating revenue requirements by the total authorized "or contracted" aquifer use of Block 1 non-agricultural users.

Authority's Response:

Authority staff received the above-referenced comment, and agrees with the comment. The basis for this determination is that the calculation of annual aquifer management fees is derived after staff determines the total authorized annual aquifer use for non-agricultural users. The Authority should use the total authorized and contracted aquifer use as described in §709.25 to calculate the aquifer management fee for Block 1 non-agricultural users. In light of the above discussion, Authority staff has modified §709.19(d)(3) accordingly.

Sections 709.19(a), 709.19(d)(2), 709.19(d)(3), 709.19(d)(4), 709.21(c)

Proposed § 709.19(a) states that:

Not later than December 31st of each year, the general manager shall, pursuant to this subchapter, calculate and assess an aquifer management fee for the succeeding year.

Proposed § 709.19(d)(2) provides that:

Not later than November 30th, the general manager shall determine the total volume of aquifer use as reported in the groundwater users reports for the prior year by Block 1 non-agricultural users.

Proposed §§ 709.19(d)(3) and 709.19(d)(4) provide that the deadline by which the general manager shall calculate the aquifer management fee to be assessed against non-agricultural users and agricultural users, is December 20th.

Public Comment No. 14:

SAWS proposes changing § 709.19(a) to read: "no later than December 20th of each year . . .." SAWS also requests the elimination of § 709.19(d)(2) stating it is an unnecessary step in fee assessment, and that there be consistency among the dates used in this section.

Authority's Response:

Authority staff received the above-referenced comments, and disagrees in part with the comments. The basis for this determination in regard to §709.19(a) is that the proposed change would limit the Authority's flexibility to assess aquifer management fees for the succeeding year. However, to achieve consistency, Authority staff recommends changing the dates in §709.19(d)(3) and §709.19(d)(4) from December 20th to December 31st. In light of the above discussion, Authority staff has modified §709.19(d)(3) and §709.19(d)(4) as set forth below:

(d)(3) By December 31st . . ..

(d)(4) By December 31st . . ..

The Authority staff agrees in part with the comments. The basis for this determination in regard to §709.19(d)(2) is that although this section details an important step in the process of calculating aquifer management fees, including a specific reference to a date is not necessary. In light of the above discussion, Authority staff has modified §709.19(d)(2) as set forth below:

(d)(2) The general manager shall determine the total volume of aquifer use as reported in the groundwater users reports for the prior year by Block 1 non-agricultural users.

In light of these modifications by the Authority, § 709.21(c) has also been amended to maintain consistency between the dates used in § 709.19 and § 709.21 as follows:

§ 709.21(c) Not later than December 31st, the general manager shall mail an aquifer management fee invoice to all non-agricultural users. Not later than December 31st, the general manager shall mail a groundwater use report form to all agricultural users . . ..

Section 709.19(d)(4)

Proposed § 709.19(d)(4) states, in part, that "the general manager shall calculate the aquifer management fee for Block 2 agricultural users at an amount equal to 20 percent of the aquifer management fee for Block 1 non-agricultural users."

Public Comment No. 15:

Susan Combs, Commissioner of the TDA, asserts that § 709.19(d)(4) requires the Authority's general manager to determine the aquifer management fees for agricultural users at an amount that "may not be more than 20 percent of the fee rate for municipal use", pursuant to § 1.29(e) of the Act. TDA further asserts that the Authority is repressing irrigated agriculture by increasing water rates and charging the maximum rate allowed by law. Accordingly, TDA requests that the Authority consider the financial position of farmers and ranchers before charging these rates.

Authority's Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination is that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Public Comment No. 16:

Fohn Farm Inc./Fohn Bros. Farms, through Joe M. Fohn commenting for Bobby Fohn and David Fohn, commented on the cost of aquifer management fees stating it reported a monetary per acre loss on its crops and asked the Authority to consider the current depressed state of agricultural prices, asserting that such status makes higher management fees unaffordable.

Authority's Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination is that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Public Comment No. 17:

The following persons and associations commented on § 709.19(d)(4) and urge the Authority to adopt a maximum cap of $3.00 per acre foot regarding water management fees:

M.M. McWilliam; Frank Mechler, Jr.; Glen Kriewald; Ernie Schreiner; Glenn Bragg; Rudy Botello; Jerry (surname illegible); Carroll T. Keller; Edgar H. Alzlnot, Jr.; G.J. Boehme; William R. Fewell; Ralph Kohlleppel, Jr.; R.Q. Stinson; Lynn F. Boehme; Ralph Kohlleppel; Chris Schuele; David B. Carter; Gail F. Boehme; Harry Lee Keller; Tim Schott; Morris Salazar; Kye Mash; Wm. Terry (surname illegible); Marshall Persyn; (first name illegible) Haby; Raymond T.(surname illegible); Jeff Tickner; George (surname illegible); Ted Kohlleppel; David Kohlleppel; David M. (surname illegible); James G. Wernette; Gilbert Eryeso; Alvin Santlelonso; Tylar J. (surname illegible); Aubrey Freeman; David Villarreal; Pamela Gardner; Mark Mendosa; Jacinto Sala; Alex Nieto; John Mueller; Edward Moore; (first name illegible) Villarreal; (first name illegible) Vogt; Jay Rogers; J. Lyon Argell; D.A. Villarreal; John Persyn; Melvin M. Zinsmeyer; Roger T. Graff; Deborah Cox; Karen Bain; Thomas Chautner; P. Gregory; Wm. Bain; Keith Taylor; (first name illegible) A. Neumann; Robert Neumann; Glenn Weiblen; Maurice DeCork, Jr.; (first name illegible) Boehme; Harold J. Bemos; (first name illegible) Besh; Stanley Riker; William H. Reus; Austin A. Clary; Fred Schueling, Jr.; Joe M. Fohn (Fohn Farm); Donald Bush (Hidden Valley); Ronnie Muennik; Tom Verstuyft; Richard S. Sterling; Calvin Bendell; Edwin L. Yanta; Chuck (surname illegible); Deon E. Stewart; Scott Noell; (first name illegible) Wurzbach; Charles L. Noonan, Jr.; Sarah L. Tracy; Rebecca D. Faseler; Roy Reyes; Ricky Robles; Melissa Ackermann; Derek Boehme; Julie Boehme; Niesso Boehme; Pat Wylach; Kathleen D. Carskaddin; Thomas Boehme; Arthur Weiblen; Corinne Davenport; Harvey Boehme; Darlene Boehme; Jeanette Boehme; (first name illegible) Keller; Cindy Hawkins; C. Ray Hawkins; Elva Hawkins; Arthur G. Isle "Tootie"; Dale K. Saatek, Jr.; Robert DeLeo, Jr.; (first name illegible) W. Banner; Mark Vish; Dorothy M. Boehme; Staci S. Boehme; Vicki Boehme; Curtis Boehme; Allison Boehme; Paul Aelvoet; George James; Russell Meyer; Clarence Mumme; Annette Billings; Wade Swanson; Geneviere Aelvoet; Amy Soltos; (first name illegible) Linderman; Rick Aelvoet; Robert Fohn; David Fohn; Harold Weiblen; Jared Boehme; Fred Weiblen; Adele Boehme; Nelson Boehme; Derek M. (surname illegible); Melissa Boehme; Leah Boehme; Morris Faseler; Cordell Bohlen; Jay E. Muennik; Franklin Muennik; Malvern Jesk; Jimmy Stewart; Thomas H. Carskadden; Rebecca C. Janysek; Roy Lee Bippert; Eloise Bippert; Shawn Noonan; Lucille Bippert; Leonard Bippert; Michele D. Bippert; Troy Bippert; Kris Noonan; Wm Reichert; Bernard Echtle; Margaret M. Echtle; Michael E. Echtle; Ashley Echtle; George M. Echtle; Alfred Keller, Jr.; Agnes E. Echtle; Marcella Keller; William Echtle; Michael Weiblen; Kathy Eaton; Joy M. Persyn; Brad Haby; Rebecca J. Haby; Gary Grantham; Marsha Lanham; Thomas C. Trautner; Jeffrey Lanham; Mark Lamon for the Medina County Farm Bureau; Gladys Gembler for the Bexar County Farm Bureau, and other individuals whose first and last names were illegible on the written comments.

Authority Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination is that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Public Comment No. 18:

In assessing the aquifer management fee under § 709.19(d)(4), Clarence Mumme requests that the Authority consider: 1) the Agricultural Industry's inability to pass the increased cost of water to their produce buyers, 2) the possibility that the unlimited or increasing charge for water use would become an unaffordable cost of business for farmers, 3) the possibility of soon incurring a $30.00 per acre user fee that would equal the cost of leasing irrigated land, 4) the contention that land owners pay a higher price for irrigated land, 5) the expense and risk of drilling a well, plus the expenditures made in purchasing, operating, and maintaining irrigation equipment, 6) the economic impact of farming in the seven county area, 7) annual changes in rainfall coupled with the assertion that irrigation water is used only when there is an insufficient amount of rain, and 8) the lower expense related to rain water as opposed to pumped water. Finally, Mr. Mumme proposes capping charges for farmers' water usage at $3.50 per acre-foot per year or, in the alternative, pay land owners $250 per acre foot per year for non-usage of his/her allocated two acre feet.

Authority's Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination in regard to limiting the amount of the annual aquifer management fee for agricultural users is that the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Authority staff received the above-referenced comment, and disagrees in part with the comment. The basis for this determination in regard to paying land owners for non-usage of his/her allocated two acre-feet per acre, is that the Authority may consider payment for non-use of a well owner's allocated groundwater in a separate program. In light of the above discussion, Authority staff has not modified §709.19(d)(4) accordingly.

Public Comment No. 19:

Ralph and Allen Gilliam of Gilliam Ranch, and Gregory and Cora Rothe, propose the elimination of § 709.19(d)(4) so the Board may retain the discretion to set agricultural user fees annually, as a part of the budget process. The Board's retention of this discretion may aid in avoiding high fees which could make farming economically prohibitive. Alternatively, if the rule is not abolished, the commenters assert that a modification is necessary to allow the general manager to annually recommend a proper percentage relationship between agricultural and non-agricultural users.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees in part with the comment. The basis for this determination is that aquifer management fees are mandated by the Act and must be available as a regulatory tool. In light of the above discussion, Authority staff has not modified §709.19(d)(4) accordingly.

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination is that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Public Comment No. 20:

S. J. Boehme and Sons, Inc. (through Curtis, Nelson, and Dorothy Boehme), recommends changing the wording of § 709.19(d)(4) to read:

(d)The aquifer management fee shall be calculated and addressed as follows:

(4) By December 20th, except as provided in § 711.420(3) of this title (relating to Enforcement) the general manager shall calculate the aquifer management fee for Block 2 agricultural users at $3.00 per acre foot for the first acre foot of initial regular permit - the amount above an acre foot be charged no more than 20 percent of the aquifer management fee for Block 1 non-agricultural users.

Boehme and Sons assert these changes will:

(1) promote water conservation for agricultural use;

(2) encourage the sale or lease of water to Block 1 non-agricultural users resulting in an increase in management fees return per acre foot;

(3) aide tenants and renters in remaining in agriculture thereby allowing landowners to continue leasing their land; and

(4) result in a smaller increase of management fees for non-agricultural users.

Authority's Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination is that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Public Comment No. 21:

Glenn Bragg, JoLynn Bragg, and David Bragg of Pecan Farms, Inc. ("Bragg"), contend that the language of this section mandates that agricultural fees be set at 20% of industrial/municipal use, thereby eliminating the Authority's ability to adjust agricultural fees below the 20% mark. Bragg contends the Act (§ 1.29(e)) demonstrates that the 20% rate was intended to be a maximum fee which allows the Authority to set rates below that maximum. Furthermore, Bragg comments that agricultural user fees will increase over time and users will likely receive buy-down fee assessments for both the 450,000 and 400,000 acre-feet (FY 2008) caps. Consequently, the fees and the increasing budgets will rapidly become insupportable for agriculture if the Authority immediately begins charging at the 20% maximum rate. Bragg emphasizes that agricultural users cannot pass the cost of increasing fees off to the consumer and recommends that agricultural water fees be fixed at the current rate of $3.70 per acre-foot unless or until agricultural prices can support an increase.

Authority's Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination is that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Public Comment No. 22:

Paul Aelvoet commented on 709.19(d)(4) and states Senate Bill 1477 requires the agricultural fee be no more than 20% of the non-agricultural fee. He states "an amount equal to 20%" is an illegal changing of the law.

Authority's Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination is that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Public Comment No. 23:

Harold Weiblen commented on §709.19(d)(4) and states the language in the proposed rule should track the Act.

Authority's Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination is that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Public Comment No. 24:

Thomas C. Trautner with Aldridge Nursery, Inc. states that the proposed fees will be about $7.00 an acre foot and may rise over the next few years, due mostly to the Authority's litigation expenses. He contends increasing fees to pay for litigation is against the law and unreasonable under § 1.29(b) of the Edwards Aquifer Authority Act. Mr. Trautner also contends the $7.00 fee per acre foot could go as high as $20.00 for irrigation use. For most farmers that rarely net more than $100,000 annually, this $14,000 fee during a drought would taken 14% of that income. He feels $7.00 is an unreasonable amount to pay for your own water and asserts that farmers will eventually become unable to operate if these higher management prices continue to rise.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees in part with the comment. The basis for this determination in regard to the statement that increasing fees to pay for litigation is illegal and unreasonable, is that § 1.29 of the Act expressly provides that the Authority shall assess aquifer management fees "to finance its administrative expenses and programs" thereby allowing the Authority to take into account litigation expenses when determining fees. In light of the above discussion, Authority staff has not modified §709.19(d)(4) accordingly.

Authority staff received the above-referenced comment, and disagrees in part with the comment. The basis for this determination in regard to the statement that increasing fees to $7.00 and above will result in farmers being unable to operate, is that the Authority cannot make such a determination based on the variables involved. Crop production costs are based on the type of crop grown and profit margins vary according to the type of crop grown. The Authority has determined, however, that to better reflect the requirements and the intent of the Act, the board may determine annually by resolution the aquifer management fee rate for agricultural users. This rate will be $3.00 per acre-foot for base irrigation groundwater and not more than 20% of the fee rate for municipal use for unrestricted irrigation groundwater. The board may consider limiting aquifer management fees for agricultural users in this annual resolution. In light of the above discussion, Authority staff has modified §709.19(d)(1) and (4) accordingly.

Section 709.21

Proposed § 709.21 deals with Billing and Collection of aquifer management fees.

Public Comment No. 25:

Richard Frenzel, General Manager of the Bexar County Water Control and Improvement District #10 in Windcrest objects to agricultural users being guaranteed two-acre feet of water per year. He also disagrees with agricultural users paying "after the fact" for whatever they use, while municipal/industrial users have to pay in advance for whatever they are going to be allocated.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that this requirement is described in the Act. Moreover, user contracts described in §709.25 provide an opportunity for municipal and industrial well owners to pay only for the groundwater projected to be used in a given year. In light of the above discussion, Authority staff has not modified §709.21 accordingly.

Section 709.21(b)(2)(B)

Proposed § 709.21(b)(2)(B) states, in part, as follows:

(2) If the aquifer use is non-agricultural, then the fee shall be assessed on:

(B) for a permittee, the total volume of groundwater authorized to be withdrawn in a final permit issued by the board, irrespective of whether the groundwater was actually withdrawn.

Public Comment No. 26:

Earl & Brown proposes an addition to § 709.21(b)(2)(B). As amended, it would read:

(B) for a permittee, the total volume of groundwater authorized to be withdrawn in a final permit issued by the board, irrespective of whether the groundwater was actually withdrawn. However, in order to promote conservation and avoid unnecessary waste under a "take or pay" scheme, the Authority shall refund to the payor Aquifer Management Fees in an amount equal to that portion unpumped permit which was not withdrawn during the calender year.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination in regard to the "take or pay" issue is that user contracts described in §709.25 are intended to promote conservation by allowing non-agricultural users to voluntarily limit the amount of groundwater they will use in a calendar year. In light of the above discussion, Authority staff has not modified §709.21(b)(2)(B) accordingly.

Section 709.21(c) and (e)

Proposed § 709.21(c) states, in part, that "the general manager shall mail a groundwater use report form to all agricultural users to report aquifer use for the preceding calendar year."

Proposed § 709.21(e) states, in part, "for agricultural users, the groundwater use report shall constitute an aquifer management fee invoice . . . This invoice for agricultural use becomes due and payable immediately upon mailing of the groundwater use report by the general manager."

Public Comment No. 27:

SAWS recommends the following changes to the above-mentioned sections:

(c)...to report aquifer use for "current" calender year.

(e) This invoice for agricultural use becomes due and payable immediately upon mailing of the groundwater use report by the "agricultural user."

Authority's Response:

Authority staff received the above-referenced comment, and agrees with the comment. The basis for this determination is the proposed revisions will better describe the process for distributing annual groundwater use report forms and for collecting aquifer management fees. In light of the above discussion, Authority staff has modified §709.21(c) and §709.21(e) accordingly. (Note: Although SAWS' comment refers to §709.21(b), Authority staff has concluded the comment was intended to address §709.21(c)).

Section 709.21(d)

Proposed § 709.21(d) provides for the payment of the aquifer management fee by non-agricultural users and provides that:

An aquifer management fee invoice for a non-agricultural user becomes due and payable immediately upon mailing. If the total annual aquifer management fee invoice for the user is less than $600, the user shall pay the fee on a lump sum basis. Such an invoice becomes delinquent if payment in full is not received by the Authority on or before March 1st of the year for which the aquifer management fee is in effect. If the total annual aquifer management fee invoice for a non-agricultural user is equal to or greater than $600, then the user may elect to pay the fee on a lump sum or in equal monthly payments. Such an invoice becomes delinquent if payment in full for a lump sum payment is not received in full by March 1st of the year for which the aquifer management fee is in effect. If the non-agricultural user elects to pay on a monthly payment schedule, then the pro rata portion of the invoice becomes due monthly on the last working day of each month. Each monthly payment of an invoice becomes delinquent if payment in full is not received by the Authority on or before the last working day of each month for which the monthly payment becomes due and payable.

Public Comment No. 28:

Richard Frenzel, General Manager of the Bexar County Water Control and Improvement District #10 in Windcrest, proposes changing § 709.21(d) to read as follows:

An aquifer management fee invoice for a non-agricultural user becomes due and payable immediately upon mailing. If the total annual aquifer management fee invoice for the user is less than $600, the user shall pay the fee on a lump sum basis. Such an invoice becomes delinquent if payment in full is not received by the Authority on or before March 1st of the year for which the aquifer management fee is in effect. If the total annual aquifer management fee invoice for a non-agricultural user is equal to or greater than $600, then the user may elect to pay the fee "in" a lump sum or in equal monthly payments. Such an invoice becomes delinquent if payment in full for a lump sum payment is not received in full by March 1st of the year for which the aquifer management fee is in effect. If the non-agricultural user elects to pay on a monthly payment schedule, then the pro rata portion of the invoice becomes due monthly on the last working day of each month. Each monthly payment of an invoice becomes delinquent if payment in full is not received by the Authority on or before the last working day of each month for which the monthly payment becomes due and payable.

Authority's Response:

Authority staff received the above-referenced comment, and agrees with the comment. The basis for this determination is this was a typographical error. In light of the above discussion, Authority staff has modified §709.21(d) accordingly.

Public Comment No. 29:

Herb Faseler commented that § 709.21(d) is discriminatory because an aquifer management fee for a non-agricultural user is delinquent if not paid by March 1 of the year for which the fee is in effect, while an invoice for agricultural users is delinquent if not received by January 31 of each year. He states January is a difficult month because farmers and ranchers must pay taxes in January and that a payment plan should be an option for agricultural users.

Authority's Response:

Authority staff received the above-referenced comment, disagrees with the comment. The basis for this determination is that as agricultural users, farmers pay aquifer management fees for groundwater used in the production of a crop during the preceding year. Municipal and industrial users are paying for the current year's groundwater use by March 1, whereas farmers are paying after the fact based on actual water use. Therefore, the proposed rule is not discriminatory. In light of the above discussion, Authority staff has not modified §709.21(d) accordingly.

Section 709.21(f)

Proposed § 709.21(f) states:

For any aquifer management fee that is delinquent, if payment in full is not received on or before 10 days after the date the amount became delinquent, then the General Manger shall assess, for every month thereafter that the invoice remains delinquent, a penalty of 5 percent of the then delinquent amount.

Public Comment No. 30:

Thomas C. Trautner asserts that the five percent penalty is usurious, especially when additional pumping cannot occur until late fees and penalties are paid.

Authority's Response:

Authority staff received the above-referenced comment, and agrees in part with the comment. The basis for this determination in regard to the penalty for late payments is that in an effort to maintain consistency with other legal constraints, the section should be amended to allow the Authority to assess a penalty for late payments in an amount equivalent to the maximum amount allowed by law. In light of the above discussion, Authority staff has modified §709.21(f) accordingly.

Section 709.21(g)

Public Comment No. 31:

Earl & Brown proposes adding § 709.21 (g), which reads:

If the total amount of Aquifer Management Fees for Block-1 Non-Agricultural User Exceeds a total of $1,000 annually, the payor shall have the option of paying the Authority a one time $10 Administration Fee and then be allowed to pay the total fees in 12 equal monthly installments to the Authority.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination in regard to monthly payments of Block 1 non-agricultural aquifer management fees is that the proposal to add §709.21(g) is repetitive of §709.21(d) detailing options for monthly payment of aquifer management fees for non-agricultural users. In light of the above discussion, Authority staff has not added §709.21(g) accordingly.

Chapter 709 - General

In response to the Authority's request to the Texas Workforce Commission ("TWC") to prepare a Local Employment Impact Statement pursuant to § 2001.022 of the Texas Government Code, the TWC responded in a letter to the Authority regarding Chapter 709 stating:

After reviewing the information provided to our Department, there is no apparent basis to refute the proposed employment impacts outlined in the (information submitted on behalf of the Authority). Our data will not confirm nor deny the potential lost jobs nor the newly created jobs based upon the impact of these proposed rules.

The Authority determined the letter did not constitute a Local Employment Impact Statement because it did not meet the criteria identified in § 2001.022(a) of the Texas Government Code. Because the Commission did not prepare and deliver to the Authority a Local Employment Impact Statement within 25 days after the date on which the Commission received the proposed rules, the proposed rules are presumed not to affect local employment pursuant to § 2001.022(e) of the Texas Government Code and no Local Employment Impact Statement is required to be included in the Notice of Proposed Rule.

Public Comment No. 32:

Thomas C. Trautner with Aldridge Nursery states the Authority is not excused from examining the impact of Chapter 709 on employment because the TWC did not make any findings regarding the issue.

Authority Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The Authority has complied with all the requirements of the Texas Government Code and has applied the legal presumption set out in § 2001.022(e). Based on the letter provided by the TWC, no Local Employment Impact Statement is required to be included in the Notice of Proposed Rule. There is no additional requirement that the Authority conduct an impact analysis independent of the TWC.

Public Comment No. 33:

Rafael Pineda states the Texas Legislature was not authorized to exercise total domain over water. "This water is private water, and it should stay private water." He also feels a great deal of water can be conserved with various sprinkler systems.

Authority's Response:

Authority staff received the above-referenced comment, and disagrees with the comment. The basis for this determination is that the aquifer is a natural resource of Texas. The Legislature, through § 1.08 of the Act, has stated that the Authority has "all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in the aquifer." In light of the above discussion, Authority staff has not modified any rules contained in Chapter 709.

Public Comment No. 34:

The TFB asserts that the Authority was required by the Texas Private Real Property Rights Preservation Act to prepare a "takings impact assessment" or "TIA" before providing notice of the proposed adoption of the Chapter 709 rules.

Authority's Response:

The Authority staff received the above-referenced comment and disagrees with the comment. Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act" ("TPRPRA"), requires governmental entities, under certain circumstances, to prepare a TIA in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the adoption of these rules.

First, the Authority has made a "categorical determination" that these proposed Chapter 709 rules do not affect vested property rights and, as such, adoption of these rules is not an action that "may result in a taking." The rules at issue here establish procedures for implementing and collecting fees. The rules set forth the various types of fees imposed by the Authority and provide procedures for the adoption and assessment, as well as the billing and collection, of those fees. They have no direct affect on private real property and may not result in a taking.

Second, the Authority's action in adopting these rules is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from the Texas Private Real Property Rights Preservation Act under § 2007.003(b)(4) of the Texas Government Code. See §§ 1.08(a), 1.11(a), (b), (d)(2), (f), and (h), 1.15(a), 1.16(b) and (d)(1), 1.29(a), (b), (c), (d), (e), (f), (g), and (h), 1.36(b), 1.44(c)(2) of the Act; § 2001.004(1) of the APA; and § 36.205 of the Texas Water Code .

This conclusion is directly supported and controlled by the decision in Edwards Aquifer Authority v. Bragg, 21 S.W.3d. 375, (Tex. App. - San Antonio 2000, pet. filed) ( "EAA v. Bragg" ). In that case, the Plaintiffs sued to invalidate a set of rules adopted by the Authority (the "prior permitting rules") which were substantially similar to these proposed rules and which were designed, like these rules, to implement the Authority's programs. The Fourth Court of Appeals held that the Authority's adoption of its prior permitting rules was expressly mandated by the Act and was therefore excepted from the operation of TPRPRA. The holding in that case controls here.

Third, it is the position of the Authority that all valid actions of the Authority are excluded from the Texas Private Real Property Rights Preservation Act under § 2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the proposal of these rules.

Accordingly, for the reasons stated above, a TIA need not be performed in connection with the proposal of these rules.

Public Comment No. 35:

The TDA commented generally that the Authority should have prepared a "small business effects statement" prior to proposing the adoption of the Chapter 709 rules, pursuant to § 2006.002(d) of the Texas Government Code.

Authority Response:

The Authority staff received the above-referenced comment and disagrees for the following reasons. Chapter 2006 of the Texas Government Code, subchapter A, requires state agencies to prepare a small business effects statement (SBES) prior to proposing, for adoption, a rule that would have an adverse economic effect on small businesses. By the statute's express terms, this requirement applies only to a "state agency." The term "state agency" is defined, for the purposes of Chapter 2006, subchapter A, as "a department, board, bureau, commission, division, office, council or other agency of the state." Id. § 2006.001(3).

Section 2006.002 does not apply to the Authority because the Authority does not meet the definition of the term "state agency" as set out forth in Chapter 2006. Section 1.02(a) of the Act creates the Authority as a "conservation and reclamation district" under Article XVI, § 59 of the Texas Constitution. Conservation and reclamation districts created under this authority have long been considered to be "political subdivisions" of the State of Texas. See, e.g., Guaranty Petroleum, 609 S.W.2d 529, 530 (Tex. 1980). In Guaranty Petroleum, the Texas Supreme Court explained the difference between political subdivisions and state agencies as follows:

A political subdivision differs from a department, board or agency of the State. A political subdivision has jurisdiction over a portion of the State; a department, board or agency of the State exercises its jurisdiction throughout the State. Members of the governing body of a political subdivision are elected in local elections or are appointed by locally elected officials; those who govern departments, boards or agencies of the State are elected in statewide elections or are appointed by State officials.

Guaranty Petroleum, 609 S.W.2d at 531 (emphasis added).

This opinion makes clear that state agencies are characterized by having statewide jurisdiction and are governed by persons who are elected in statewide elections or are appointed by state officials. Political subdivisions like the Authority, on the other hand, have jurisdiction over only a portion of the state and are governed by persons who are elected in local elections or are appointed by locally elected officials. These principles have been reiterated by the Texas Supreme Court in Lohec v. Galveston County Commissioners Court, 841 S.W.2d 361, 364 (Tex. 1992) (noting that "statewide jurisdiction" is "a trait required of entities recognized as department, boards, or agencies of the state") and Monsanto Company v. Cornerstones Municipal Utility District, 865 S.W.2d 937, 939-40 (Tex. 1993).

Because the Authority has jurisdiction over only a portion of the State and because the members of its governing body are elected in local elections or are appointed by locally elected officials, the Authority is a political subdivision and not a state agency, and is not subject to the SBES requirement found in Chapter 2006 of the Government Code.

No revisions to the Chapter 709 are required in response to this comment.

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rules governing procedures of the Board and the authority." This section directs the Board to adopt rules as necessary to implement the various substantive programs set forth in the Act related to the Edwards Aquifer, which includes application, registration, aquifer management, and regular permit special retirement fees, and in particular, administrative procedures to be used before the Board and the Authority.

Section 1.11(b) of the Act requires the Authority "ensure compliance with permitting, metering, and reporting requirements and shall regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, empowers the Authority to establish procedures related to the filing and processing of various applications and registrations with and by the Authority.

Section 1.11(d)(2) of the Act provides, among other things, that the Authority may enter into contracts.

Section 1.11(f) of the Act provides the Authority may contract with a person who uses water from the aquifer for the Authority or that person to construct, operate, own, finance, and maintain water supply facilities which include a dam, reservoir, treatment facility, transmission facility, or recharge project. This section further provides management fees or special fees may not be used for purchasing or operating these facilities.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. Pursuant to this section, the Authority is required to comply with the APA in connection with its rulemaking, even though the Authority is not a state agency and would therefore otherwise not generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.15(a) of the Act directs the Authority to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by this Act.

Section 1.16(b) of the Act sets forth certain requirements concerning an existing user's declaration of historical use and an applicant's payment of application fees required by the Board.

Section 1.16(d)(1) of the Act requires the Board to grant an initial regular permit to an existing user who, among other things, files a declaration and pays fees as required by this section.

Section 1.29(a) of the Act relates to fees. This section provides that the allocation of the cost of reducing withdrawals or permit retirements must be borne: solely by users of the aquifer for reducing withdrawals from the level on the effective date of this article to 450,000 acre-feet a year, or the adjusted amount determined under § 1.14(b) for the period ending December 31, 2007; and equally by downstream water rights holders for permit retirements from 450,000 acre-feet a year, or the adjusted amount determined under § 1.14(d) for the period ending December 31, 2007, to 400,000 acre-feet a year, or the adjusted amount determined under §1.14(d) for the period beginning January 1, 2008.

Section 1.29(b) of the Act provides for the assessment of aquifer management fees based on aquifer use under the water management plan to finance the Authority's authorized administrative expenses and programs. This section also allows water districts governed by Chapter 52 of the Texas Water Code and within the Authority's boundaries, to contract with the Authority to pay the Authority's expenses through taxes in lieu of user fees, to be paid by water users in the district. This section provides the Authority with the power to assess fees in order to generate revenue to finance the operation of the Authority in its regulation of the aquifer, however, the Authority may not collect a total amount of fees and taxes that is more than is reasonably necessary for the administration of the Authority.

Section 1.29(c) of the Act provides that the Authority shall assess an equitable special fee based on permitted aquifer water rights to be used only to finance the retirement of rights necessary to meet the goals of the Authority for reducing the maximum annual volume of water withdrawals from the aquifer. The section further provides the Authority shall set the fees on permitted aquifer users at a level sufficient to match the funds raised from the assessment of equitable special fees on downstream water rights holders.

Section 1.29(d) of the Act provides for the assessment of equitable special fees by the Commission on all downstream water rights holders in the Guadalupe River Basin to be used to finance the retirement of aquifer rights necessary to meet the goals of the Authority for reducing the maximum annual volume of water withdrawals from the aquifer. This section further provides that downstream water rights holders shall pay the assessed fees to the Authority. This section prohibits the assessment of fees by the Commission on contractual deliveries of water stored in Canyon Lake that may be diverted downstream of the San Marcos Springs or Canyon Dam.

Section 1.29(e) of the Act provides for the development of an equitable fee structure under § 1.29 and authorizes the Authority to establish different fee rates on a per acre-foot basis for different types of use. The fees must be equitable between types of uses and shall be assessed on the amount of water a permit holder is authorized to withdraw under the permit. Aquifer management fee rates for agricultural use shall be based on the volume of water withdrawn and may not be more than 20 percent of the fee rate for municipal use. Aquifer management fees rates for non-agricultural users are to be based on the face value of a permittee's initial regular permit or the amount authorized to be withdrawn under interim authorization status.

Section 1.29(f) of the Act requires the Authority to impose a permit application fee of not more than $25.

Section 1.29(g) of the Act empowers the Authority to impose a registration application fee of not more than $10.

Section 1.29(h) of the Act states that special fees collected under subsection (c) or (d) of §1.29 may not be used to finance a surface water supply reservoir project.

Section 1.36(b) of the Act provides the Authority with enforcement power and states that Authority shall provide for the suspension of a permit of any class for failure to pay a required fee or for a violation of a permit condition, order of the Authority, or rule adopted by the Authority.

Section 1.44(c)(2) of the Act relates to cooperative contracts for artificial recharge and states the political subdivision causing artificial recharge of the aquifer is entitled to withdraw during any 12-month period the measured amount of water actually injected or artificially recharged during the preceding 12-month period, as demonstrated and established by expert testimony, less an amount determined by the Authority to account for that part of the artificially recharged water discharged through springs, and to compensate the Authority in lieu of users' fees.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This proposed rulemaking is in furtherance of this legislative mandate. These proposed rules are rules of practice that state the procedures applicable to the fee setting process of the Authority.

Section 36.205 of the Texas Water Code authorizes groundwater conservation districts to set fees for administrative acts of the districts. Such fees may not unreasonably exceed the cost to the district of performing the administrative function for which the fee is charged.

Subchapter A. DEFINITIONS

31 TAC §709.1

The new section is adopted pursuant to §§ 1.08(a), 1.11(a), (b), (d)(2), (f), and (h), 1.15(a), 1.16(b) and (d)(1), 1.29(a), (b), (c), (d), (e), (f), (g), and (h), 1.36(b), 1.44(c)(2) of the Act; § 2001.004(1) of the Texas Administrative Procedure Act (Texas Government Code Annotated, §§ 2001.001-.902 (Vernon 2000)) ("APA"); and § 36.205 of the Texas Water Code (Texas Water Code Annotated, § 36.205 (Vernon 2000)). The Authority interprets these sections as authorizing the Authority to adopt rules establishing a fee structure for the Authority.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007351

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter B. REGISTRATION FEES

31 TAC §§709.3, 709.5, 709.7

The new sections are adopted pursuant to §§ 1.08(a), 1.11(a), (b), (d)(2), (f), and (h), 1.15(a), 1.16(b) and (d)(1), 1.29(a), (b), (c), (d), (e), (f), (g), and (h), 1.36(b), 1.44(c)(2) of the Act; § 2001.004(1) of the Texas Administrative Procedure Act (Texas Government Code Annotated, §§ 2001.001-.902 (Vernon 2000)) ("APA"); and § 36.205 of the Texas Water Code (Texas Water Code Annotated, § 36.205 (Vernon 2000)). The Authority interprets these sections as authorizing the Authority to adopt rules establishing a fee structure for the Authority.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007352

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter C. PERMIT APPLICATION FEES

31 TAC §§709.9, 709.11, 709.13

The new sections are adopted pursuant to §§ 1.08(a), 1.11(a), (b), (d)(2), (f), and (h), 1.15(a), 1.16(b) and (d)(1), 1.29(a), (b), (c), (d), (e), (f), (g), and (h), 1.36(b), 1.44(c)(2) of the Act; § 2001.004(1) of the Texas Administrative Procedure Act (Texas Government Code Annotated, §§ 2001.001-.902 (Vernon 2000)) ("APA"); and § 36.205 of the Texas Water Code (Texas Water Code Annotated, § 36.205 (Vernon 2000)). The Authority interprets these sections as authorizing the Authority to adopt rules establishing a fee structure for the Authority.

§709.11.Permit Application Fees; Applicability.

The general manager shall impose a $25 fee to file with the Authority any application, including but not limited to, an application for a regular, term, or an emergency groundwater withdrawal permit, a well construction permit, monitoring well permit, aquifer recharge and storage permit, and recharge recovery permits. The fee must be paid at the time the application is filed.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007353

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter D. AQUIFER MANAGEMENT FEES

31 TAC §§709.15, 709.17, 709.19, 709.21, 709.23, 709.25, 709.27, 709.29, 709.31, 709.33, 709.35

The new sections are adopted pursuant to §§ 1.08(a), 1.11(a), (b), (d)(2), (f), and (h), 1.15(a), 1.16(b) and (d)(1), 1.29(a), (b), (c), (d), (e), (f), (g), and (h), 1.36(b), 1.44(c)(2) of the Act; § 2001.004(1) of the Texas Administrative Procedure Act (Texas Government Code Annotated, §§ 2001.001-.902 (Vernon 2000)) ("APA"); and § 36.205 of the Texas Water Code (Texas Water Code Annotated, § 36.205 (Vernon 2000)). The Authority interprets these sections as authorizing the Authority to adopt rules establishing a fee structure for the Authority.

§709.19.Adoption and Assessment.

(a)

Not later than December 31st of each year, the general manager shall, pursuant to this subchapter, calculate and assess an aquifer management fee for the succeeding year.

(b)

The aquifer management fee shall be based on aquifer use.

(c)

The aquifer management fee shall be based on two user blocks, and be uniform such that the average unit cost of groundwater, regardless of quantity withdrawn, remains constant and is applicable to all the aquifer users within the same user block. The Blocks shall be as follows:

(1)

Block 1: non-agricultural users; and

(2)

Block 2: agricultural users.

(d)

The aquifer management fee shall be calculated and assessed as follows:

(1)

By resolution and order, the board shall adopt a Block 1 and an agricultural users aquifer management fee rate and budget reflecting its annual operating revenue requirement for the succeeding fiscal year based on a cash-needs approach. The budget shall determine the net annual operating revenue requirement by subtracting from the annual operating revenue requirement any carryover funding from the current fiscal year in addition to funding from other sources expected to be available for expenditure during the fiscal year, including but not limited to, aquifer management fees for agriculture use for preceding calendar years.

(2)

The general manager shall determine the total volume of aquifer use as reported in the groundwater users reports for the prior year by Block 1 non-agricultural users.

(3)

By December 31st, the general manager shall calculate the aquifer management fee that may be assessed against Block 1 non-agricultural use on a unit cost basis by dividing the net annual operating revenue requirements by the total authorized or contracted aquifer use of Block 1 non-agricultural users.

(4)

By December 31st, except as provided in §711.420(3) of this title (relating to Enforcement), the general manager shall calculate the aquifer management fee for Block 2 agricultural users as follows:

(A)

For base irrigation groundwater: $3.00 per acre-foot; or

(B)

For unrestricted irrigation groundwater: Not more than 20 percent of the aquifer management fee for Block 1 non-agricultural users.

(e)

The unit cost for the aquifer management fees shall be expressed in dollars per acre-foot per annum.

§709.21.Billing and Collection.

(a)

All persons authorized for aquifer use under interim authorization status pursuant to §1.17 of the Act and the rules of the Authority, or under a final groundwater withdrawal permit issued by the board, are required to pay to the Authority an aquifer management fee as assessed pursuant to this subchapter.

(b)

The general manager shall bill to and collect from all aquifer users an aquifer management fee for the fiscal year as calculated and assessed by the general manager pursuant to this subchapter, unless subject to a user contract under §709.25 of this title (relating to User Contracts),

(1)

If the aquifer use is agricultural, the aquifer management fee shall be assessed on the total volume of groundwater withdrawn in a calendar year from the aquifer by an aquifer user.

(2)

If the aquifer use is non-agricultural, then the fee shall be assessed on:

(A)

for an applicant qualifying for interim authorization status under §1.17 of the Act, the historical, maximum beneficial use set forth in §4B of the application for initial regular permit, irrespective of whether the groundwater was actually withdrawn; or

(B)

for a permittee, the total volume of groundwater authorized to be withdrawn in a final permit issued by the board, irrespective of whether the groundwater was actually withdrawn.

(c)

Not later than December 31st, the general manager shall mail an aquifer management fee invoice to all non-agricultural users. Not later than December 31st, the general manager shall mail a groundwater use report form to all agricultural users to report aquifer use for the current calendar year.

(d)

An aquifer management fee invoice for a non-agricultural user becomes due and payable immediately upon mailing. If the total annual aquifer management fee invoice for the user is less than $600, the user shall pay the fee on a lump sum basis. Such an invoice becomes delinquent if payment in full is not received by the Authority on or before March 1st of the year for which the aquifer management fee is in effect. If the total annual aquifer management fee invoice for a non-agricultural user is equal to or greater than $600, then the user may elect to pay the fee in a lump sum or in equal monthly payments. Such an invoice becomes delinquent if payment in full for a lump sum payment is not received in full by March 1st of the year for which the aquifer management fee is in effect. If the non-agricultural user elects to pay on a monthly payment schedule, then the pro rata portion of the invoice becomes due monthly on the last working day of each month. Each monthly payment of an invoice becomes delinquent if payment in full is not received by the Authority on or before the last working day of each month for which the monthly payment becomes due and payable.

(e)

For agricultural users, the groundwater use report shall constitute an aquifer management fee invoice. An agricultural user shall file a completed groundwater use report form with the Authority no later than January 31st of each year for aquifer use for the preceding calendar year. Payment of the aquifer management fee shall accompany the completed groundwater use report. This invoice for agricultural use becomes due and payable immediately upon mailing of the groundwater use report by the agricultural user. An invoice becomes delinquent if payment in full is not received by the Authority on or before January 31st of each year.

(f)

For any aquifer management fee that is delinquent, if payment in full is not received on or before 10 days after the date the amount became delinquent, then the General Manager shall assess, for every month thereafter that the invoice remains delinquent, a penalty equivalent to the maximum amount allowed by law.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007354

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Chapter 711. GROUNDWATER WITHDRAWAL PERMITS

I. INTRODUCTION.

The Edwards Aquifer Authority ("Authority") adopts new 31 TAC, §§711.1, 711.10, 711.12, 711.14, 711.90, 711.92, 711.94, 711.96, 711.98, 711.100, 711.102, 711.104, 711.108, 711.110, 711.112, 711.116, 711.118, 711.130, 711.132, 711.134, 711.160, 711.162, 711.164, 711.166, 711.168, 711.170, 711.172, 711.174, 711.176, 711.180, 711.220, 711.222, 711.224, 711.226, 711.228, 711.230, 711.232, 711.234. Sections 711.1, 711.12, 711.94, 711.96, 711.98, 711.100, 711.102, 711.108, 711.112, 711.116, 711.118, 711.130, 711.134, 711.166, 711.168, 711.172, and 711.176 are adopted with changes to the proposed text as published in the August 11, 2000, issue of the Texas Register (25 TexReg 7548 - 7596) and are republished herein. Sections 711.10, 711.14, 711.90, 711.92, 711.104, 711.110, 711.132, 711.160, 711.162, 711.164, 711.170, 711.174, 711.180, 711.220, 711.222, 711.224, 711.226, 711.228, 711.230, 711.232, and 711.234 are adopted without changes and will not be republished.

These rules have been written to implement the Authority's groundwater withdrawal permitting program.

In response to the public comments, the Authority has elected not to adopt §711.178 at this time and hereby withdraws the rule from consideration for permanent adoption.

II. SUMMARY OF THE FACTUAL BASES FOR THE ADOPTED RULES; AND CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The Edwards Aquifer Authority Act, Act of May 30, 1993, 73rd Legislature, Regular Session, Chapter 626, 1993 TEXAS GENERAL LAWS 2350, as amended by Act of May 28, 1995, 74th Legislature, Regular Session, Chapter 3189, 1995 TEXAS GENERAL LAWS 2505, Act of May 16, 1995, 74th Legislature, Regular Session, Chapter 361, 1995 TEXAS GENERAL LAWS 3280, and Act of May 6, 1999, 76th Legislature, Regular Session, Chapter 163, 1999 TEXAS GENERAL LAWS 634 (the "Act"), requires the Authority to implement a permitting system whereby "existing users" of groundwater from the Edwards Aquifer and other potential users of aquifer water may apply for and receive initial regular permits and other types of permits issued by the Authority allowing for the withdrawal of groundwater from the aquifer. Other types of permits are also required by the Act for well construction and related work. Certain other withdrawals are exempted by the Act from permitting requirements. The Act also specifies an "interim authorization" period prior to the issuance by the Authority of final initial regular permits during which certain existing users of the aquifer may continue to make withdrawals. The Act imposes a number of restrictions upon the use of the aquifer during the interim authorization period as well as after permits are issued. It also places limits on the ability to transfer permits or interim authorization status. The rules in this Chapter 711 are intended to effectuate these various components of the Act.

The new sections are adopted pursuant to the following statutory provisions:

Section 1.01 of the Act contains the findings of the Texas Legislature that the Edwards Aquifer is a distinctive natural resource and that a special regional management district (the Authority) is required for the effective control of the resource to protect terrestrial and aquatic life, domestic and municipal water supplies, existing industries, and the economic development of the state.

Section 1.03(1) defines the "Edwards Aquifer."

Section 1.03(4) of the Act defines "beneficial use" to mean the use of water that is economically necessary for a purpose authorized by law when reasonable intelligence and reasonable diligence are used in applying the water to that purpose. The concept of beneficial use is incorporated into the permitting rules of Chapter 711.

Section 1.03(9) of the Act defines "domestic or livestock use." This concept is incorporated into the exempt well rules found within Chapter 711.

Section 1.03(10) of the Act defines "existing user" as a person who has withdrawn and beneficially used underground water from the aquifer on or before June 1, 1993. This concept is incorporated into the Chapter 711 rules, while also accounting for the beneficial use requirement and including the successors in interest of existing users within the definition.

Section 1.03(11) of the Act defines "industrial use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(12) of the Act defines "irrigation use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(13) of the Act defines "livestock." The Chapter 711 rules incorporate this concept when determining whether a well qualifies as "exempt" from permitting requirements.

Section 1.03(14) of the Act defines "municipal use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(21) of the Act defines "waste." This concept is incorporated into the Chapter 711 rules, while also including other practices which are considered wasteful under the Act or under the long-standing water law concept of beneficial use.

Section 1.07 of the Act provides, in part, that the actions taken by the Authority pursuant to the Act may not be construed as depriving or divesting owners of their ownership rights as landowners in underground water, subject to rules adopted by the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer. These rules further those objectives.

Section 1.08(b) makes it clear that the Authority's powers apply only to water within or withdrawn from the Edwards Aquifer, and not to surface water.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rule governing procedures of the board and the authority." This section provides broad rulemaking authority to implement the various substantive and procedures programs set forth in the Act related to the Edwards Aquifer, including the permitting program.

Section 1.11(b) of the Act requires the Authority to "ensure compliance with permitting, metering, and reporting requirements and . . . regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, requires the Authority to adopt and enforce the Chapter 711 rules.

Section 1.11(d)(2) of the Act empowers the Authority to enter into contracts. Pursuant to this section, the Authority may enter into contracts with well owners concerning meters and reimbursement for same under Subchapter M of the Chapter 711 rules.

Section 1.11(d)(8) of the Act provides that the Authority may close abandoned, wasteful or dangerous wells. The Authority's rules relating to the requirement of beneficial use and the prohibition of waste, as well as the closure of abandoned wells derive in part from this statutory authority.

Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 of the Texas Water Code and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) Chapter 32 imposes certain duties upon drillers of water wells and the owners of those wells. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 derive in part from this statutory authority.

Section 1.11(d)(11) of the Act provides that the Authority may require to be furnished with copies of the water well drillers' logs that are required by Chapter 32 of the Texas Water Code.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. This section essentially provides that the Authority is required to comply with the APA for its rulemaking, even though the Authority is a political subdivision and not a state agency that would generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.13 of the Act requires the Authority to allow credit to be given for certified reuse of aquifer water. The Authority will likely adopt rules implementing this section. This concept is acknowledged in Subchapter F.

Section 1.14(a) of the Act provides that authorizations to withdraw aquifer water shall be limited in order to: protect water quality of the aquifer and surface streams to which the aquifer contributes springflow; achieve water conservation; maximize beneficial use of water from the aquifer; protect aquatic and wildlife habitat as well as federally or state-designated threatened or endangered species; and provide for instream uses, bays and estuaries. The Chapter 711 rules are adopted, in large part, pursuant to these statutory mandates.

Section 1.14(b) of the Act imposes, subject to certain limitations, an initial aquifer withdrawal "cap" for permitted withdrawals of 450,000 acre-feet per year, until December 31, 2007. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(c) of the Act imposes, subject to certain limitations, an aquifer withdrawal "cap" for permitted withdrawals of 400,000 acre-feet per year, beginning January 1, 2008. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(d) of the Act provides that either of the caps listed above may be raised by the Authority if, through studies and implementation of certain strategies, the authority, in consultation with state and federal agencies, determines the caps may be raised.

Section 1.14(e) of the Act requires the Authority to prohibit withdrawals from new wells drilled after the effective date of the Act unless the "caps" are raised and then only on an interruptible basis. The Chapter 711 rules incorporate this prohibition.

Section 1.14(f) of the Act entitles the Authority to allow (or not allow) permitted withdrawals on an uninterruptible basis when certain index wells are at or above the following measurements: for the San Antonio pool, when well J-17 is at or above 650 mean sea level (msl); and for the Uvalde Pool, when well J-27 is at or above 865 msl. The section also imposes the duty on the Authority to limit additional withdrawals to ensure that springflows are not affected during critical drought conditions. The Chapter 711 rules incorporate these concepts by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.14(g) of the Act allows the Authority to, by rule, define other pools within the aquifer in accordance with hydrogeologic research, and to establish index wells for any pool to monitor the level of the aquifer to aid the regulation of withdrawals from the pools.

Section 1.14(h) of the Act provides that the Authority generally must ensure, by December 31, 2012, that continuous minimum springflows of Comal and San Marcos Springs are maintained to protect threatened and endangered species to the extent required by federal law. The Chapter 711 rules incorporate this requirement by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.15(a) of the Act directs the Authority "to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by the Act." This section is implemented through the Chapter 711 rules.

Section 1.15(b) of the Act states that "except as provided by §§1.17 and 1.33 of this article, a person may not withdraw water from the aquifer or begin construction of a well or other works designed for the withdrawal of water from the aquifer without obtaining a permit from the authority." This section is implemented through the Chapter 711 rules.

Section 1.15(c) of the Act allows the Authority to issue regular permits, term permits, and emergency permits. This section is implemented through the Chapter 711 rules.

Section 1.15(d) of the Act provides that each permit issued by the Authority must specify the maximum rate and total volume of water that the user may withdraw annually. This section is implemented through the Chapter 711 rules.

Section 1.16(a) of the Act allows an existing user to apply for an initial regular permit by filing a declaration of historical use documenting use of aquifer water during the period from June 1, 1972 through May 31, 1993. The initial regular permits issued pursuant to the Chapter 711 rules will be based upon such.

Section 1.16(b) of the Act, in conjunction with Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996)(holding that declarations must be filed within six months after the effective date of the Act, i.e., December 30, 1996) provides that an existing user's declaration of historical use (permit application) must be file on or before December 30, 1996, and the applicant must timely pay all application fees required by the Authority. It further requires irrigation applicants to submit, as part of their applications, documentation regarding the number of acres irrigated during the historical period.

Section 1.16(c) of the Act provides that an owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under § 1.33 of the Act is not required to file a declaration of historical use.

Section 1.16(d) of the Act requires the Board to grant an initial regular permit to an existing user who: (1) files a declaration and pays fees as required by this section; and (2) establishes by convincing evidence beneficial use of underground water from the aquifer. This requirement is incorporated into the Chapter 711 rules.

Section 1.16(e) of the Act explains the quantity of water to be permitted under an initial regular permit. Pursuant to this section, if enough water is available, each existing user shall be permitted for an amount equal to the user's maximum beneficial use during the historical period. If there is not enough water available, then this section requires the Authority to "proportionately adjust" permit amounts downward in order to meet the withdrawals "caps" discussed above. However, this section also creates certain "permit minimums" for existing irrigation users and for those existing users who have operated a well for three or more years during the historical period. This section also requires the Authority to extrapolate water use on an annual basis for those existing users who do not have a full year's use during the historical period. These concepts are incorporated into Chapter 711, primarily in Subchapter G.

Section 1.16(f) requires the Authority to equitably treat persons whose historic use was affected by participation in a federal program, such as agricultural subsidy programs. This concept is incorporated in the Chapter 711 rules.

Section 1.16(g) of the Act provides that initial regular permits do not have a term and remain in effect until abandoned, cancelled or retired. These concepts are incorporated in the Chapter 711 rules.

Section 1.16(h) of the Act requires the Authority to notify each permit holder of the limitations to which the permit is subject. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter F.

Section 1.17(a) of the Act provides that a person who, on the effective date of this article, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the Authority, if: "(1) the well is in compliance with all statutes and rules relating to well construction, approval, location, spacing, and operation; and (2) by March 1, 1994, the person files a declaration of historical use on a form as required by the authority."

Section 1.18 of the Act allows the Authority, in certain circumstances, to issue additional regular permits. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.19 of the Act allows the Authority to issue term permits and places certain limitations and conditions on the right to withdraw water under such a permit. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.20 of the Act allows the Authority to issue emergency permits under certain circumstances and subject to certain conditions. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.21 of the Act sets out a process by which the Authority is to implement a plan for reducing the withdrawal "cap" from 450,000 to 400,000 acre-feet per year by January 1, 2008. The plan must be enforceable and include various water conservation, reuse, retirement, and other management measures. If, on or after January 1, 2008, total permitted withdrawals still exceed the 400,000 acre-feet cap, then the Authority must implement "equal percentage reductions" of all permits in order to reach the cap. This concept is implemented in Chapter 711, primarily in Subchapter G.

Section 1.22 of the Act provides that the Authority may acquire permitted aquifer rights to be used for: holding in trust for sale or transfer to other users; holding in trust as a means of managing aquifer demand; holding for resale or retirement as a means of achieving pumping reductions required by the Act; or retiring the rights. These concepts are implemented in part in Chapter 711.

Section 1.23(a) of the Act provides that the Authority may require certain permittees to submit and implement water conservation plans and water reuse plans. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.25 of the Act requires the Authority to develop and implement a comprehensive water management plan and, in conjunction with the SCTWAC and other water districts, to develop and implement a plan for providing alternative water supplies, with oversight by state agencies and the Edwards Aquifer Legislative Oversight Committee. The alternative supplies plan shall consider alternative technologies, financing issues, costs and benefits, and environmental issues. These concepts are implemented, in part, in Chapter 711, primarily through Subchapter F.

Section 1.26 of the Act requires the Authority to prepare and coordinate implementation of a critical period management plan which meets certain, enumerated criteria. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.29 of the Act authorizes the imposition of various types of fees on various types of permits. The Chapter 711 rules acknowledge this fee provision, primarily in Subchapter E.

Section 1.31 of the Act provides that nonexempt well owners must install and maintain meters or alternative measuring devices to measure the flow rate and cumulative amount of water withdrawn from each well. These concepts are implemented in the Chapter 711 rules.

Section 1.32 of the Act requires permittees to submit annual water use reports to the Authority. This section is acknowledged in Subchapter F.

Section 1.33 of the Act provides the criteria for exempt wells -- i.e., wells that produce no more than 25,000 gallons of water per day for domestic and livestock use and that are not within or serving a subdivision requiring platting. The section explains that such wells are exempt from metering requirements. However, such wells must be registered with the Authority. These concepts are implemented in Chapter 711.

Section 1.34 of the Act imposes certain limitations upon the ways in which aquifer water and/or water rights may be transferred (alienated). First, aquifer water must be used within the Authority's boundaries. Second, the section allows the Authority to establish rules by which a person may install water conservation equipment and sell the water conserved. Third, the section further provides that a holder of a permit for irrigation use may not transfer more than 50 percent of the irrigation rights initially permitted and that the user's remaining irrigation water rights must be used in accordance with the original permit and must pass with transfer of the irrigated land. These concepts are implemented, in part, in Chapter 711.

Section 1.35 of the Act prohibits: withdrawing aquifer water except as authorized by a permit; violating permit terms or conditions; wasting aquifer water; polluting or contributing to the pollution of the aquifer; or violating the Act or an Authority rule. These concepts are implemented in Chapter 711.

Section 1.36 of the Act empowers the Authority to enter orders enforcing the terms and conditions of permits, orders, or rules, and to draft rules suspending permits for failure to pay required fees or violations of permits, orders or rules. These concepts are implemented, in part, in Chapter 711.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This rulemaking is in furtherance of this legislative mandate.

Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711derive in part from this statutory authority and implement this chapter and the supporting rules.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.101(a) empowers the Authority to make and enforce rules to provide for conserving, preserving, protecting, and recharging of the groundwater in order to, among other things, prevent waste and carry out the duties provided elsewhere in Chapter 36. This requirement is implemented, in large part, through Chapter 711.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.111 requires the Authority to require aquifer users to keep and maintain reports of drilling, equipping, and completing water wells and the production and uses of groundwater. Chapter 711 implements these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. The section further specifies the permitted format and contents of permit applications, and lays out criteria for the district to consider when ruling on a permit application. The section also provides that permits may be issued subject to the district's rules and other restrictions. The Chapter 711 rules incorporate these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.1131 specifies what may be included as elements of a permit issued by a district.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.115 provides that no person may drill a well, alter the size of a well or well pump, or operate a well without first obtaining a permit from the Authority.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that drilling a well without a required permit or operating a well at a higher rate of production than the rate approved for the well is declared to be illegal, wasteful per se, and a nuisance. This concept is incorporated into Chapter 711, primarily in the definition of waste found in § 711.1.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.211(a) endows districts such as the Authority with the "functions, powers, authority, rights, and duties that will permit accomplishment of the purposes for which it was created or the purposes authorized by the constitution, this code, or any other law." This broad delegation of powers is incorporated into the Chapter 711 rules.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.221 empowers representatives of the Authority to enter land and perform tests and other inspections. This authority is incorporated into Chapter 711, primarily in § 711.416.

16 TAC, Chapter 76. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation (TDLR).) The TDLR's rules implementing Chapter 32 are found at 16 TAC, Chapter 76. These rules impose numerous duties upon well drillers and well owners related to well construction, operation, and plugging. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 implement, in part, the rules found in 16 TAC, Chapter 76.

Subchapter A

Section 711.1, Subchapter A of the Chapter 711 rules, sets forth the definitions that will apply to all rules issued by the Authority in Chapter 711. These rules have been written to provide uniform definitions for words and phrases that are expected to be used consistently throughout Chapter 711. They are intended to provide useful "short-hand" to reduce the amount of cumbersome regulatory language necessary in other Authority rules, thus allowing for a more efficient understanding and operation of other rules of the Authority.

Contained within § 711.1 are definitions of "existing user" (§711.1(2)), "contract user" (§711.1(1)), and "prior user" (§711.1(4)). In order to obtain an initial regular permit, the applicant must be an "existing user." See Act § 1.16(a).

As defined by § 711.1(2), an "existing user" is "a person, or the successor in interest of such a person, who, on June 1, 1993, owned an existing well from which groundwater from the aquifer had been withdrawn and placed to beneficial use during the historical period." A well owner who transferred his interest in the well during the historical period is referred to by the Authority as a "prior user." A person who did not own an aquifer well, but who withdrew or purchased aquifer water during the historical period pursuant to a contractual or other agreement with the well owner, qualifies as a "contract user." Although "existing user" is defined in the Act, the Authority believes that, based upon the remainder of the text of the Act, the statutory definition of "existing user" requires elaboration by the Authority and the definitions of "contract user" and "prior user" must be added.

The statutory definition states that an existing user need only have beneficially used aquifer water "on or before June 1, 1993," a date which corresponds with the close of the statutory "historical period." See Act § 1.16(a). The Act goes on to provide, however, any application for an "initial regular permit" must be based upon aquifer use during the historical period. See Act § 1.16(a) and (b). Thus, no initial regular permit may be granted to an "existing user" unless his or her use was during the historical period. The Authority's definition makes this clear.

The Authority's definition also clarifies that an "existing user" may be the person who owned the existing well on June 1, 1993 or his "successor in interest." Because, for any particular applicant, the ownership of points of withdrawal and places of use may not have been static since the inception and closure of the statutory historical period, the Authority must account for transfers and the impact of transfers on existing user status.

The Authority's definition also clarifies that an "existing user" must be the owner of the well for which an application is sought. The Authority believes this requirement is implicit in the Act. The sine qua non of an "existing user" is ownership of the point(s) of withdrawal (i.e. well(s)) from which the withdrawals are made during the historical period. For example, § 1.17(a) makes clear that interim authorization status only extends to persons owning non-exempt producing wells. Further, numerous sections of the Act make reference to the owner of a well having certain rights and duties, thereby confirming that proper applicants for initial regular permits must be the well owners. See §§1.03(21)(E) and (F) (relating to the definition of waste); 1.16(b) (evidentiary obligation of owners of irrigation wells); 1.16(c) (owners of exempt wells not required to file declarations of historical use); 1.17(a) (owners of producing wells may continue to withdraw under interim authorization); 1.17(d)(2) (well owners may file declarations of historical use); and 1.31(a) (owners of nonexempt wells).

It is equally necessary to define "contract user" (711.1(1)) and "prior user" (711.1(4)) which create a distinction as to who may apply for a permit. For any individual well, the ownership of points of withdrawal and places of use may not have been static since the inception and closure of the statutory historical period. Thus, without elaboration by the Authority, a reading of the definition of "existing user" in the Act could lead one to the incorrect inference that there may be multiple permit holders deriving their permits from the same point of withdrawal, place of use, and historical use. This could result in absurd outcomes, such as former well owners applying for initial regular permits for wells they no longer own.

Take, for example, a hypothetical well that was owned and used by more than one person before, during and after the historical period. The well was originally owned and used by Mr. U prior to the commencement of the historical period in 1972. It was then sold to Mr. V in 1970. The well was owned and used by Mr. V for the period from 1970 through 1980. It was then sold by Mr. V to Mr. W in 1980. Mr. W used the well himself until 1985. While continuing to own the well, Mr. W then, by contract, leased his land to Mr. X and allowed Mr. X to withdraw water from the well to irrigate the land. Mr. W sold the well to Mr. Y in 1995, after the close of the historical period in 1993. Mr. Y filed a timely permit application with the Authority. Mr. Y then sold his land, well and permit application to Mr. Z in 1998. Unless distinctions are made, via the Authority's rules, between contract users, existing users, and prior users, there would be confusion as to who may apply for and obtain a permit for the historical use of the well in question. The legislature did not intend to allow Messrs. U, V, W, X, Y and Z each to obtain a permit for the same well and historical use. For example, Mr. U cannot be an existing user because he did not have use during the historical period, even though he may have been the original owner. Mr. V, who has not held any interest in the land or the well since 1980, has no right to claim a permit. Similarly, Messrs. W and Y have not held any interest since 1995 and 1998, respectively. Mr. X simply leased from Mr. W the right to withdraw water from the well. He does not have an ownership interest. Under the definitions adopted by the Authority, Mr. U has no status of any kind, Messrs. V and W would be "prior users", and Messrs. V, W, and Y would be the predecessors in interest to the "existing user," Mr. Z, and Mr. X would be a "contract user." Mr. Y, although a former existing user, would have no status because he acquired and sold his interest after the close of the historical period. Only Mr. Z would be the "existing user" entitled to apply for an initial regular permit. Mr. Z would also be entitled to base his permit application on the pumpage during the historical period of his predecessors in interest, and any prior users and contract users. This is consistent with the Court's reasoning in Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996) wherein the court noted: "Historical use could be established through previous landowners' withdrawals from the well, and permits could be transferred to future owners of the land." It logically follows that an application for an initial regular permit and the right to file the declaration of historical use may also be transferred to future owners of the land. This necessarily means that one's existing user status is transferred with the transfer of the land. Accordingly, by elaborating upon the definition of existing user and adding definitions for contract users and prior users, the possibility of multiple applicants for the same point of withdrawal and place of use is eliminated.

Section 711.1(3) defines "historical use" as "the lawful withdrawing and placing to beneficial use of groundwater from the aquifer during the historical period." The Authority believes this definition is required to add clarity as to the type of historical usage upon which a permit application may be granted. The Authority is charged with the duty to prevent waste of the aquifer. See Act § 1.08. The Act makes it clear that, while an initial regular permit must be based upon historical usage, that historical usage must have lawfully been obtained and put to beneficial use during the historical period. Section 1.16(d) of the Act states that a initial regular permit shall be granted to an applicant who files a declaration, pays his fee, and "establishes by convincing evidence beneficial use of underground water from the aquifer." (Emphasis added.) See also § 1.16(e). The common law relating to groundwater, which was controlling during the historical period, likewise prohibits the waste (i.e., non-beneficial use) of groundwater. Thus, waste constitutes an unlawful use of groundwater which cannot be considered by the Authority when calculating one's eligibility for a permit. The definition clarifies this point.

As amended in response to public comments (discussed more fully below), § 711.1(5) defines "producing well" as "a well from which groundwater from the aquifer is capable of being withdrawn for a beneficial use." This definition is needed to clarify the phrase "producing well" which is found in § 1.17(a) of the Act. Section 1.17 provides certain well owners with the right to continue pumping aquifer water, pursuant to "interim authorization" status, while their permit applications are pending before the Authority. The section states, in part, that "a person who, on the effective date of the Act, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the authority. . . ." Without clarification by the Authority, this section of the Act could be read to mean that, in order to qualify for interim authorization status, a well owner must have actually withdrawn water on the effective date of the Act (June 28, 1996). The Authority does not believe this to be the Legislature's intent. Instead, the Authority believes the intent was to allow anyone who, on the effective date of the Act, owned a well capable of producing, regardless of whether it actually produced on that particular date, to qualify for interim authorization status assuming the other statutory criteria are met. The definition makes this clear.

Section 711.1(6) defines "waste" using 10 different criteria. Six of those criteria are essentially identical to those found in Act's definition of waste found at § 1.03(21) and require no further elaboration. Although "waste" is defined in the Act, the Authority believes that, based upon the remainder of the text of the Act, and other statutory authorities, the statutory definition of "waste" requires elaboration by the Authority. Thus, additional definitional criteria for waste are added, consistent with the Act and other statutes for which the Authority has enforcement responsibility. First, subparagraph (E) of the Act's definition of "waste" is modified by the italicized language:

Willfully or negligently causing, suffering or permitting groundwater from the aquifer to escape into any river, creek, natural watercourse, depression, lake, reservoir, drain, sewer, street, highway, road, or road ditch, or onto any land other than that of the owner of the well, unless:

(1) such discharge is authorized by permit, rule, or order issued by the commission under Chapter 26, Water Code; and

(2) after discharge, the groundwater from the aquifer is beneficially used by the existing user, applicant or permittee making the discharge;

This revision reiterates the requirement found throughout the Act that water from the aquifer be beneficially used and not wasted.

Next, the following subparagraph H is added to the definition of "waste:"

(H) Constructing, installing, drilling, equipping, completing, altering, operating, maintaining, or making withdrawals from a well without a required permit;

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that drilling a well without a required permit or operating a well at a higher rate of production than the rate approved for the well is declared to be illegal, wasteful per se, and a nuisance. This concept is incorporated into Chapter 711 primarily through subparagraph (H) of the waste definition in § 711.1.

Next, the following subparagraph (I) is added to the definition of "waste:"

(I) Withdrawal of water that is substantially in excess of the volume or rate reasonably required for a beneficial use;

The addition of subparagraph (I) is consistent with and in harmony with the Legislative objectives of the Act. Subparagraph (I) is designed to further elucidate the meaning of subparagraph (B) of the definition related to beneficial use. It also furthers the objectives of other applicable provisions of the Act. Section 1.03(4) of the Act defines "beneficial use" as "the use of the amount of water that is economically necessary for a purpose authorized by law, when reasonable intelligence and reasonable diligence are used in applying the water to that purpose. " (Emphasis added.) This evidences a clear intent on the part of the Legislature that, for any given use, the amount of withdrawn water used may not be unreasonably high when compared to the intended end use. If, for example, an industrial user used twice the amount of water to produce its products than would a competitor who generated the same output, then such excessive usage would be considered non-beneficial and wasteful by the Authority.

Next, the following subparagraph (J) is added to the definition of "waste:"

(J) Irrigation use of groundwater from the aquifer in a volume per irrigated acre that is so insufficient that a crop could not have been reasonably cultivated and produced.

The Act delegates to the Authority broad discretion to limit waste of water, protect the aquifer, and maximize the beneficial use of water from the aquifer. See, e.g., Act §§ 1.08(a) and 1.14(a). Section 1.16(d)(2) dictates that groundwater first be beneficially used before it can qualify for the statutory irrigator minimum in section 1.16(e). The use of a quantity of aquifer water in a volume per acre that is insufficient to reasonably cultivate and produce a crop does not constitute a beneficial use and is, therefore, wasteful. The definition in § 711.1(6)(J) implements this beneficial use requirement.

Subchapter B

The Act requires the Authority to implement a permitting system whereby certain "existing users" of groundwater from the aquifer and other potential users of aquifer water may apply for and receive initial regular permits and/or other types of permits issued by the Authority allowing for the withdrawal of groundwater from the aquifer. Other types of permits are also required by the Act for well construction and related work. Sections 711.10 - 711.14, Subchapter B of the Chapter 711 rules, set forth the activities for which a permit from the Authority is required.

Section 711.10 sets out the purposes of the Chapter 711 rules, which relate to managing the aquifer to protect the aquifer, species dependent upon springflows from the aquifer, and the various entities and other interests utilizing the aquifer. These purposes are derived directly from sections 1.01, 1.06(a) and 1.08(a) of the Act, furthering the Legislative objectives behind the creation of the Authority, and require no further elaboration.

Section 711.12 identifies the types of activities for which a permit is generally required from the Authority. This section provides that a permit is generally required before one may construct, alter or operate an aquifer well, including a monitoring well, or a well pump. These provisions derive primarily from § 1.15(b) of the Act. The Authority interprets the requirement in § 1.15(b) of the Act, to obtain a permit before constructing a well, to extend to all types of aquifer wells, including monitoring wells, and to extend to construction activities such as the installation of pumps. This conclusion is buttressed by Chapter 36 of the Texas Water Code, which generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. However, as set forth in rule § 711.12(b), the Authority does not consider the well construction permit requirement to extend to routine operation and maintenance operations for wells after they are constructed.

Section 711.12 further provides that a permit is generally required before one may recharge water into the aquifer, store water in the aquifer, or construct or alter a well designed to withdraw non-Edwards groundwater if the well intersects the Edwards Aquifer. These provisions derive primarily from the Authority's duties to protect the aquifer as mandated in sections 1.08(a), 1.14(a) and 1.15(a) of the Act and § 36.113 of the Texas Water Code. The Authority believes that the construction of wells which intersect the aquifer, or projects designed to enhance recharge into the aquifer or store water in the aquifer all have the potential to negatively impact the quality and/or quantity of water within the aquifer. Accordingly, it is appropriate to regulate such activities through the Authority's permitting process.

Section 711.14 identifies the types of groundwater withdrawals for which a withdrawal permit is not required from the Authority -- withdrawals from wells qualifying for interim authorization status, or from exempt wells. This rule derives directly from and implements sections 1.15(b), 1.17(a) and 1.33 of the Act, which create exemptions from the permit requirement for "exempt wells" and wells qualifying for interim authorization status.

Subchapter E

The Act requires the Authority to implement a permitting system whereby "existing users" of groundwater from the aquifer and other potential users of aquifer water may apply for and receive initial regular permits and/or other types of permits issued by the Authority allowing for the withdrawal of groundwater from the aquifer. The Act also requires the Authority to issue permits for the construction of Edwards Aquifer wells. Sections 711.90-711.118, Subchapter E of the Chapter 711 rules, help fulfill these requirements by setting forth the types of permits issued by the Authority, the conditions governing how and when such permits could be issued, the quantity of and conditions under which water could be withdrawn or wells constructed pursuant to such permits, the duration of such permits, the required contents of permit applications, and the rights and limitations associated with being the holder of such permits.

Primarily, the sections in Subchapter E list the information that the Authority has determined is necessary for its consideration and issuance of various types of permits. Most of the sections in Subchapter E each list the attributes of the various kinds of permits issued by the Authority and the criteria by which permit applications will be judged. The rules also identify the elements an applicant is required to prove in order to obtain a permit from the Authority. The requirements in these rules pertain to information that the Authority needs in order to effectively manage, conserve and protect the Aquifer and to implement its statutorily-mandated programs.

Section 711.90 identifies the types of permits which may be issued by the Authority: (1) initial regular permits, as authorized by § 1.16 of the Act; (2) additional regular permits, as authorized by § 1.18 of the Act; (3) term permits, as authorized by § 1.19 of the Act; (4) emergency permits, as authorized by § 1.20 of the Act; (5) and (6) aquifer recharge and storage permits and recharge recovery permits, as authorized by sections 1.08(a) and 1.14(a), 1.15(a) of the Act and § 36.113 of the Texas Water Code; (7) well construction permits, as authorized by § 1.15(b) of the Act; and (8) monitoring wells, as authorized by § 1.15(a) and (b) of the Act. The Authority interprets the requirement in § 1.15(b) of the Act to obtain a permit before constructing a well to extend to all types of aquifer wells, including monitoring wells. The Authority further believes that projects designed to enhance recharge into the aquifer or store water in the aquifer (i.e., aquifer recharge and storage and recharge recovery activities) can potentially negatively impact the quality and/or quantity of water within the aquifer. Accordingly, it is appropriate to regulate such activities through the Authority's permitting process.

Section 711.92 provides that, as designated in a groundwater withdrawal permit, aquifer water may be beneficially used only for irrigation use, municipal use or industrial use. This limitation derives from the Act. The Act clearly requires that water pumped from the aquifer be "beneficially used" and not wasted. See, e.g., Act sections 1.16(d) and (e) (authorizing permits if beneficial use is established, and calculating permit amounts based upon beneficial use without waste), 1.17 and 1.18. While the Act does not expressly identify the types of use which may be considered "beneficial," the Act does identify and define four specific types of use - domestic or livestock use, industrial use, irrigation use, and municipal use. Domestic or livestock use is expressly made exempt from permitting requirements pursuant to sections 1.15(b) and 1.33 of the Act and such use is not governed by § 711.92. The Authority has concluded that the remaining three types of uses identified in the Act -- industrial, irrigation and municipal -- cover the gambit of known, lawful purposes to which water from the aquifer is being put or is likely to be put and for which a permit would be required.

Section 711.94(a) requires that groundwater withdrawn from the aquifer, whether withdrawn during or after the historical period, must be placed to beneficial use without waste. This limitation derives from the Act. The Act clearly requires that water pumped from the aquifer be "beneficially used" and not wasted. See, e.g., Act sections 1.16(d) and (e) (authorizing permits if beneficial use is established, and calculating permit amounts based upon beneficial use without waste), 1.17 and 1.18. Section 1.35(c) prohibits the waste of water withdrawn from the aquifer. The use of water in a way that is not beneficial is the equivalent of wasting water. Section 1.08(a) of the Act charges the Authority with the duty to prevent the waste of aquifer water.

Section 711.94(b) and (c) provide that the beneficial use of water by a "contract user" (one who withdrew or purchased and put to beneficial use aquifer water during the statutory historical period pursuant to a contract or other legal right from a prior or existing user from an existing well) may only be claimed by the prior or existing user in support of a permit application. As discussed more fully in the discussion for Subchapter A, above, this rule is included to avoid the result whereby more than one person (i.e., the prior user, existing user, and/or contract user) each seeks a permit based upon the same pumpage during the historical period.

Section 711.94(d) states that "irrigation in the volume of two-acre feet per irrigated acre is rebuttably presumed to constitute beneficial use without waste." It is clear that § 1.16(e) the Act calls for a "permit minimum" for certain irrigators equivalent to two-acre feet per acre. Thus, this rule makes it clear that irrigators begin with the presumption in their favor that irrigation in that quantity is not wasteful. The purpose of including the phrase "rebuttably presumed" in this rule is not to affect the process by which irrigators are issued permits or to affect their eligibility for the statutory two acre-feet irrigator minimum. Instead, it is intended to facilitate the Authority's ability and duty to prevent waste by irrigators once permits have been issued. Not all irrigation practices necessitate the use of two acre-feet of water per acre per year, nor are irrigators any more exempt than any other aquifer users from the requirement in § 1.35(c) of the Act that aquifer water be beneficially used and not wasted. It is possible that an irrigator's practices may be wasteful even if his rate of use is below two acre-feet per acre per year. In that event, the Authority needs to retain the right to rebut the presumption that usage of two acre-feet is not wasteful.

Section 711.94(e) provides that irrigation of multiple or successive crops is a beneficial use to the extent it does not constitute waste. This provision is added to make it clear that the planting of multiple crops in any given year is not, in itself, considered by the Authority to be wasteful. Such practices are common within the boundaries of the Authority, and the Authority does not believe it would be reasonable to consider such practices wasteful in the absence of other evidence indicating waste.

Section 711.94(f) provides a mechanism whereby prior or existing users whose historic use has been affected by a requirement of or participation in a federal program shall be given a credit in their permit applications for the amount of water they would have withdrawn and beneficially used were it not for the federal program. This section derives directly from § 1.16(f) of the Act which requires the Authority to adopt a rule implementing a mechanism to equitably treat permit applicants whose use of the aquifer during the historical period was "affected" by a requirement of, or participation, in a "federal program." Through this rule, the Authority attempts to treat such persons equitably by giving them a "beneficial use credit" for the amount which they would have withdrawn, but for participation in the federal program. That credit is based upon the use by other, similarly situated pumpers who were not affected by the federal program.

Section 711.94(g) provides a mechanism whereby beneficial use of aquifer water, during the historical period, at the same place of use by multiple existing users -- each owning different wells -- will be shared on a pro rata basis. The Authority is aware of several permit applications which fit the following general description: Applicant A, who owns well A, files an application based upon A's aquifer pumpage from well A during the historical period which was used to irrigate Blackacre. Applicant B, who owns well B, also files an application based upon B's aquifer pumpage from well B during the historical period which was used to irrigate Blackacre. Blackacre consists of 100 acres. If no provision is made in the Authority's rules governing how the historical irrigation of Blackacre should be handled in the permitting process, the incorrect inference might be made that Applicant A and Applicant B are each entitled to irrigation permits for 200 acre-feet (100 acres times the statutory two acre-feet per acre irrigator minimum). The Authority has concluded that such a result is contrary to the Act and the intent of the Legislature when they passed the Act. Such an outcome would result in four acre-feet per acre worth of permits being issued. With § 711.94(g), Applicant A and Applicant B would each get a permit for 100 acre-feet (100 acres times the statutory two acre-feet per acre irrigator minimum divided by two applicants).

Section 711.96 clarifies that the Authority's permitting program is limited to withdrawals from the Edwards Aquifer. Therefore, the section states that the Authority cannot issue a permit for the withdrawal of water from non-Edwards aquifers. Similarly, the section provides a mechanism whereby applications for wells withdrawing water from multiple aquifers, including the Edwards Aquifer, will be granted by the Authority only for a quantity corresponding to the amount the well withdraws from the Edwards Aquifer. Section 1.08(b) of the Act makes it clear that the Authority's regulatory powers do not extend to aquifers other than the Edwards Aquifer or to surface waters. Thus, the Authority lacks the power to issue a permit for water withdrawn by an applicant during the historical period from an aquifer other than the Edwards. Notwithstanding this rule, permit applicants or permit holders remain free to pump groundwater from aquifers other than the Edwards without any restriction from the Authority.

Section 711.98 identifies who may apply for, and the attributes of, an initial regular permit ("IRP"). This section is intended to locate, in one convenient reference point, the general attributes of IRPs as contemplated and intended by the Act. It is common practice for water resource management agencies to identify the criteria necessary to implement their permitting programs. The list of the attributes of an IRP, together with the list of criteria which must be proven in order to obtain such a permit, will assist in enabling the Authority to manage all points of withdrawal from the Edwards Aquifer, and to accomplish its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

The attributes of IRPs are discussed below. Where appropriate, the statutory basis for each rule is identified in parentheses. Only existing users may apply for IRPs (Act § 1.16). IRPs are transferrable (Act § 1.34(a)). IRPs have a perpetual term (Act § 1.16(g)). IRPs may be proportionally adjusted in accordance with the Authority's rules in Subchapter G of Chapter 711 (Act § 1.16(e)). IRPs may be retired in accordance with the Authority's springflow maintenance rules, equal percentage reduction rules, and permit retirement rules. (Act sections 1.14(h), 1.16(g), and 1.21). IRPs may be suspended in accordance with the Authority's demand management rules and groundwater trust rules (Act sections 1.14(d) and 1.22). IRPs may be interrupted in accordance with the Authority's drought management rules, critical period management rules, and springflow maintenance rules (Act sections 1.14(d) and (h), and 1.26). IRPs may be abandoned and/or cancelled in accordance with the Authority's abandonment and cancellation rules (Act § 1.16(g)). This rule does not itself set forth the substantive rules relating to proportional adjustment, permit retirement, and so on. Instead, it merely clarifies that IRPs are subject to those rules and provides a reference to those rules.

The section also lists the elements which an initial regular permit applicant must prove in order to be granted such a permit. For example, the application (declaration) must have been filed and application fee paid on or before December 30, 1996 (required by Act § 1.16(b)) and Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996) (holding that declarations must be filed within six months after the effective date of the Act, i.e., December 30, 1996). The application must identify an existing well which was owned by the applicant, or the applicant's predecessor in interest, on June 1, 1993, and the well must be located within the Authority's boundaries and must be a point of withdrawal for Edwards aquifer water. (Act sections 1.14(e), 1.03(1), 1.08(b)). The usage upon which the application is based must have been made during the historical period and by the applicant, a prior user who is the applicant's predecessor in interest, or a contract user. This requirement is included in order to clarify that an application must be based upon historical use and an applicant cannot base his application upon historical use by others with whom the applicant lacks any connection to the well in question. The historical withdrawals must have been placed to a beneficial use for irrigation, municipal or industrial use. (See the discussion for § 711.92, above.) The rule provides that in order to obtain an IRP, the well cannot qualify for exempt well status. (See discussion of public comments on this rule, below.) Finally, the application must be in compliance with the Act and the Authority's rules.

Section 711.98(k) explains that IRPs shall be issued in an amount as calculated in §§ 711.176 and/or 711.180 of the Chapter 711 rules. These rules explain how permit amounts are arrived at and are discussed in more detail below.

Section 711.100 identifies who may apply for, and the attributes of, an additional regular permit ("ARP"). This section is intended to locate, in one convenient reference point, the general attributes of ARPs as contemplated and intended by the Act. It is common practice for water resource management agencies to identify the criteria necessary to implement their permitting programs. The list of the attributes of an ARP, together with the list of criteria which must be proven in order to obtain such a permit, will assist in enabling the Authority to manage all points of withdrawal from the Edwards Aquifer, and to accomplish its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

The attributes of ARPs are discussed below. The rule provides that any person owning or proposing to construct a well may apply for an ARP if final determinations have been made by the Authority on all IRP applications and the board has declared it will accept ARP applications. § 1.18 of the Act makes it clear that ARPs are subject to the 450,000 and 400,000 acre-feet "caps," and ARPs may be issued by the Authority only if, after all IRPs are issued, there is still water available under those caps for permitting of ARPs. Thus, the Authority will only begin accepting ARP applications in the unlikely event that the cap hasn't been met after all IRP determinations. The rule provides that any applications submitted prior to that time will be returned to the applicant.

Section 711.100 also provides that ARPs are transferrable (Act § 1.34(a)) and have a perpetual term. The Authority has concluded that the term is perpetual because, once issued, ARPs are functionally no different than IRPs, which have a perpetual term.

The rule provides that ARPs may be retired in accordance with the Authority's springflow maintenance rules, equal percentage reduction rules, and permit retirement rules. (Act sections 1.14(h) and 1.21). ARPs may be suspended in accordance with the Authority's demand management rules and groundwater trust rules (Act sections 1.14(d) and 1.22). ARPs may be interrupted in accordance with the Authority's drought management rules, critical period management rules, and springflow maintenance rules (Act sections 1.14(d) and (h), and 1.26). The Authority has also concluded in this rule that, just as with IRPs, ARPs may be abandoned and/or cancelled in accordance with the Authority's abandonment and cancellation rules. The Authority reached this conclusion because, once issued, ARPs are functionally no different than IRPs, and it would be nonsensical for ARPs to be immune from the abandonment and cancellation rules while IRPs are subject to such rules. This rule does not itself set forth the substantive rules relating to permit retirement, suspension, and so on. Instead, it merely clarifies that ARPs are subject to those rules and provides a reference to those rules.

Section 711.100 also lists the elements which, assuming there is water available for such permits, an additional regular permit applicant must prove in order to be granted such a permit. For example, the applicant must pay a fee; the application must identify an existing or proposed well; the well must be located within the Authority's boundaries and must be a point of withdrawal for Edwards aquifer water; and the water produced must be used within the Authority's boundaries. (Act sections 1.14(e), 1.03(1), 1.08(b), 1.34(a)). The withdrawals must be proposed to be placed to a beneficial use for irrigation, municipal or industrial use. (See the discussion for § 711.92, above.)

Section 711.100 also provides that an ARP application cannot be granted unless there will continue to be sufficient water (i.e., enough water below the cap) to provide for any restorations to IRPs required in the event that either of the withdrawal caps are raised. This provision is included because § 1.16(d) gives the Authority the ability, under limited circumstances, to raise either of the withdrawal caps. In the event these caps are raised, the Authority will, to the extent possible, restore back to IRPs amounts reduced off of IRP amounts through the "proportional adjustment" or "equal percentage reduction" processes mandated by sections 1.16(e) and 1.21(c) of the Act, respectively. The Act gives a clear preference to IRPs over ARPs and to existing users, generally. Thus, in keeping with that preference, the Authority has determined that no ARPs shall be issued if such issuance will reduce the amount of water available to restore to any IRP.

The rule provides that in order to obtain an ARP, the well cannot qualify for exempt well status. (See discussion of public comments on the rule 711.98, below.) The rule also requires that the proposed withdrawals be consistent with the Authority's comprehensive groundwater management rules. As originally proposed, the rule included a requirement that the applicant demonstrate that he has no other reasonable source of water from a municipal supply. This requirement applies to term and emergency permits, but was inadvertently added to this rule for ARPs, and was not intended to be included among the requirements for an ARP. Accordingly, the Authority has deleted this requirement in the rule as adopted. Finally, the application must be in compliance with the Act and the Authority's rules.

Section 711.102 identifies who may apply for, and the attributes of, a term permit. This section is intended to locate, in one convenient reference point, the general attributes of term permits, as contemplated and intended by the Act. It is common practice for water resource management agencies to identify the criteria necessary to implement their permitting programs. The list of the attributes of a term permit, together with the list of criteria which must be proven in order to obtain such a permit, will assist in enabling the Authority to manage all points of withdrawal from the Edwards Aquifer, and to accomplish its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

The rule provides that any person owning or proposing to construct a well may apply for a term permit. Section 1.19 of the Act vests the Authority with the discretion to issue term permits. Because the Act does not require the Authority to issue term permits, and because it is charged with managing, conserving and protecting the aquifer, the Authority will not issue term permits unless the board has issued an order authorizing the issuance of such permits. The rule provides that the Authority will only begin accepting term permit applications after such an order has been issued. Any applications submitted prior to that time will be returned to the applicant. The board is also to specify, by January 15 of each year, the total quantity of water from each pool which may be withdrawn pursuant to term permits.

Section 711.102 also provides that term permits are only transferrable as to ownership (Act § 1.34(a)). Term permits are designed to be issued for special cases. Their issuance will be based upon highly specific facts as to the need of the applicant and the place and purpose of use. If a party applies for and receives a permit based upon his specific needs, it would defeat the limited purpose of term permits to allow the permit holder to then sell the permit to a third party for totally unrelated uses and places of use.

Section 711.102 provides that term permits may be interrupted if certain index wells drop to certain levels. As proposed, the rule was keyed to three index wells. In response to comments, the Authority has amended the rule so that only two index wells apply. Specifically, two different interruption criteria are specified. First, for a well located in the San Antonio pool, a term permit may be interrupted if the J-17 index well measures at or less than 665 feet above mean sea level (msl). Second, for a well located in the Uvalde pool, a term permit may be interrupted if the J-27 index well measures at or less than 865 feet above msl. These interruption criteria are mentioned in the Act.

Section 711.102 next provides that term permits may also be interrupted in accordance with the Authority's springflow maintenance rules, critical period management rules, and drought management rules. (See Act sections 1.14(d) and (h), and 1.26). This rule does not itself set forth the substantive rules relating to springflow maintenance, critical period and drought management rules. Instead, it merely clarifies that term permits are subject to those rules and provides a reference to those rules.

Section 711.102 next provides that a term permit may be issued for any period of time that the Authority considers feasible, but not to exceed 10 years. This provision derives directly from § 1.19(a) of the Act.

Section 711.102 also lists the elements which, assuming water is available for term permits, a term permit applicant must prove in order to be granted such a permit. For example, the applicant must pay a fee; the application must identify an existing or proposed well; the well must be located within the Authority's boundaries and must be a point of withdrawal for Edwards Aquifer water; and the water produced must be used within the Authority's boundaries. (Act sections 1.14(e), 1.03(1), 1.08(b), 1.34(a)). Further, the well cannot qualify for exempt well status. (See discussion of public comments on the rule 711.98, below.) The rule also requires that the applicant be in compliance with any other groundwater permits held by him or her, proposed withdrawals be consistent with the Authority's comprehensive groundwater management rules, and that the applicant has no other reasonable source of water from a municipal distribution system. Because term permits are more vulnerable to interruption than are initial and additional regular permits, they are not as desirable or dependable for water users' needs, nor are they particularly desirable from the Authority's standpoint. The Authority wishes to discourage the drilling of numerous new wells into the aquifer in order to satisfy the short-term needs of the kind required for a term permit.

Because the Authority is charged with managing withdrawals from the aquifer, § 711.102 requires that the applicant demonstrate that: the withdrawals pursuant to the proposed term permit will not unreasonably negatively affect other permittees and the applicant will take all reasonable measures to conserve water. The proposed use of water pursuant to the permit application must be economically feasible in relation to the proposed length of the permit. The applicant must, where applicable, have an approved on-site sewer system or a permit to construct such a system. Finally, the application must be in compliance with the Act and the Authority's rules.

Section 711.104 identifies who may apply for, and the attributes of, an emergency permit. This section is intended to locate, in one convenient reference point, the general attributes of emergency permits, as contemplated and intended by the Act. It is common practice for water resource management agencies to identify the criteria necessary to implement their permitting programs. The list of the attributes of an emergency permit, together with the list of criteria which must be proven in order to obtain such a permit will assist in enabling the Authority to manage all points of withdrawal from the Edwards Aquifer, and to accomplish its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

The rule provides that any person owning a well may apply for an emergency permit. Section 711.104 provides that emergency permits are not transferrable. This is because emergency permits are designed to be issued for special cases. Their issuance will be based upon highly specific facts relating to the need of the applicant, and the place and purpose of use. If a party applies for and receives an emergency permit based upon his specific needs, it would defeat the very limited purpose of emergency permits to allow the permit holder to then sell the permit to a third party.

Section 711.104 provides that, unlike other withdrawal permits issued by the Authority, emergency permits are not interruptible and may have a term that does not exceed 30 days. Pursuant to § 1.20 of the Act and § 711.104, emergency permits are intended to be issued only under very limited circumstances. They may be issued only "to prevent the loss of life or to prevent severe, imminent threats to the public health or safety." Given such circumstances, combined with the fact that, pursuant to § 1.20 of the Act, emergency permits are generally only valid for 30 days, the Authority has determined that it would be counterproductive to subject emergency permits to interruption.

Section 711.104 next lists the elements which an applicant must prove in order to be granted an emergency permit. The applicant must pay a fee; the application must identify an existing or proposed well; the well must be located within the Authority's boundaries and must be a point of withdrawal for Edwards Aquifer water; and the water produced must be used within the Authority's boundaries. (Act sections 1.14(e), 1.03(1), 1.08(b), 1.34(a)). Further, the well cannot qualify for exempt well status. (See discussion of public comments on the rule 711.98, below.) The withdrawals pursuant to the proposed permit must be placed to a beneficial use for irrigation, municipal or industrial use. The rule also requires that the applicant be in compliance with any other groundwater permits held by him or her and that the withdrawal amounts authorized in all other groundwater withdrawal permits held by the applicant, if any, have been exhausted. Before an applicant may be issued a permit, he or she must have no other source of water from a municipal distribution system. Because emergency permits are issued for very short terms, they are not a particularly dependable water source, nor are they a long-term solution to an applicant's water needs. Therefore, Authority wishes to discourage the drilling of numerous new wells into the aquifer in order to satisfy the short-term needs of the kind required for an emergency permit. The Authority wishes to encourage the use of alternate water sources, such as a municipal distribution system, in lieu of emergency permits. Section 711.104, as adopted, furthers that objective.

Pursuant to § 1.20 of the Act, § 711.104 requires the applicant demonstrate that he or she will take all reasonable measures to conserve water. Finally, the application must be in compliance with the Act and the Authority's rules.

In keeping with the purpose of an emergency permit, § 711.104 provides that, if an emergency permit is to be issued, the board shall issue a permit which authorizes only the withdrawal of an amount of Edwards Aquifer water which is necessary to prevent the loss of life or to prevent severe, imminent threats to public health or safety as demonstrated in the application.

Section 1.15(a) and (b) of the Act direct the Authority to manage and regulate all withdrawal points from the aquifer and to require a permit for any person seeking to construct a well or other works designed to withdraw aquifer water. Section 1.08(a) of the Act endows the Authority with broad powers to manage, conserve, preserve and protect the aquifer and prevent the waste or pollution of water in the aquifer. Activities related to the construction of wells have the obvious potential to negatively impact the quantity and quality of water within the aquifer. Therefore, the Authority adopts § 711.108 which implements the Authority's well construction permitting program. Section 711.108 identifies who may apply for, and the attributes of, a well construction permit ("WCP"). This section is intended to locate, in one convenient reference point, the general attributes of WCPs as contemplated and intended by the Act. It is common practice for water resource management agencies to identify the criteria necessary to implement their permitting programs. The list of the attributes of a WCP, together with the list of criteria which must be proven in order to obtain such a permit will, assist in enabling the Authority to manage all points of withdrawal from the Edwards Aquifer, and to accomplish its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

The rule provides that one must first apply for and obtain a WCP in order to:

1) construct, install, drill, equip, complete, alter, operate or maintain a well or other works designed for the withdrawal of aquifer water;

2) construct, install, drill, equip, complete, alter, operate or maintain a well or other works designed for the monitoring of the water quality or level of the aquifer;

3) equip, complete, alter, operate or maintain a well pump installed or to be installed on an aquifer well; or

4) construct, install, drill, equip, complete or alter a well or other works designed to withdraw groundwater from an aquifer other than the Edwards Aquifer, but that intersects the Edwards Aquifer.

(For a more thorough discussion of these criteria, see the discussion of § 711.12, above.)

Section 711.108 provides that WCPs are not transferrable. This is because WCPs are intended to be issued to individual applicants who can demonstrate their intention and ability to comply with the rules of the Authority in the construction activity in question. If a party applies for and receives a WCP, the Authority believes it would defeat the very limited purpose of a WCP to allow the permit holder to then sell the permit to a third party.

Section 711.108 provides that WCPs have a term of 180 days within which construction activities must be completed. Upon application to the Authority, the permit term may be extended by one additional 180-day period if the permit holder demonstrates to the Authority that the permit holder's failure to complete the well within the original 180-day term is not due to the permit holder's own lack of diligence. Upon the expiration of the permit term, the permit automatically expires and is cancelled. The Authority believes it would be counterproductive to issue open-ended construction permits without providing any deadline within which to perform the proposed construction activities. The Authority has concluded that construction permits should be issued to allow construction of wells for which there is a real need, not for wells which may be needed at some indefinite point in the future. Further, issuance of open-ended construction permits (i.e., permits with no construction deadline) would hinder the Authority's ability to monitor permit holders' construction activities for compliance with the Authority's rules. Thus, adding a construction deadline increases the administrative convenience and effectiveness of the Authority.

Section 711.108 next lists the elements which an applicant must prove in order to be granted a WCP. The applicant must pay a fee; the application must identify an existing or proposed well; the well must be located within the Authority's boundaries and must be a point of withdrawal for Edwards Aquifer water; the withdrawals must be proposed to be placed to a beneficial use for domestic or livestock use, irrigation use, municipal use, or industrial use; and the water produced must be used within the Authority's boundaries. (Act sections 1.14(e), 1.03(1), 1.08(b), 1.34(a)).

The rule also requires that the applicant have a legal right to make withdrawals from the well. In other words, the proposed well must either be exempt, or one for which a groundwater withdrawal permit has been obtained. Section 711.108 requires that the applicant be in compliance with any other Authority permits held by him or her and that the quantity of water the well would be capable of producing, if constructed, is consistent with the quantity of water the applicant proposed to produce.

Section 711.108 requires the applicant demonstrate: that the construction and operation of the proposed well would not unreasonably negatively affect the aquifer or other permittees; and that the proposed well will be constructed, operated and maintained consistent with the Authority's own water quality rules and all other applicable local, state and federal laws relating to well construction, operation and maintenance. Section 1.11(d)(10) of the Act empowers the Authority, within its boundaries, to enforce Chapter 32 of the Texas Water Code and any rules adopted thereunder. Chapter 32 relates to issues concerning well construction. Similarly, Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. Section 36.115 prohibits the drilling of a well or alteration of a well pump without a permit. The Chapter 711 rules incorporate these requirements. The Authority believes it is appropriate to require compliance with these "other applicable laws" in § 711.108. Finally, the application must be in compliance with the Act and the Authority's rules.

Section 711.110 identifies who may apply for, and the attributes of, a monitoring well permit ("MWP"). This section is intended to locate, in one convenient reference point, the general attributes of MWPs as contemplated and intended by the Act. It is common practice for water resource management agencies to identify the criteria necessary to implement their permitting programs. The list of the attributes of a MWP, together with the list of criteria which must be proven in order to obtain such a permit will assist in enabling the Authority to manage all points of withdrawal from the Edwards Aquifer, and to accomplish its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

Section 1.15(a) and (b) of the Act directs the Authority to manage and regulate all withdrawal points from the aquifer and to require a permit for any person seeking to construct a well or other works designed to withdraw aquifer water. Section 1.08(a) of the Act endows the Authority with broad powers to manage, conserve, preserve and protect the aquifer and prevent the waste or pollution of water in the aquifer. Activities related to the construction of wells have the obvious potential to negatively impact the quantity and quality of water within the aquifer. Although a monitoring well will typically withdraw much less water than other aquifer wells, the Authority has determined that a permit should be required for such wells. The Authority cannot effectively regulate wells of which it is unaware. Further, just as with any other type of well, monitoring wells are potential conduits of contamination of the aquifer and this rule will help prevent pollution of water in the aquifer.

Section 711.110 provides that any person proposing to construct a monitoring well may apply for a MWP. Section 711.110 provides that MWPs are transferrable, non-interruptible, and perpetual in term. The Authority does not believe that the quantity of water withdrawn by monitoring wells is sufficient to warrant interruption during times of drought, etc. Further, a key function of monitoring wells is to monitor water quality and quantity in the aquifer. This function is critically important during times of drought and other circumstances during which other types of permits may be interrupted. Thus, monitoring well withdrawals are arguably more valuable and necessary during times when other permit withdrawals are subject to interruption.

Section 711.110 next lists the elements which a MWP applicant must prove in order to be granted such a permit. The applicant must pay a fee; the application must identify an existing or proposed well; the well must be located within the Authority's boundaries and must be a point of withdrawal for Edwards Aquifer water; and the well must be used for monitoring purposes. The rule also requires that the applicant demonstrate that he or she will take all reasonable measures to conserve water. Finally, the application must be in compliance with the Act and the Authority's rules.

Section 711.112 identifies the many provisions that shall be included, and the issues that are to be addressed, in any groundwater withdrawal permit issued by the Authority. It is common practice for water resource management agencies to identify and specify the contents of their permits. This list of the required contents of a groundwater withdrawal permit will assist the Authority in managing all points of withdrawal from the Edwards Aquifer, and accomplishing its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

Pursuant to section 711.112, the permit shall identify: the name, address and phone number of the permit owner and any authorized representative of the owner; the type of permit; the permit term; the purpose of use for the permit; and the maximum authorized rate of withdrawal in gallons per minute, together with the maximum total annual volume of withdrawal by purpose of use. The Authority is required, pursuant to § 1.15(d) of the Act, to specify a maximum rate and total volume of withdrawal for each groundwater withdrawal permit issued by it. Where applicable, the permit shall identify the applicant's "maximum historical use," "historical average minimum" or "irrigator minimum," "phase-1 proportionally adjusted amount," "step-up amount," "phase-2 proportionally adjusted amount," and "equal percentage reduction amount." These terms are relevant to the method by which initial regular permit amounts are calculated and reduced in order to achieve the 450,000 and 400,000 acre-feet "caps" mandated by the Act. They may also bear upon any "restoration" of permit amounts in the event that the Authority raises either of the withdrawal caps. These terms are defined and applied in sections 711.172 and 711.174 of these rules. Readers are encouraged to refer to the discussion of those sections, below, for a more complete explanation of those terms and their purposes.

Section 711.112 also requires that the permit identify the location of the well(s) for which the permit is issued; the place of use of the water withdrawn; the source of the groundwater (which must be the Edwards Aquifer); the type of meter or alternative measuring method employed on the well(s); the conditions for the retirement, suspension, or interruption of withdrawals or, where applicable, the conditions for renewal of the permit; any reporting requirements imposed upon the permit holder; a notice that the permit is subject to the limitations provided in the Act and the Authority's rules; a listing of the standard groundwater withdrawal conditions set forth in the Subchapter F rules (discussed in more detail below); and any other appropriate conditions on the withdrawal of water from the aquifer.

Section 711.116 identifies the many provisions that shall be included, and issues that are to be addressed, in any well construction permit ("WCP") issued by the Authority. It is common practice for water resource management agencies to identify and specify the contents of their permits. This list of the required contents of a WCP will assist the Authority in managing all points of withdrawal from the Edwards Aquifer, and accomplishing its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

Pursuant to § 711.116, the permit shall identify: the name, address and phone number of the permit owner and any authorized representative of the owner; the type of permit; the permit term; and the purpose of use for the permit. The Authority is required, pursuant to § 1.15(d) of the Act, to specify a maximum rate and total volume of withdrawal for each groundwater withdrawal permit issued by it. Thus, § 711.116 requires the permit to specify the maximum authorized rate of withdrawal in gallons per minute, together with the maximum annual volume of withdrawal by purpose of use for the proposed well.

As originally proposed, the rule also required the permit to specify the maximum monthly rate of withdrawals in acre-feet. This requirement has been deleted to conform more closely with the two rate and volume criteria which are specified in § 1.15(d) of the Act.

Section 711.116 also requires that the permit provide a detailed legal description of the well location and identify: the applicant's specific legal authority to make withdrawals if the well is constructed; the source of the groundwater (which must be the Edwards Aquifer); the pump size, pumping rate, pumping method and other specifications for metering the well; the internal diameter, well depth and other construction specifications for the well; and any reporting requirements imposed upon the permit holder. The permit must also include a notice that the permit is subject to the limitations provided in the Act and the Authority's rules and any other appropriate conditions on the withdrawal of water from the aquifer.

Section 711.118 identifies the many provisions that shall be included, and the issues that are to be addressed, in any monitoring well permit ("MWP") issued by the Authority. It is common practice for water resource management agencies to identify and specify the contents of their permits. This list of the required contents of a MWP will assist the Authority in managing all points of withdrawal from the Edwards Aquifer, and accomplishing its other various duties to manage, conserve, preserve, and protect the Edwards Aquifer and to prevent waste or pollution of the aquifer.

Pursuant to § 711.118, the permit shall identify: the name, address and phone number of the permit owner and any authorized representative of the owner; the type of permit; the permit term; and the purpose of use for the well authorized by the permit. The Authority is required, pursuant to § 1.15(d) of the Act, to specify a maximum rate and total volume of withdrawal for each groundwater withdrawal permit issued by it. Thus, § 711.118 requires the permit to specify the maximum authorized rate of withdrawal in gallons per minute, together with the maximum annual volume of withdrawal by purpose of use for the proposed well.

As originally proposed, the rule also required the permit to specify the maximum monthly rate of withdrawals in acre-feet. This requirement has been deleted to conform more closely with the two rate and volume criteria which are specified in § 1.15(d) of the Act.

Section 711.118 also requires that the permit provide a detailed legal description of the well location and identify: the purpose of the monitoring activity; the source of the groundwater (which must be the Edwards Aquifer); the pump size, pumping rate, pumping method and other specifications for metering the well; the internal diameter, well depth and other construction specifications for the well; the construction specifications for any additional monitoring equipment to be installed or associated with the well; and any reporting requirements imposed upon the permit holder. The permit must also include a notice that the permit is subject to the limitations provided in the Act and the Authority's rules and any other appropriate conditions on the withdrawal of water from the aquifer.

Many of the sections listing the required contents of Authority permits include provisions requiring: "any other appropriate conditions . . . as determined by the Authority" or "any other information required by the board to implement the Act or the Authority's rules." (See §§ 711.112(26) and (27), 711.116(16) and (17), and 711.118(17) and (18).) The basis for these provisions lies in the need for flexibility in the processing and issuance of applications by the Authority. The Authority will need to exercise such flexibility. The processing and issuance of many applications will be straight-forward, presenting a generic and well-defined set of issues to be examined. Other applications, however, will be unique and will present special issues and raise questions that are specific to that application. The provisions allowing the Authority to require "other information" provides the Authority with some flexibility in dealing with unique situations.

Subchapter F

While the Act requires the Authority to implement a permitting system, it also imposes a number of restrictions, limitations and other requirements upon the withdrawal of water from the Edwards Aquifer. Sections 711.130-711.134, Subchapter F of the Chapter 711 rules, harmonize these provisions of the Act by notifying holders of groundwater withdrawal permits that they must comply with a number of conditions, including: avoiding actions that adversely affect water quality or threatened or endangered aquifer-dependent species; complying with other Authority rules, including rules designed to protect water quality, conserving water, maximizing beneficial use of water, protecting aquatic and wildlife habitat and threatened or endangered species, and protecting instream uses, bays and estuaries; and complying with the Act. These conditions will be incorporated into the terms of the permits when they are issued. These conditions implement requirements from the Act and are necessary for the Authority to effectively regulate its permits in order to manage, conserve, preserve, and protect the aquifer and to prevent the waste or pollution of water in the aquifer. The Subchapter F rules do not themselves set forth the substantive conditions which apply to permits issued by the Authority. Instead, they merely clarify that the permits are subject to those conditions and provide a reference to the rules implementing those conditions.

Section 711.130 states that the purpose of Subchapter F is to establish the standard conditions required to be contained in a groundwater withdrawal permit. Those conditions are designed, among other things, to: 1) protect the quality of water in the aquifer; 2) protect the water quality of the surface streams to which the aquifer provides springflow; 3) achieve water conservation and the maximization of groundwater available for withdrawal from the aquifer; 4) protect aquatic and wildlife habitat and listed threatened or endangered species; and 5) provide for instream uses, bays and estuaries. These objectives derive directly from § 1.14(a) of the Act, and the Authority is given, by that section of the Act, a clear mandate to limit "authorizations to withdraw water from the aquifer" (i.e. permits) in order to achieve those objectives. Because the objectives listed in § 711.130 derive directly from § 1.14(a) of the Act, no further elaboration is required.

In response to public comments, and as discussed more fully in the public comments discussion, the Authority has revised and reorganized §711.130 and §711.134. These revisions are primarily non-substantive and are intended to make the rule more easily understood.

Section 711.132 simply clarifies that Subchapter F applies to all groundwater withdrawal permits issued by the Authority.

Section 711.134 is included in the Chapter 711 rules in order to comply with the statutory mandate contained within § 1.16(h) of the Act. Section 1.16(h) requires the Authority to provide notice to each permit holder that his or her permit "is subject to limitations" provided in the Act. These limitations are referred to by the Authority as "conditions" upon the permits issued by the Authority. Thus, 711.134 lists each of the conditions (or limitations) which the Act empowers or requires the Authority to impose upon groundwater withdrawal permits. The section does not itself set forth the substance of the conditions which apply to permits issued by the Authority. Instead, it merely clarifies that the permits are subject to those conditions and provides a reference to the rules or other applicable laws which actually implement those conditions. The section also specifies that the permit holder is required to comply with the listed conditions. This section is intended to locate, in one convenient reference point, the standard conditions to which all groundwater withdrawal permits are subject and with which all permit holders must comply.

The conditions listed in § 711.134, and the statutory bases therefor, are as follows:

1) Permittees must comply with the Authority's rules relating to the construction, operation, and maintenance of wells. Sections 1.08(a), 1.11(a), (b), (d)(10) and (11), (h), 1.14(a)(1) and (2), 1.15(a) and (b), 1.35(d) of the Act and Chapters 32, 36 and 49 of the Texas Water Code empower and require the Authority to regulate the construction, operation and maintenance of Edwards Aquifer wells within its boundaries.

2) Permittees must comply with the Authority's rules relating to the abandonment and closure of wells. Sections 1.08(a), 1.11(a),(b), (d)(8),(10), and (11), (h), 1.14(a), 1.15(a), and 1.16(g), 1.35(d) of the Act and Chapters 32, 36 and 49 of the Texas Water Code empower and require the Authority to implement and enforce rules regarding the abandonment and closure of wells.

3) Permittees must comply with the Authority's rules relating to the spacing of wells. Sections 1.08(a), 1.11(a), (b), and (h), 1.14(a), 1.15(a), and 1.35(d) of the Act and Chapters 36 and 49 of the Texas Water Code empower and require the Authority to regulate the spacing of Edwards Aquifer wells within its boundaries.

4) Permittees must comply with the Authority's rules relating to the installation, operation and maintenance or well fields. Sections 1.08(a), 1.11(a), (b) and (h), 1.14(a), 1.15(a), 1.35(d) of the Act and Chapters 36 and 49 of the Texas Water Code empower and require the Authority to regulate wells fields of Edwards Aquifer wells within its boundaries.

5) Permittees must comply with the Authority's rules relating to the recharge of the aquifer. Sections 1.08(a), 1.11(a), (b), (d), (f) and (h), 1.14(d), 1.15(a), 1.27(b), 1.44, 1.45 of the Act empower and require the Authority to regulate artificial recharge activities related to the Aquifer.

6) Permittees must take no action that pollutes or contributes to the pollution of the aquifer. Sections 1.08(a), 1.14(a), 1.15, and 1.35(d) of the Act empower and require the Authority to regulate and prevent pollution of the Aquifer.

7) Permittees must comply with the Authority's aquifer water reuse rules. Sections 1.03(19), 1.08(a), 1.11(a), (b), (d), and (h), 1.13, 1.14(d), 1.15(a), 1.21(b), 1.23, 1.24(c), and 1.27(b)(3) of the Act empower and require the Authority to regulate and require the beneficial use and utilization of groundwater withdrawn from the aquifer that is reused.

8) Permittees are prohibited from wasting aquifer water. Sections 1.08(a), 1.11(a), (b), (f), and (h), 1.14(e), (f), 1.15(a), (b), (c) and (d), 1.16(c), (d), (g) and (h), 1.18, 1.19, 1.20, 1.33, 1.35, and 1.44(a) of the Act and Chapter 36 of the Texas Water Code empower and require the Authority to regulate and prevent the waste of water from the Aquifer.

9) Permittees must comply with the Authority's groundwater conservation rules. Sections 1.01, 1.08(a), (b), 1.11(a), (b), (d), 1.14(a), 1.15(a), 1.17(c), 1.21(b), 1.23(a), (b) and (c), 1.24, 1.25(a), 1.27(b), and 1.34(b) of the Act empower and require the Authority to adopt rules designed to conserve groundwater.

10) Permittees must comply with the Authority's demand management rules. Sections 1.08(a), 1.10(i), 1.11(a), (b), (d) and (h), 1.14(h), 1.15(a), 1.17(c), 1.22(a) and (b), 1.25(a), and 1.29(a) of the Act empower and require the Authority to adopt rules designed to manage the demand for aquifer water.

11) Permittees must comply with the Authority's drought management rules. Sections 1.08(a), 1.11(a), (b), and (h), 1.14(d) and (f), 1.15(a), 1.17(c) of the Act empower and require the Authority to adopt rules designed to manage the aquifer during times of drought.

12) Permittees must comply with the Authority's critical period management rules. Sections 1.08(a), 1.11(a), (b) and (h), 1.14(d) and (f), 1.15(a), 1.17(c) and 1.26 of the Act empower and require the Authority to adopt rules designed to manage the aquifer what the Act describes as "critical periods."

13) and 14) Permittees must comply with the Authority's rules relating to the installation, operation and maintenance of meters or alternative measuring methods, including any record keeping and reporting requirements contained therein. Sections 1.08(a), 1.11(a), (b),(d) and (h), 1.15(a), 1.31, 1.32 and 1.33(a) of the Act and Chapters 36 and 49 of the Texas Water Code empower and require the Authority to adopt rules regulating meters or alternative measuring devices and their installation on aquifer wells.

15) Permittees must comply with the Authority's rules requiring the beneficial use of aquifer water and prohibiting waste. Sections 1.08(a), 1.11(a), (b), (f) and (h), 1.14(e) and (f), 1.15(a), (b), (c) and (d), 1.16(c), (d), (g) and (h), 1.18, 1.19, 1.20, 1.33(a), 1.35and 1.44(a) of the Act and Chapter 36 of the Texas Water Code empower and require the Authority to adopt rules requiring beneficial use and prohibiting waste.

16) Permittees must comply with the Authority's rules relating to the interruption or retirement of withdrawal rights. Sections 1.08(a), 1.11(a), (b), (d) and (h), 1.14(a), (d), (f) and (h), 1.15(a), 1.17(c) and 1.27(a) and (b) of the Act empower and require the Authority to adopt rules providing mechanisms whereby permitted withdrawal rights may be interrupted and/or retired.

17) and 18) Permittees must comply with the Authority's rules relating to the method by which permits are "proportionally adjusted" or reduced by "equal percentage reduction" in order to achieve the withdrawal caps. Sections 1.08(a), 1.11(a), (b) and (h), 1.14(b) and (c), 1.15(a) and (b), 1.16, 1.18(a), (b) and (c), 1.20(d), 1.21(a) and (c), 1.44(d) of the Act empower and require the Authority to implement such reduction strategies.

19) Permittees must comply with the Authority's rules relating to the retirement of withdrawal rights. Sections 1.08(a), 1.11(a), (b) and (h), 1.14(h), 1.15(a), 1.16(g), 1.21, 1.22(a), 1.24(c), 1.29(a), (c) and (d) of the Act empower and require the Authority to adopt rules providing mechanisms whereby permitted withdrawal rights may be interrupted.

20) Permittees must comply with the Authority's rules relating to the acquisition of additional water supplies. Sections 1.08(a), 1.11(a), (b), and (h), 1.15(a), 1.25(a) and (b), and 1.27(b) of the Act empower and require the Authority to adopt such rules.

21) Permittees must comply with the Authority's rules requiring the providing of notice in the event of a change in name or mailing address.

22) Permittees must pay all applicable Authority fees. Such fees are authorized by § 1.29 of the Act.

23) Permittees must comply with the Authority's rules relating to the interim authorization period. Sections 1.08(a), 1.11(a), (b) and (h), 1.15(a) and (b), 1.16(c), 1.17 and 1.33(a) of the Act empower and require the Authority to adopt rules governing the interim authorization period.

24) and 25) Permittees must comply with the Authority's rules relating to the abandonment and cancellation of wells or permits. Sections 1.08(a), 1.11(a), (b), (d)(8) and (h), 1.14(b) and (c), 1.15(a) and 1.16(g) of the Act empower and require the Authority to adopt rules governing abandoned or cancelled wells or permits.

26) Permittees must comply with the Authority's rules relating to the method by which permits amounts may be are "restored" in the event the withdrawal caps are raised. Sections 1.08(a), 1.11(a), (b) and (h), 1.14(d) and 1.15(a) of the Act empower the Authority to adopt such rules.

27) Permittees must comply with the Authority's rules regulating the transfer of permit rights. Sections 1.08(a), 1.11(a), (b) and (h), 1.15(a), 1.22(a), 1.24(c), 1.28(b), 1.30, and 1.34 of the Act and Chapter 36 of the Texas Water Code empower the Authority to adopt such rules.

28) Permittees must comply with the Authority's prohibitions against transferring water outside the boundaries of the Authority. Section 1.34(a) of the Act empower the Authority to prohibit such transfers.

29) - 32) Finally, permittees must comply with the terms of their permits, the Act, the Authority's rules, and any other condition which may, in the board's discretion, be reasonable and appropriate. The basis for these provisions lies in the need for flexibility in the issuance and regulation of permits by the Authority. The Authority will need to exercise such flexibility. Many permits will be straight-forward, presenting a generic and well-defined set of issues to be examined. Other permits, however, will be unique and will present special issues and raise questions that are specific to that permit. The provisions allowing the Authority to require compliance with "other reasonable conditions" provides the Authority with some flexibility in dealing with unique situations.

Subchapter G

The Act requires the Authority to implement a permitting system. The Act also imposes two "caps" which limit the aggregate amount of certain permitted withdrawals which may be issued by the Authority. Specifically, the Act mandates that, initially, total permitted withdrawals for initial and additional regular permits may not exceed 450,000 acre-feet per year and, after January 1, 2008, total permitted withdrawals may not exceed 400,000 acre-feet per year. In the absence of these "caps," total permitted withdrawals might exceed the cap amounts. Therefore, the Act requires the Authority to "proportionally adjust" initial regular permit amounts to reach the 450,000 acre-feet cap, and implement "equal percentage reductions" in order to reach the 400,000 acre-feet cap. The Act also imposes several permit "minimums" applicable to certain initial regular permit holders. Sections 711.160-711.182, Subchapter G of the proposed Chapter 711 rules, implement these provisions of the Act by establishing the amount of groundwater available for permitting, explaining which types of permits are subject to the caps, implementing a method of calculating the permit minimums, and setting out the procedures for carrying out "proportional adjustment" and "equal percentage reductions."

Section 711.160 explains that the purpose of the subchapter is to establish the amount of groundwater available for permitting, and to set forth the procedures to be used to proportionally adjust permit amounts and implement equal percentage reductions to permit amounts. The factual basis for § 711.160 is grounded in legal facts found in the Act. A review of the Act demonstrates that the Authority's permit program needs to establish the amount of groundwater available for permitting for each category of groundwater withdrawal permits; and establish procedures for implementing "proportional adjustments" and "equal percentage reductions" of initial regular permits under certain circumstances. For initial and additional regular permits, sections 1.14 (b) and (c) of the Act impose two permitted withdrawal parameters or "caps," subject to certain limitations. The first cap (1.14 (b)) sets a maximum of 450,000 acre-feet of permitted withdrawals per year until December 31, 2007. The second cap (1.14 (c)) sets a maximum of 400,000 acre-feet per year of permitted withdrawals beginning January 1, 2008. Section 1.16 (e) of the Act requires that initial regular permits be proportionally adjusted in the event that the aggregate maximum historical use of groundwater from the aquifer exceeds 450,000 acre-feet per annum. Section 1.21(c) requires equal percentage reductions of initial regular permits and additional regular permits (if any) in order to meet the 400,000 acre-feet per annum "cap." These legislative facts form the basis of and set parameters for the purpose of Subchapter G as stated in this section. The rules set forth in this subchapter implement these requirements of the Act. In that §711.160 identifies these purposes to be advanced by subchapter G, a rational connection is established between the legislative factual basis in the Act and the final rule as adopted.

Section 711.162 provides that Subchapter G only applies to certain categories of groundwater withdrawal permits. The factual basis for § 711.162 is grounded in legal facts found in the Act. The Authority may issue other types of permits, such as well construction permits. However, the Authority interprets the "caps" in sections 1.14(b) and (c) as being applicable only to initial and additional regular permits. Similarly, it interprets the "equal percentage reduction" provisions of § 1.21(c) to apply to initial and additional regular permits. A review of § 1.16(e) of the Act shows that it may only apply to initial regular permits. Initial and additional regular permits are both groundwater withdrawal permits. There are other types of groundwater withdrawal permits recognized in the Act which require consideration of the amount of groundwater available for permitting (term permits and emergency permits). Monitoring well permits, while not mentioned in the Act, also exist within the Authority boundaries and require treatment in this subchapter. These facts form the basis for § 711.162. In that § 711.162 limits the scope of subchapter G to groundwater withdrawal permits, there is a rational connection between the factual basis and the final rule as adopted.

Section 711.164 provides that the aggregate withdrawal "caps" - 450,000 acre-feet from the effective date of these rules through December 31, 2007 and 400,000 acre-feet thereafter - apply to initial regular permits and additional regular permit unless either of the caps is increased by the Authority pursuant to § 1.14(d) of the Act. The factual basis for § 711.164 is grounded in legislative facts found in the Act. Sections 1.14(b) and (c) of the Act, respectively, provide that the amounts of groundwater available for permitting are 450,000 acre-feet per year through December 31, 2007, and 400,000 acre-fee per year thereafter, unless either of the caps is increased by the Authority pursuant to § 1.14 (d). Sections 1.14(b) and (c) do not specifically identify the groundwater withdrawal permits to which the "caps" apply. Those sections do not state that the caps apply to all permits. However, a review of the Act as a whole shows that these caps can logically only apply to initial and additional regular permits. In this analysis, it is important to also consider the import of §§ 1.16(e), 1.18(a), 1.19, 1.20, and 1.21(a) of the Act. The "cap" is made applicable to initial regular permits by § 1.16(e) where it provides that, "to the extent water is available for permitting," certain permit amounts should be recognized and certain proportional adjustment procedures may need to be invoked. Section 1.16 addresses exclusively the issuance of initial regular permits. Section 1.18(a) also provides that "to the extent water is available for permitting after the issuance of permits to existing users" (i.e. initial regular permits), then the Authority may issue additional regular permits. Neither § 1.19 nor 1.20, relating to term and emergency permits, respectively, contain langauge such as "to the extent water is available for permitting" which would suggest an intent to subject those types of permits to the caps. Further, term and emergency permits are subjected to their own, independent limiting factors. Section 1.19 of the Act provides for interruption of withdrawals under term permits based on the triggering of certain index well water levels. Because of this interruptibility feature of term permits at higher aquifer levels (than initial and additional regular permits might otherwise be subject to) it is unnecessary to apply the caps in sections 1.14(b) and (c) to term permits. Section 1.20(d) specifically provides that withdrawals under emergency permits may be made "without regard to its effect on other permit holders." The Authority interprets this provision to mean that the issuance of emergency permits does not affect the permit allocation process under §1.14(b) and (c), the proportional adjustment process under § 1.16(e), or the equal percentage reduction process under § 1.12(c). Section 1.21(a) and (c) also reinforce the conclusion that the "caps" do not apply to term or emergency permits. Under subsection (a), the Authority is to prepare a plan to reduce withdrawals "under regular permits" to meet the cap. Similarly, subsection (c) establishes the process to reduce withdrawals "under regular permits" to reduce "each regular permit" to meet the cap. These legislative facts in the form of sections of the Act form the factual basis for § 711.164. This rules implements these requirements of the Act. In that § 711.164 identifies the amount of groundwater available for permitting for initial and additional regular permits, a rational connection is established between the legislative factual basis in the Act and the final rule as adopted.

Section 711.166 states that the amount of groundwater which may be withdrawn pursuant to term permits is not subject to the withdrawal caps. Instead, the aggregate amount of term permits which can be issued by the Board will be governed by the amount specified in the Board's annual order authorizing the issuance of term permits. Further, term permit withdrawals will only be authorized when the key index well levels are greater than as specified as follows: 1) for wells within the San Antonio pool, when well J-17 is greater than 665 feet above mean sea level; and 2) for wells within the Uvalde pool, when well J-27 is greater than 865 feet above mean sea level.

The Act does not establish a "cap" on the amount of groundwater available for permitting for term permits. However, under § 1.15(a) of the Act, the Authority is authorized to manage all points of withdrawals from the aquifer. Additionally, § 1.08(a) confers on the Authority all of the powers, rights, and privileges necessary to manage, conserve, preserve and protect the aquifer. Withdrawals under term permits early or late in a year when the aquifer is above certain higher index well readings (i.e. when the aquifer is "full") may affect the water supply that will be available to the holders of initial regular permits during periods of low rainfall and high rates of withdrawals. Term permit withdrawals may also affect the performance of the Authority's other aquifer management programs. The amount of groundwater that is in the aquifer at the beginning of a year varies based on the prior year's rainfall and amount of withdrawals. Accordingly, the act of establishing, by order of the Board, on an annual basis the amount of groundwater that may be permitted under term permits will assist the Authority in managing the overall water supply that is available from the aquifer. Section 711.166 also provides the conditions set forth in the Act that term permit withdrawals will only be authorized when key index well levels are greater than as specified as follows: for wells within the San Antonio pool, when well J-17 is greater than 665 feet above mean sea level; and for wells within the Uvalde pool, when well J-27 is greater than 865 feet above mean sea level. There is a rational connection between this factual basis for § 711.166 and the rule as adopted because it provides rational limits on term permit withdrawals, which are not subject to the "cap" as discussed above for § 711.164, by specifying aggregate permissible term permit withdrawals in the Board's annual order, and by conditioning term permit withdrawals on index well readings.

Section 711.168 provides that the amount of groundwater which may be withdrawn pursuant to emergency permits is not subject to the withdrawal caps. Instead, the amount of emergency permits the board may issue shall not exceed the amount necessary to prevent the loss of life or to prevent severe, imminent threats to public health or safety. The criteria for eligibility for an emergency permit derive from §1.20 of the Act. The Act does not establish a "cap" on the amount of groundwater available for permitting for emergency permits. However, under § 1.15(a) of the Act, the Authority is authorized to manage all points of withdrawals from the aquifer. Additionally, § 1.08(a) confers on the Authority all of the powers, rights, and privileges necessary to manage, conserve, preserve and protect the aquifer . Because of the nature and duration of withdrawals under emergency permits (i.e. relatively low withdrawal amounts in rare circumstances for relatively short 30-day time periods), there is little likelihood that these withdrawals will materially affect the water supply that will available to the holders of regular permits. Moreover, emergency permit withdrawals are not likely to affect the performance of the Authority's other aquifer management programs. This section ensures that groundwater withdrawals necessary to meet emergency conditions, as described in this section, are available only in quantities of groundwater determined by the Authority to be necessary. The Act and the rules defer judgment to the Authority with regard to making a determination on whether conditions meet the criteria listed in this section and, therefore, justify an emergency permit. The maintenance of public health and safety is established in this section as a requirement that takes precedence over all other allocation requirements and parameters on groundwater withdrawn from the aquifer. Accordingly, there is a rational connection between this factual basis for § 711.168 and the rule as adopted because it provides that emergency permit withdrawals are not subject to the "cap" as discussed above for § 711.164, and that amount of withdrawals under emergency should be limited to that amount required to address the emergency.

Section 711.170 provides that the amount of groundwater which may be withdrawn pursuant to monitoring well permits is not subject to the withdrawal caps. Instead, the amount of monitoring well permits may not exceed the amount reasonably necessary to properly collect water quality samples from the aquifer. The Act does not establish a "cap" on the amount of groundwater available for permitting for monitoring well permits. However, under § 1.15(a) of the Act, the Authority is authorized to manage all points of withdrawal from the aquifer. Additionally, § 1.08(a) confers on the Authority all of the powers, rights, and privileges necessary to manage, conserve, preserve and protect the aquifer. Because of the nature and duration of withdrawals under monitoring well permits (i.e. generally low withdrawal amounts on an intermittent basis), there is little likelihood that these withdrawals will materially affect the water supply that will available to the holders of regular permits. Moreover, monitoring well permit withdrawals are not likely to affect the performance of the Authority's other aquifer management programs. This section ensures that groundwater withdrawals necessary to perform monitoring well functions are available in quantities of groundwater determined by the Authority to be necessary for this purpose. Subsection 711.170 (b) states that irrespective of the groundwater levels of index wells J-17, TD 69-47-306, or J-27, the amount of groundwater from the aquifer that the Board may permit to be withdrawn pursuant to monitoring well permits shall not exceed the amount necessary to properly collect water quality samples from the aquifer for each calendar year. This section gives proper recognition to the significance of groundwater quality monitoring to the long-term maintenance of the viability of the aquifer. Monitoring activities will not be constrained or made more difficult by groundwater policy established by the Authority to allocate withdrawals for persons with other types of permits. Accordingly, there is a rational connection between this factual basis for § 711.170 and the rule as adopted because it provides that monitoring well permit withdrawals are not subject to the "cap" as discussed above for § 711.164, and that amount of withdrawals under monitoring well permits emergency should be limited to that amount required for this purpose.

Section 711.172 sets forth the mechanism by which initial regular permits will be proportionately adjusted, if necessary, in order to reach the 450,000 acre-feet withdrawal cap or other applicable cap. The factual basis for § 711.172 is grounded in the legislative facts found in § 1.16(e) of the Act. Section 1.16(e) provides for proportional adjustment under certain circumstances. Section 1.16 is limited to initial regular permits. Accordingly, the proportional adjustment process only applies to initial regular permits. Subsection (a) of § 711.172 provides that this section only applies to initial regular permits.

Section 1.16(e) provides for, among other things, the recognition of groundwater withdrawal amounts in an initial regular permit equal to "the average amount of water withdrawn annually during the historical period." Only existing users who have "operated a well for three or more years during the historical period" qualify for this treatment. The Authority refers to this concept as the "historical average minimum." The Act provides no guidance in its text as to (1) what "operate a well" means; (2) how the "three or more years" is calculated for purpose of qualifying for the historical average minimum; and (3) how the historical average minimum is calculated for purposes of determining the average annual beneficial use during the historical period.

"Operate a well" can essentially be interpreted to mean one of at least two concepts: (1) the well is being supplied with energy, the pump is engaged, and groundwater is emanating and being discharged from the well head; or (2) the well is fully functionally and is capable of making withdrawals, but is not in fact making withdrawals or is only intermittently making withdrawals (these wells are sometimes referred to as well "capable of operation"). The "operate a well" criteria has the purpose of determining eligibility for the "historical average minimum" based on three or more years of operation. Because § 1.16 of the Act, among others, requires actual beneficial use of groundwater from the aquifer during the historical period in order to be eligible to receive an initial regular permit, the Authority interprets the phrase "operate a well" as requiring a physical discharge of groundwater from the well as constituting the operation of a well for purposes of the threshold determination of eligibility of an existing user for the "historical average minimum."

As for the "three or more years" criteria, a year could mean either that a well was operated for a full three or more years (i.e., 1095 or more continuous or intermittent days) or that the operation of the well occurred at any time in a year, albeit for a period of time less than a full year. Generally, water users do not keep their water accounting records on a daily basis. Most water use reporting is on an annual basis. Additionally, most water wells do not operate on a continuous basis. There may be days when withdrawals from a well are not required to be made. Accordingly, the Authority interprets "three or more years" to mean that an applicant is required to have withdrawn groundwater from a well and placed the water to a beneficial use in three or more years during the historical period (even if it was for no more than one day within a year).

As for the calculation of "average amount of water withdrawn annually during the historical period," the Authority refers to standard definitions of an "average" as constituting a single value that summarizes or represents the general significance of a set of unequal values and being the quotient obtained by dividing the sum total of a set of figures by the number of figures. See WEBSTER'S COLLEGIATE DICTIONARY 80 (10th ed. 1997). The "number of figures" for purposes of § 1.16(e) would be the total number of years during the historical period inclusive of an after the date of initial installation of the well, irrespective of whether withdrawals may have been made in any year. The "sum total of a set of figures" would be the total aggregate withdrawals during the historical period.

As for calculating the "historical average" as discussed above, the purpose of § 1.16(e) in allowing for a "historical average minimum" is to recognize as a minimum initial regular permit groundwater withdrawal amount the arithmetic mean (as discussed above) of the aggregate water that is required on an annual basis for the beneficial use requirements of an existing user. The actual beneficial use requirement of an existing user would necessarily include both low and high water use years. Moreover, the high years may be very high (as long as the use was not wasteful), and the low years may be very low, even including years in which there was no water use. However, these high and low years would nonetheless be accurate representations of the actual beneficial use requirements for an existing user in that particular year. Therefore, for purposes of calculation of a "historical average," a year in which a well that was capable of operation but did not in fact operate should be included for purposes of calculating the average historical beneficial use.

The Act does not provide definitions for "operate a well" or "historical average minimum." Because these terms are likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as an applicant or permittee, the Authority has determined that it is useful to define these terms. Section 711.172(b)(1) and (4) incorporates the concepts discussed upon in the factual basis discussed above providing a rational connection between the factual basis and the final rule as adopted.

The factual basis for the definition of "irrigator minimum" is derived from the legislative facts contained in the Act. Section 1.16(e) provides that existing irrigator users receive an initial regular permit for not less than 2.0 acre-feet per acre for each acre actually irrigated in any one calendar year during the historical period. During the historical period an irrigator may have placed water to beneficial use for irrigation during the historical period in four typical ways. First, the irrigator may have withdrawn groundwater from a well owned by the irrigator and irrigated a place of use owned by the irrigator. Second, the irrigator may have withdrawn groundwater from a well owned by the irrigator and irrigated a place of use owned by a third party. Third, the irrigator may have leased or assigned to a third-party the right to withdraw groundwater from a well owned by the irrigator and the third-party irrigated a place of use owned by the irrigator. Fourth, the irrigator may have leased or assigned to a third-party the right to withdraw groundwater from a well owned by the irrigator and the third-party irrigated a place of use owned by the third-party. Additionally, a transferee of an application for an initial regular permit may have relied on the placing to beneficial use for irrigation purpose that may have been done by a contract user, prior existing user or former existing user. The withdrawal of groundwater from a well, or the irrigation of a place of use may have occurred lawfully with the permission of the owner of the place of use, or unlawfully without such permission. The Authority does not interpret the Act as requiring it to issue an initial regular permit to a person who had no legal right to access either the well or the place of use for irrigation purposes. As is discussed in the definition of "existing user" in § 711.1(2), an existing user who may be eligible for an "irrigator minimum" must also be the owner of the well from which the place of use was irrigated. The Act does not provide a definition for "irrigator minimum." Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as an applicant or permittee, the Authority has determined that it is useful to define this term. Section 711.172(b)(2) incorporates the concepts discussed upon in the factual basis discussed above providing a rational connection between the factual basis and the final rule as adopted.

The factual basis for the definition of "maximum historical use" is derived from the legislative facts contained in the Act. Section 1.16(e) provides that "to the extent water is available for permitting, the board shall issue the existing user a permit for withdrawal of an amount of water equal to the user's maximum beneficial use of water without waste during any one calendar year of the historical period." The Authority refers to this concept as "maximum historical use." Section 1.16(e) also provides for the upward extrapolation of an existing user's maximum historical use" if a water user does not have historical use for a full year." Because irrigators are to receive an initial regular permit in the amount of their "irrigator minimum" as discussed above, irrigators generally do not claim "maximum historical use" other than the 2.0 acre-feet per year constituting the "irrigator minimum." The Act does not provide a definition for "maximum historical use." Because this term is likely to be regularly used by the Authority in its rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as an applicant or permittee, the Authority has determined that it is useful to define this term. Section 711.172(b)(2) incorporates the concepts discussed upon in the factual basis discussed above thereby providing a rational connection between the factual basis and the final rule as adopted.

The factual basis for the definition of "step-up amount" is derived from the legislative facts contained in the Act. Section 1.16(e) provides for the proportional adjustment of initial regular permits in the event that the aggregate maximum historical uses exceeds the amount of groundwater available for permitting (i.e. 450,000 acre-feet per annum). This section also provides for the minimum initial regular permit amounts as discussed above: the irrigator minimum and the historical average minimum. If the proportional adjustment process results in adjusting an initial regular permit below the required minimum, then the groundwater withdrawal amount in the permit must be adjusted back upwards to the applicable minimum. The definition accounts for situations in which an irrigator applicant qualifies for both the irrigator and historical average minimums, by calculating the step-up amount as the difference between the higher of the two minimums and the applicant's phase 1 proportionally adjusted amount. The Authority refers to this upward adjustment as a "step-up amount." The Act does not provide a definition for "step-up amount." Because this term is likely to be regularly used by the Authority in it rules and in the general conducting of its procedures as they relate to its permit program, as well as by the regulated community that will interact with the Authority as an applicant or permittee, the Authority has determined that it is useful to define this term. Section 711.172(b)(2) incorporates these concepts in the factual basis discussed above.

Section 1.16 (e) of the Act requires that initial regular permits be proportionally adjusted in the event that the aggregate of all maximum historical uses of groundwater from the aquifer exceeds 450,000 acre-feet per annum. The purpose of this section is to provide a procedural mechanism to achieve the 450,000 acre-foot "cap." Subsection (c) of § 711.172 reflects this purpose.

Section 1.16(e) does not define the term "proportional." The Authority refers to standard definitions of "proportional" as "having the same or a constant ratio." See WEBSTER'S COLLEGIATE DICTIONARY 936 (10th ed. 1997). Subsection (d) of 711.172 incorporates this definitional concept.

Section 1.16(e) of the Act requires that initial regular permits be proportionally adjusted in the event that the aggregate maximum historical use of groundwater from the aquifer exceeds 450,000 acre-feet per annum. The Authority has no discretion in this regard. Section 1.16(e) mandates that the proportional adjustment process be applied if the criteria in that section are satisfied. Subsection (e) of § 711.172 incorporates this duty to proportionally adjust.

Section 1.16(e), while requiring proportional adjustment under certain circumstances, does not state what procedural device should be used by the Authority to make the adjustment. Section 1.11(c) of the Act authorizes the board to issues orders to enforce the Act and its rules. The board will issue an order when it grants an application for an initial regular permit. Thus, it is appropriate also to issue an order to accomplish a proportional adjustment. The use of orders by governing bodies such as the board of directors of the Authority is a common procedural tool to effectuate a regulatory action. Therefore, subsection (f) of § 711.172 incorporates the concept of a proportional adjustment order.

Section 1.16(e), while requiring proportional adjustment under certain circumstances and giving some guidance, does not state in a detailed manner how the Authority is to calculate the adjustment. A review of § 1.16(e) reveals that several concepts and steps need to be set out in the calculation. Under § 1.16(e) it will be necessary for the Authority to determine each applicant's maximum historical use (MHU) during the historical period. The board must also determine if an applicant qualifies for an "irrigator minimum" or a "historical average minimum." Then, a proportional adjustment factor (referred to by the Authority as a "phase-1 proportional adjustment factor" or "PA-1 factor") will be calculated by subtracting 450,000 from the total of all maximum historical uses (MHUs) and dividing the result by the total of all MHUs. A "phase-1 proportionally adjusted amount" ("PA-1 Amount") will then need to be calculated for each applicant by multiplying the applicant's MHU times the PA-1 Factor and subtracting the product from the applicant's MHU. In order to implement the duty to issue initial regular permits at an irrigator minimum or an historical average minimum to an applicant who so qualifies, the Authority will then need to compare the PA-1 Amount to the minimum. If the PA-1 amount is less than the minimum, the Authority will then determine a "step-up amount" (SUA) which will be equal to the difference between the minimum and the PA-1 Amount. If, after the SUAs are made, the 450,000 "cap" will be exceeded (which the Authority estimates is likely), then the Authority will need to pursue a "withdrawal reduction" program. Section 711.180, discussed more fully below, discusses this program and will allow the Authority to further reduce withdrawals by entering into agreed orders whereby initial regular permit applicants may waive (possibly by selling to the Authority) all or part of their applications for initial regular permits. If the "withdrawal reduction" program is successful, then the 450,000 "cap" will have been met and there will be no need to do a second proportional adjustment. If, despite these waivers, the total of all PA-1 Amounts plus all SUAs still exceeds the 450,000 acre-feet cap, then a second proportional adjustment will need to implemented by calculating a "Phase-2 proportional adjustment factor" (referred to by the Authority as a "PA-2 Factor") by adding the totals of all remaining PA-1 amounts and SUAs, subtracting 450,000 from the sum, and then dividing the result by the totals of all remaining PA-1 amounts and SUAs. The second proportionately adjusted amount (PA-2 Amount) will then be calculated for each applicant as follows: for applicants eligible for an SUA, their PA-2 amount will be calculated by multiplying the PA-2 factor by their PA-1 and SUA, and subtracting the result from the total of their PA-1 amount and SUA; for those ineligible for an SUA, their PA-2 amount will be calculated by multiplying the PA-2 factor by their PA-1 amount and subtracting the result from their PA-1 amount. At this point, if not sooner, the 450,000 acre-foot cap will have been met. Subsection (g) of § 711.172 incorporates these concepts for the calculation of proportional adjustments under § 1.16(e) of the Act. The approach meets the requirements of § 1.16 of the Act and provides an integrated procedure that distributes the reduction of withdrawals among the existing initial regular permits.

Section 1.14(d) of the Act provides that the "caps" may be raised under certain circumstances. Section 1.21(c) of the Act allows for the "restoration" of reduced amounts under certain circumstances. If the "cap" is raised it will be necessary to identify how the additional groundwater available for permitting will be allocated. Subsection (h) of 711.172 provides that if the "cap" is raised, then the proportionately adjusted amounts will be restored through the inverse application of this section.

Pursuant to § 1.21 (c) of the Act, §711.174 establishes the "equal percentage reduction" process for the retirement of initial regular permits. The equal percentage reduction requirement of the Act is triggered after January 1, 2008 if the overall volume of groundwater authorized to be withdrawn from the aquifer under regular permits is greater than 400,000 acre-feet per year. Under this requirement, the maximum authorized withdrawal of each regular permit will be reduced by an equal percentage as necessary to reduce overall maximum demand to 400,000 acre-feet per year or to an adjusted amount determined under subsection (d) of § 1.14 of the Act. The equal percentage reduction process only applies to initial regular permits. (This procedure also theoretically applies to additional regular permits. However, because the Authority estimates the aggregate of the irrigator and historical average minimums will exceed the 450,000 "cap" there will likely be no water left that is available for permitting of additional regular permits after all initial regular permits have been issued.) The equal percentage reduction rules will be a subchapter of the comprehensive water management plan implementation rules in chapter 715 of this title. These rules have not yet been proposed. Section 711.174 is a cross-reference in chapter 711 to those rules in chapter 715 as an aid to those who may have an interest in that subject matter.

Section 1.16(e) provides for the various scenarios governing the groundwater withdrawal amount to be issued in an initial regular permit. There are two basic scenarios as follows: (1) the aggregate maximum historical use of all applications for initial regular permits does not exceed the 450,000 acre-foot "cap;" or (2) the aggregate maximum historical use does exceed the 450,000 acre-foot "cap." In the event of the first scenario, an applicant must receive an initial regular permit in the amount of his "maximum historical use." In the second scenario, which appears much more likely, proportional adjustment under § 1.16(e) of the Act is triggered. Under this circumstance there are six possible outcomes: (1) if an applicant does not qualify for an irrigator or historical average minimum, and no phase-2 proportional adjustment is performed, then the initial regular permit is issued in the phase-1 proportionally adjusted amount; (2) if an applicant does not qualify for an irrigator or historical average minimum, and a phase-2 proportional adjustment is performed, then the initial regular permit is issued in the phase-2 proportionally adjusted amount; (3) if an applicant does qualify for an irrigator or historical average minimum, and no phase-2 proportional adjustment is performed, and the phase-1 proportionally adjusted amount is greater than the irrigator or historical average minimum, as appropriate, then the initial regular permit is issued in the phase-1 proportionally adjusted amount; (4) if an applicant does qualify for an irrigator or historical average minimum, and no phase-2 proportional adjustment is performed, and the phase-1 proportionally adjusted amount is less than the irrigator or historical average minimum, as appropriate, then the initial regular permit is issued, after step-up, in the amount of the irrigator or historical average minimum; (5) if an applicant does qualify for an irrigator or historical average minimum, a phase-2 proportional adjustment is performed, and the phase-2 proportionally adjusted amount is greater than the irrigator or historical average minimum, as appropriate, then the initial regular permit is issued in the phase-2 proportionally adjusted amount; and (6) if an applicant does qualify for an irrigator or historical average minimum, a phase-2 proportional adjustment is performed, and the phase-2 proportionally adjusted amount is less than the irrigator or historical average minimum, as appropriate, then the initial regular permit is issued in the phase-2 proportionally adjusted amount and the applicant is compensated by the Authority for the fair market value of the difference between the applicant's PA-2 amount and minimum. Section 711.176 sets forth these methods by which initial regular permit amounts will be determined. In cases such as category (6), above, compensation will be provided at the fair market value as defined in § 11.0275 of the Texas Water Code. Section 711.176 is intended to normalize allocations when the 450,000 acre-feet cap is not exceeded and in several contingency options that derive from circumstances in which the aggregate cap is exceeded. The section is needed because, based upon the Authority's extensive review of the initial regular permit applications on file, it appears entirely possible that the aggregate of the maximum historical uses will exceed the cap and it even appears likely that the aggregate of all minimums will exceed the cap. In order to meet its statutory duty to achieve the cap, the Authority must implement measures to adjust permit amounts. In the event that withdrawals derived under Phase-2 calculations cannot be authorized, compensation is provided for.

Section 1.14(b) of the Act prohibits the Authority from issuing initial regular permits in an aggregate amount that exceeds 450,000 acre-feet per annum. The basic procedure provided by the Act to ensure that the aggregate total does not exceed the "cap" is the proportional adjustment process contained in § 1.16(e) of the Act. The Authority currently estimates that after "stepping-up" the proportionally adjusted permits to their appropriate minimums, the aggregate of the irrigator and historical average minimums will exceed the "cap." Accordingly, the Authority will be required to "reduce withdrawals" and, under § 129(a)(1) of the Act, those withdrawal reduction costs are to be borne by existing users. One manner in which the Authority may "reduce withdrawals" to the 450,000 acre-foot "cap" is to enter into agreements with applicants that they may abandon or waive all or part of their application for an agreed to compensation. By entering into such agreements at the application phase (pre-permit issuance) rather than waiting until initial regular permits have been issued (which the Authority cannot do if the "cap" is going to be exceeded) the Authority will be able to affect the final aggregate groundwater withdrawal amount in the initial regular permits. Section 711.180 provides the procedural mechanism for this "withdrawal reduction" by the application waiver approach to be realized.

Subchapter I

The Act requires the Authority to impose and enforce a number of restrictions, limitations and other requirements upon the use of water from the aquifer. Sections 711.220-711.234, Subchapter I of the Chapter 711 rules, impose a number of prohibitions on aquifer use, including: requiring water withdrawn from the aquifer to be used within the Authority's boundaries; limiting withdrawals from new wells; requiring permits for most withdrawals and well construction; requiring registration of exempt wells; requiring compliance with the Act, the Authority's rules and the terms of Authority permits; and prohibiting waste or pollution of the aquifer.

Section 711.220(a) generally requires that groundwater withdrawn from the aquifer be used within the Authority's boundaries. This rule implements § 1.34(a) of the Act which states that aquifer water "must be used within the boundaries of the Authority." Section 711.220(b) states that, for water processed into or used to produce a commodity, the place of use is the plant site where the commodity is produced. This portion of the rule is not found in the Act, however, its creation is a necessary extension of subsection (a). Realizing aquifer water will, at times, be used in the production of commodities, the Authority has established a uniform rule that designates the site of production as the place where aquifer water is used. It would not be practical to use the destination point of commodities as the place of use; such a concept would make it impossible for producers to market their products beyond the Authority's boundaries.

Section 711.222 prohibits aquifer withdrawals from new wells unless the withdrawals are from an exempt well, a permitted well, or a well identified as a point of withdrawal in a transfer approved by the Authority. This rule is based on § 1.15 of the Act which gives the Authority the power to manage withdrawals from the aquifer and all withdrawal points from the aquifer. Section 1.15 of the Act further states that unless exemptions apply, a person "may not withdraw water from the aquifer . . . without obtaining a permit from the Authority." The water management programs implemented by the Authority in furtherance of the Act are based, in part, on the Authority's ability to issue permits to control and manage aquifer withdrawals. Without this ability, the Authority would not be able to carry out the statutory mandates set out in the Act, such as the maximum permitted withdrawal levels. Section 711.222 will ensure that new well withdrawals are in compliance with the limitations imposed by the Act.

Section 711.224(a) generally prohibits groundwater withdrawals without a permit issued by the Authority unless otherwise excepted. This rule is derived directly from § 1.35(a) of the Act which states that a person "may not withdraw water from the aquifer except as authorized by a permit issued by the Authority or by this article." While § 1.35(a) of the Act indicates water may be withdrawn from the aquifer without a permit if authorized by other provisions in the article, the Authority has included specific references in § 711.224(a) to those provisions of the Act providing exceptions to the permitting requirements. Therefore, the Authority has included in § 711.224(a) the exceptions from the permitting requirement provided in §§ 1.15(b), 1.16(c), 1.17(a) and 1.33(a) and (c) of the Act and § 711.14 of this title (relating to Withdrawals Not Requiring a Groundwater Withdrawal Permit).

Section 711.224(b) prohibits new well construction unless authorized pursuant to a well construction permit. This provision is based on § 1.15(a) and (b) of the Act which authorizes the Authority to manage all withdrawals from the aquifer and states that a person may not "begin construction of a well . . . for withdrawal of water from the aquifer without obtaining a permit from the Authority." This section is further based on §36.119(a) of the Texas Water Code which decrees that drilling a well without a required permit is illegal. Under § 1.08(a) of the Act, chapter 52 of the Texas Water Code is applicable to the Authority to the extent that it does not conflict with the Act. Chapter 52 has since been repealed and recodified as chapter 36, Texas Water Code, which is now applicable to the Authority. See Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 933, sec. 2, 6, 1995 Texas General Laws 4673. Section 711.224(c) prohibits the operation of a well at a higher rate of production than authorized in a withdrawal permit. The foundation for this requirement is also located in § 36.119(a) of the Texas Water Code which decrees that operating a well at a higher rate of production than the rate approved for the well is illegal. Additional grounds for § 711.224(c) are found in § 1.15(d) of the Act which requires each permit "specify the maximum rate and total volume of water" that may be withdrawn. Implementing the concepts of § 36.119(a) of the Water Code and § 1.15 of the Act into § 711.224 will prevent unauthorized withdrawals or levels of withdrawals from permitted wells as well as the construction of unauthorized wells.

Section 711.226 prohibits operation of an exempt well unless the well has been registered with the Authority. This rule implements § 1.33(b) of the Act which states that exempt wells must register with the Authority. By conditioning operation of an exempt well on the filing of the statutorily mandated registration, the rule will ensure compliance with the Act.

Section 711.228 prohibits violations of the Act, the Authority's rules, or the terms or conditions of a permit. This rule is derived from § 1.35(b) of the Act which states that a person "may not violate the terms or conditions of the permit." It is also derived from § 1.35(e) of the Act which states that a person "may not violate this article or a rule of the Authority adopted under this article." The adoption of this rule will enable the Authority to use the enforcement powers authorized by § 1.36 of the Act which states the Authority "may enter orders to enforce the terms and conditions of permits, orders, or rules issued or adopted under this article." The purpose of § 711.228 is to deter violations. However, in the event a provision of the Act, a rule adopted by the Authority, or the terms and conditions or a permit, are violated, the Authority will have the ability to take enforcement action.

Section 711.230 prohibits the waste of groundwater within or withdrawn from the aquifer. This rule is derived from § 1.35(c) of the Act which expressly prohibits the waste of aquifer water. The establishment of a rule prohibiting waste is further supported by § 1.08(a) of the Act which states that the Authority "has all of the powers, rights, and privileges necessary . . . to prevent the waste or pollution of water in the aquifer." The adoption of this rule will enable the Authority to use the enforcement powers authorized by § 1.36 of the Act which states the Authority "may enter orders to enforce the terms and conditions of permits, orders, or rules issued or adopted under this article." The purpose of § 711.230 is to deter violations. However, in the event aquifer water is wasted in violation of this rule, the Authority will have the ability to take enforcement action to stop the waste.

Section 711.232 prohibits the pollution of the aquifer. This provision is based directly on § 1.35(d) of the Act which states that a "person may not pollute or contribute to the pollution of the aquifer." The establishment of a rule prohibiting pollution is further supported by § 1.08(a) of the Act which states that the Authority "has all of the powers, right, and privileges necessary . . . to prevent the waste or pollution of water in the aquifer." The adoption of this rule will enable the Authority to use the enforcement powers authorized by § 1.36 of the Act which states the Authority "may enter orders to enforce the terms and conditions of permits, orders, or rules issued or adopted under this article." The purpose of § 711.232 is to deter pollution of the aquifer. However, in the event the aquifer is polluted in violation of this rule, the Authority will have the ability to take enforcement action to stop such action.

Section 711.234 identifies various practices declared to be nuisances. These practices are: 1) wasting of aquifer water; 2) operation of a well at a higher rate of production than the rate approved for the well; and 3) pollution of the aquifer. This section is based, in part, on § 36.119(a) of the Texas Water Code. Under § 1.08(a) of the Act, chapter 52 of the Texas Water Code is applicable to the Authority to the extent that it does not conflict with the Act. Chapter 52 has since been repealed and recodified as chapter 36, Texas Water Code, which is now applicable to the Authority. See Act of May 29, 1995, 74th Legislature, Regular Session, Chapter 933, sec. 2, 6, 1995 Texas General Laws 4673. Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that operating a well at a higher rate of production than the rate approved for the well is declared to be a nuisance. This concept is incorporated into § 711.234(2). Section 711.234(1) is based on § 11.092, Texas Water Code, which states the wasteful use of water is a public nuisance. While this particular rule applies to surface water, the Authority has determined it should be applied to aquifer groundwater in an effort to protect those who use the water. Finally, the Authority includes pollution or the contribution to the pollution of the aquifer as a nuisance in § 711.234(3). This classification is supported by Texas common law which defines a public nuisance as a condition that amounts to an unreasonable interference with a right common to the general public. Jamail v. Stoneledge Condo. Owners Ass'n, 970 S.W.2d 673 (Tex. App. - Austin 1998, no writ). Pollution of the aquifer water would interfere with the rights of other aquifer users to enjoy clean, unadulterated water.

By declaring waste, excessive production, and pollution of aquifer water as nuisances, § 711.234 is intended to prevent the occurrence of these practices which could endanger or cause harm to lawful users of the aquifer.

III. REGULATORY IMPACT ANALYSIS OF MAJOR ENVIRONMENTAL RULES.

Section 2001.0225 of the Texas Government Code requires an agency to perform, under certain circumstances, a regulatory analysis of major environmental rules ("RIAMER"). There are two primary components that must be met before a RIAMER is required. First, no RIAMER need be prepared if the rules in question are not "major environmental rules" or "MERs." Second, even if the rules are MERs, no RIAMER need be prepared if adoption of the MERs would not result in any one of the following criteria listed in § 2001.0225(a)(1)-(4):

1. the MER would "exceed" a standard set by federal law, unless the MER is specifically required by state law;

2. the MER would "exceed" an express requirement of state law, unless the MER is specifically required by federal law;

3. the MER would "exceed" a requirement of a delegation agreement or contract between the state and an agency or representative of the federal governmental to implement a state and federal program; or

4. the MER is adopted solely under the "general powers" of the agency instead of under a specific state law.

The following analysis examines whether a RIAMER is required for any of the rules on a subchapter by subchapter basis.

Analysis of Subchapter A

The Authority has determined that none of the rules in Subchapter A of 31 TAC - § 711.1 (the "Subchapter A Rules") are "major environmental rules" as that term is defined by §2001.0225(g)(3) of the Texas Government Code. The Subchapter A rules set forth the definitions that will apply to all rules issued by the Authority in Chapter 711. These rules have been written to provide uniform definitions for words and phrases that are expected to be used consistently throughout Chapter 711. They are intended to provide useful "short-hand" to reduce the amount of cumbersome regulatory language necessary in other Authority rules, thus allowing for a more efficient understanding and operation of other rules of the Authority. The definitions have no regulatory import outside of their incorporation in substantive rules that may be found elsewhere in Chapter 711. Because they do not have the specific intent to protect the environment or reduce risks to human health from environmental exposure, they are not MERs.

Further, even if any of the Subchapter A rules were MERs, no RIAMER need be prepared for those rules because none of the rules in Subchapter A meet any of the criteria listed in APA § 2001.0225(a)(1)-(4). First, the rules do not exceed a standard set by federal law. The only reasonably related federal law establishes the Sole Source Aquifer Program implemented by the EPA for portions of the Edwards Aquifer, which applies only to federally-funded projects conducted on the aquifer. Under that program, no federal financial assistance may be made to projects that the EPA determines may contaminate the Edwards Aquifer so as to create a significant hazard to public health. There is no federal law that specifically requires definitions such as those contained in the Subchapter A rules. Therefore, the Subchapter A rules do not exceed a standard set by federal law.

Second, the Subchapter A rules do not exceed an express requirement of state law. Instead, the rules are designed to carry out the Authority's statutory responsibility to: manage, conserve, preserve and protect the aquifer, adopt rules to carry out its powers and duties under the Act, to regulate permits, manage withdrawals and points of withdrawals from the aquifer, require various types of permits for certain withdrawals, allow for interim authorization withdrawals prior to permit issuance, impose various conditions and restrictions on aquifer use, require that aquifer use be limited to beneficial uses, prohibit waste of aquifer water, and regulate transfers of aquifer rights (pursuant to, inter alia, §§ 1.03(4), (10) and (21), 1.08(a), 1.11(a) and (b), 1.14, 1.15, 1.16, 1.17 and 1.34 of the Act). The rules are designed to comply with these express requirements of state law and not exceed them. There are no other applicable "express requirements of state law" which are exceeded by these rules.

Third, the Subchapter A rules do not exceed a requirement of a delegation agreement or contract between the State of Texas and an agency or representative of the federal government to implement a state and federal program. The subject matter of the rules is not covered by any delegation agreement or contract between the state and an agency or representative of the federal government to implement a state and federal program.

Fourth, the Subchapter A rules would not be adopted solely under the general powers of the Authority instead of under a specific state law. While these rules are adopted in part under the Authority's general powers, they are also adopted under the Act. In particular, the rules are adopted pursuant to, inter alia, §§ 1.03(4), (10) and (21), 1.08(a), 1.11(a) and (b), 1.14, 1.15, 1.16, 1.17 and 1.34 of the Act, which require the Authority to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits, manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals; allow for interim authorization withdrawals prior to permit issuance; impose various conditions and restrictions on aquifer use; require that aquifer use be limited to beneficial uses; prohibit waste of aquifer water; and regulate transfers of aquifer rights. For these reasons, it is not necessary to perform a RIAMER on the Subchapter A rules.

Analysis of Subchapter B Rules

With respect to Subchapter B of 31 TAC, §§ 711.10 - 711.14 (the "Subchapter B Rules"), the Authority has determined that only § 711.12 is a "major environmental rule" as that term is defined by §1.0225(g)(3) of the Texas Government Code because it has the specific intent to protect the environment. The Subchapter B rules generally set forth the activities for which a permit from the Authority is required. The other Subchapter B rules do not have the specific intent to protect the environment or reduce risks to human health from environmental exposure and are, therefore, not MERs.

Further, no RIAMER need be prepared for any of the Subchapter B rules because none of the rules in Subchapter B meet any of the criteria listed in APA § 2001.0225(a)(1)-(4). First, the rules do not exceed a standard set by federal law. The only reasonably related federal law establishes the Sole Source Aquifer Program implemented by the EPA for portions of the Edwards Aquifer, which applies only to federally-funded projects conducted on the aquifer. Under that program, no federal financial assistance may be made to projects that the EPA determines may contaminate the Edwards Aquifer so as to create a significant hazard to public health. There is no federal law that specifically requires permitting for withdrawals of Edwards Aquifer groundwater, or for well construction or related work. Therefore, the Subchapter B rules do not exceed a standard set by federal law. Moreover, even if the rules did exceed a standard set by federal law, the rules are specifically required by the Act, a state law which requires the Authority to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits, manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals and well construction; and protect the quality of the water within the aquifer (pursuant to, inter alia, §§ 1.08(a), 1.11(a), (b) and (d), 1.14 and 1.15 of the Act).

Second, the Subchapter B rules do not exceed an express requirement of state law. Instead, the rules are designed to carry out the Authority's statutory responsibility to: manage, conserve, preserve and protect the aquifer, adopt rules to carry out its powers and duties under the Act, to regulate permits, manage withdrawals and points of withdrawals from the aquifer, require various types of permits for certain withdrawals and well construction, and protect the quality of the water within the aquifer (pursuant to, inter alia §§ 1.08(a), 1.11(a), (b) and (d), 1.14 and 1.15 of the Act). The rules are designed to comply with these express requirements of state law and not exceed them. Other than the Act, there are no other "express requirements of state law" which could be exceeded by these rules.

Third, the Subchapter B rules do not exceed a requirement of a delegation agreement or contract between the State of Texas and an agency or representative of the federal government to implement a state and federal program. The subject matter of the rules is not covered by any delegation agreement or contract between the state and an agency or representative of the federal government to implement a state and federal program.

Fourth, the Subchapter B rules would not be adopted solely under the general powers of the Authority instead of under a specific state law. While these rules are adopted in part under the Authority's general powers, they are also adopted under the Act, a specific state law regarding the Edwards Aquifer. In particular, the rules are adopted pursuant to, inter alia, §§ 1.08(a), 1.11(a), (b) and (d), 1.14 and 1.15 of the Act, which require the Authority to, among others: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits, manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals and well construction; and protect the quality of the water within the aquifer. For these reasons, it is not necessary to perform a RIAMER on the Subchapter B rules.

Analysis of Subchapter E

The Subchapter E rules of 31 TAC, §§ 711.90-711.118 (the "Subchapter E Rules") would implement the Authority's permitting program by essentially setting forth: the categories of permits issued by the Authority, the conditions governing how and when such permits could be issued, the quantity of and conditions under which water could be withdrawn or wells constructed pursuant to such permits, the duration of such permits, the required contents of permit applications, and the rights and limitations associated with being the holder of such permits. Because these rules impose limits on the legal authority to withdraw groundwater which did not exist under the common law, they would tend to have an environmental protection aspect. Therefore, Subchapter E rules are probably MERs because they have the specific intent to "protect the environment."

However, no RIAMER need be prepared for any of the Subchapter E rules because none of them meet any of the criteria listed in APA § 2001.0225(a)(1)-(4). First, the rules do not exceed a standard set by federal law. The only reasonably related federal law establishes the Sole Source Aquifer Program implemented by the EPA for portions of the Edwards Aquifer, which applies only to federally-funded projects conducted on the aquifer. There is no federal law that specifically requires permitting for withdrawals of Edwards Aquifer groundwater or for construction of Edwards Aquifer wells. Therefore, the Subchapter E rules do not exceed a standard set by federal law. Moreover, even if the rules did exceed a standard set by federal law, the rules are specifically required by state law which requires the Authority to manage, conserve, preserve and protect the aquifer, adopt rules to carry out its powers and duties under the Act, to regulate permits, manage withdrawals and points of withdrawals from the aquifer, require various types of permits for certain withdrawals and well construction, and specify withdrawal amounts pursuant to those permits (pursuant to, inter alia, §§ 1.03(9), (11), (12), (13) and (14), 1.08(a), 1.11(a) and (b), 1.14, 1.15, 1.16, 1.18, 1.19, 1.20 and 1.33(a), (b) and (c) of the Act).

Second, the Subchapter E rules do not exceed an express requirement of state law. Instead, the rules are designed to carry out the Authority's statutory responsibility to manage, conserve, preserve and protect the aquifer, adopt rules to carry out its powers and duties under the Act, to regulate permits, manage withdrawals and points of withdrawals from the aquifer, require various types of permits for certain withdrawals and well construction, and specify withdrawal amounts pursuant to those permits (pursuant to, inter alia, §§ 1.03(9), (11), (12), (13) and (14), 1.08(a), 1.11(a) and (b), 1.14, 1.15, 1.16, 1.18, 1.19, 1.20 and 1.33(a), (b) and (c) of the Act). The rules are designed to comply with these express requirements of state law and not exceed them. Other than the Act, there are no other "express requirements of state law" which are applicable to these rules or which could be exceeded by these rules.

Third, the Subchapter E rules do not exceed a requirement of a delegation agreement or contract between the State of Texas and an agency or representative of the federal government to implement a state and federal program. The subject matter of the rules is not covered by any delegation agreement or contract between the state and an agency or representative of the federal government to implement a state and federal program.

Fourth, the Subchapter E rules would not be adopted solely under the general powers of the Authority instead of under a specific state law. While these rules are adopted in part under the Authority's general powers, they are also adopted under the Act, a specific state law regarding the Edwards Aquifer. In particular, the rules are adopted pursuant to, inter alia §§ 1.03(9), (11), (12), (13) and (14), 1.08(a), 1.11(a) and (b), 1.14, 1.15, 1.16, 1.18, 1.19, 1.20 and 1.33(a), (b) and (c) of the Act, which require the Authority to manage, conserve, preserve and protect the aquifer, adopt rules to carry out its powers and duties under the Act, to regulate permits, manage withdrawals and points of withdrawals from the aquifer, require various types of permits for certain withdrawals and well construction, and specify withdrawal amounts pursuant to those permits. For these reasons, it is not necessary to perform a RIAMER on the Subchapter E rules.

Analysis of Subchapter F

The Act requires the Authority to implement a permitting system. At the same time, the Act imposes a number of restrictions, limitations and other requirements upon the withdrawal of water from the Edwards Aquifer. The Subchapter F rules of 31 TAC, §§ 711.130-711.134 (the "Subchapter F Rules") would harmonize these provisions of the Act by clarifying that holders of groundwater withdrawal permits must comply with a number of conditions, including: avoiding actions that adversely affect water quality, or threatened or endangered aquifer-dependent species; complying with other Authority rules, including rules designed to protect water quality, conserve water, maximize beneficial use of water, protect aquatic and wildlife habitat and threatened or endangered species, and protect instream uses, bays and estuaries; and complying with the Act. Because these rules impose limits on the legal authority to withdraw groundwater which did not exist under the common law, they would tend to have an environmental protection aspect. Therefore, the Subchapter F rules are probably MERs because they have the specific intent to "protect the environment."

However, no RIAMER need be prepared for any of the Subchapter F rules because none of them meet any of the criteria listed in APA § 2001.0225(a)(1)-(4). First, the rules do not exceed a standard set by federal law. The only reasonably related federal law establishes the Sole Source Aquifer Program implemented by the EPA for portions of the Edwards Aquifer, which applies only to federally-funded projects conducted on the aquifer. There is no federal law that specifically requires permitting for withdrawals of Edwards Aquifer groundwater or for construction of Edwards Aquifer wells, or which imposes conditions upon such permits akin to those found in the Subchapter F rules. Therefore, the Subchapter F rules do not exceed a standard set by federal law. Moreover, even if the rules did exceed a standard set by federal law, the rules are specifically required by the Act, a state law which requires the Authority to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits; manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals and well construction; develop and implement a demand management plan; close abandoned, wasteful or dangerous wells; regulate well construction, operation, maintenance and closure; ensure adequate springflows; protect threatened and endangered species; provide notice to permit holders of the limitations provided by the Act; retire permits to reduce withdrawals; implement water conservation and reuse measures; acquire permitted rights for aquifer management purposes; require water conservation and reuse plans; implement a conservation management plan, a demand management plan, and a critical period management plan; limit transport of water out of Uvalde and Medina Counties; impose fees; regulate withdrawals of water from the Guadalupe River in lieu of aquifer withdrawals; require meters on aquifer wells; require water use reports; and regulate transfers of aquifer rights (pursuant to, inter alia, §§ 1.07, 1.08(a), 1.10(i)(1) and (2), 1.11(a), (b), (d)(8), (d)(10) and (d) (11), 1.14, 1.15, 1.16, 1.17, 1.21, 1.22, 1.23(a), 1.25, 1.26, 1.28(b), 1.29, 1.30, 1.31, 1.32, 1.34, 1.35, and 1.36 of the Act).

Second, the Subchapter F rules do not exceed an express requirement of state law. Instead, the rules are designed to carry out the Authority's statutory responsibility to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits; manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals and well construction; develop and implement a demand management plan; close abandoned, wasteful or dangerous wells; regulate well construction, operation, maintenance and closure; ensure adequate springflows; protect threatened and endangered species; provide notice to permit holders of the limitations provided by the Act; retire permits to reduce withdrawals; implement water conservation and reuse measures; acquire permitted rights for aquifer management purposes; require water conservation and reuse plans; implement a conservation management plan; a demand management plan, and a critical period management plan; limit transport of water out of Uvalde and Medina Counties; impose fees; regulate withdrawals of water from the Guadalupe River in lieu of aquifer withdrawals; require meters on aquifer wells; require water use reports; and regulate transfers of aquifer rights (pursuant to, inter alia, §§ 1.07, 1.08(a), 1.10(i)(1) and (2), 1.11(a), (b), (d)(8), (d)(10), and (d)(11), 1.14, 1.15, 1.16, 1.17, 1.21, 1.22, 1.23(a), 1.25, 1.26, 1.28(b), 1.29, 1.30, 1.31, 1.32, 1.34, 1.35, and 1.36 of the Act). The rules are designed to comply with these express requirements of state law and not exceed them. There are no other "express requirements of state law" which are applicable to these rules or which could be exceeded by these rules.

Third, the Subchapter F rules do not exceed a requirement of a delegation agreement or contract between the State of Texas and an agency or representative of the federal government to implement a state and federal program. The subject matter of the rules is not covered by any delegation agreement or contract between the state and an agency or representative of the federal government to implement a state and federal program.

Fourth, the Subchapter F rules would not be adopted solely under the general powers of the Authority instead of under a specific state law. While these rules are adopted in part under the Authority's general powers, they are also adopted under the Act, a specific state law regarding the Edwards Aquifer. In particular, the rules are adopted pursuant to, inter alia, §§ 1.07, 1.08(a), 1.10(i)(1) and (2), 1.11(a), (b), (d)(8), (d)(10) and (d)(11), 1.14, 1.15, 1.16, 1.17, 1.21, 1.22, 1.23(a), 1.25, 1.26, 1.28(b), 1.29, 1.30, 1.31, 1.32, 1.34, 1.35, and 1.36 of the Act, which require the Authority to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits; manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals and well construction; develop and implement a demand management plan; close abandoned, wasteful or dangerous wells; regulate well construction, operation, maintenance and closure; ensure adequate springflows; protect threatened and endangered species; provide notice to permit holders of the limitations provided by the Act; retire permits to reduce withdrawals; implement water conservation and reuse measures; acquire permitted rights for aquifer management purposes; require water conservation and reuse plans; implement a conservation management plan, a demand management plan, and a critical period management plan; limit transport of water out of Uvalde and Medina Counties; impose fees; regulate withdrawals of water from the Guadalupe River in lieu of aquifer withdrawals; require meters on aquifer wells; require water use reports; and regulate transfers of aquifer rights. For these reasons, it is not necessary to perform a RIAMER on the Subchapter F rules.

Analysis of Subchapter G

The Act requires the Authority to implement a permitting system. The Act also imposes two "caps" which limit the aggregate amount of certain permitted withdrawals which may be issued by the Authority. Specifically, the Act mandates that, initially, total permitted withdrawals may not exceed 450,000 acre-feet per year and, after January 1, 2008, total permitted withdrawals may not exceed 400,000 acre-feet per year. In the absence of these "caps," total permitted withdrawals might exceed the cap amounts. Therefore, the Act requires the Authority to "proportionally adjust" permit amounts to reach the 450,000 acre-feet cap, and implement "equal percentage reductions" in order to reach the 400,000 acre-feet cap. The Act also imposes several permit "minimums" applicable to certain initial regular permit holders. The Subchapter G rules of 31 TAC, §§ 711.160-711.180 (the "Subchapter G Rules") would implement these provisions of the Act by establishing the amount of groundwater available for permitting, explaining which types of permits are subject to the caps, implementing a method of calculating the permit minimums, and setting out the procedures for carrying out "proportional adjustment" and "equal percentage reductions."

Because the Subchapter G rules implement caps on the aggregate amounts of groundwater withdrawal permits, and provide for proportional adjustment, and equal percentage reductions of permits, this subchapter would tend to have an environmental protection aspect. Therefore, the Subchapter G rules are probably MERs because they have the specific intent to "protect the environment."

However, no RIAMER need be prepared for any of the Subchapter G rules because none of them meet any of the criteria listed in APA § 2001.0225(a)(1)-(4). First, the rules do not exceed a standard set by federal law. The only reasonably related federal law establishes the Sole Source Aquifer Program implemented by the EPA for portions of the Edwards Aquifer, which applies only to federally-funded projects conducted on the aquifer. There is no federal law that specifically requires permitting for withdrawals of Edwards Aquifer groundwater or limits the maximum amount which can be withdrawn pursuant to those permits. Therefore, the Subchapter G rules do not exceed a standard set by federal law. Moreover, even if the rules did exceed a standard set by federal law, the rules are specifically required by the Act, a state law which requires the Authority to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits; manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals; limit permitted withdrawals to achieve the caps and protect the aquifer; proportionately adjust, if necessary, to meet the 450,000 acre-feet cap; implement the permit minimums; and conduct equal percentage reduction, if necessary, to meet the 400,000 acre-feet cap (pursuant to, inter alia, §§ 1.08(a), 1.11(a) and (b), 1.14, 1.15, 1.16, 1.18, 1.19, 1.20, 1.21, and 1.44 of the Act).

Second, the Subchapter G rules do not exceed an express requirement of state law. Instead, the rules are designed to carry out the Authority's statutory responsibility to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits; manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals; limit permitted withdrawals to achieve the caps and protect the aquifer; proportionately adjust, if necessary, to meet the 450,000 acre-feet cap; implement the permit minimums; and conduct equal percentage reduction, if necessary, to meet the 400,000 acre-feet cap (pursuant to, inter alia, §§ 1.08(a), 1.11(a) and (b), 1.14, 1.15, 1.16, 1.18, 1.19, 1.20, 1.21, and 1.44 of the Act). The rules are designed to comply with these express requirements of state law and not exceed them. There are no other "express requirements of state law" which could be exceeded by these rules.

Third, the Subchapter G rules do not exceed a requirement of a delegation agreement or contract between the State of Texas and an agency or representative of the federal government to implement a state and federal program. The subject matter of the rules is not covered by any delegation agreement or contract between the state and an agency or representative of the federal government to implement a state and federal program.

Fourth, the Subchapter G rules would not be adopted solely under the general powers of the Authority instead of under a specific state law. While these rules are adopted in part under the Authority's general powers, they are also adopted under the Act, a specific state law regarding the Edwards Aquifer. In particular, the rules are adopted pursuant to, inter alia, §§ 1.08(a), 1.11(a) and (b), 1.14, 1.15, 1.16, 1.18, 1.19, 1.20, 1.21, and 1.44 of the Act, which require the Authority to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits; manage withdrawals and points of withdrawals from the aquifer; require various types of permits for certain withdrawals; limit permitted withdrawals to achieve the caps and protect the aquifer; proportionately adjust, if necessary, to meet the 450,000 acre-feet cap; implement the permit minimums; and conduct equal percentage reduction, if necessary, to meet the 400,000 acre-feet cap. For these reasons, it is not necessary to perform a RIAMER on the Subchapter G rules.

Analysis of Subchapter I

The Act requires the Authority to impose and enforce a number of restrictions, limitations and other requirements upon the use of water from the aquifer. The Subchapter I rules of 31 TAC,- §§ 711.220-711.234 (the "Subchapter I Rules") impose a number of prohibitions on aquifer use, including: requiring water withdrawn from the aquifer to be used within the Authority's boundaries; limiting withdrawals from new wells; requiring permits for most withdrawals and well construction; requiring registration of exempt wells; requiring compliance with the Act, the Authority's rules and the terms of Authority permits; and prohibiting waste or pollution of the aquifer.

The Authority has determined that §§711.222, 711.224, 711.230, and 711.232 have the specific intent to protect the environment and are, therefore, probably MERs. The other Subchapter I rules do not have the specific intent to protect the environment or reduce risks to human health from environmental exposure and are, therefore, not MERs.

However, no RIAMER need be prepared for any of the Subchapter I rules because none of them meet any of the criteria listed in APA § 2001.0225(a)(1)-(4). First, the rules in Subchapter I do not exceed a standard set by federal law. The only reasonably related federal law establishes the Sole Source Aquifer Program implemented by the EPA. There is no federal law that specifically imposes restrictions akin to those in the Subchapter I rules. Therefore, the Subchapter I rules do not exceed a standard set by federal law. Moreover, even if the rules did exceed a standard set by federal law, the rules are specifically required by the Act, a state law which requires the Authority to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits, manage withdrawals and points of withdrawals from the aquifer; limit withdrawals from new wells; prohibit transfers of water outside the Authority's boundaries; require compliance with permits, the Act, and Authority rules; and prohibit waste and pollution of the aquifer (pursuant to, inter alia 1.08(a), 1.11(a) and (b), 1.14(e), 1.15(a), 1.34(a), and 1.35 of the Act).

Second, the Subchapter I rules do not exceed an express requirement of state law. Instead, the rules are designed to carry out the Authority's statutory responsibility to: manage, conserve, preserve and protect the aquifer, adopt rules to carry out its powers and duties under the Act, regulate permits; manage withdrawals and points of withdrawals from the aquifer, limit withdrawals from new wells, prohibit transfers of water outside the Authority's boundaries, require compliance with permits, the Act, and Authority rules, and prohibit waste and pollution of the aquifer (pursuant to, inter alia §§ 1.08(a), 1.11(a) and (b), 1.14(e), 1.15(a), 1.34(a), and 1.35 of the Act). The rules are designed to comply with these express requirements of state law and not exceed them. Other than the Act, there are no other "express requirements of state law" which could be exceeded by these rules.

Third, the Subchapter I rules do not exceed a requirement of a delegation agreement or contract between the State of Texas and an agency or representative of the federal government to implement a state and federal program. The subject matter of the rules is not covered by any delegation agreement or contract between the state and an agency or representative of the federal government to implement a state and federal program.

Fourth, the Subchapter I rules would not be adopted solely under the general powers of the Authority instead of under a specific state law. While these rules are adopted in part under the Authority's general powers, they are also adopted under the Act, a specific state law regarding the Edwards Aquifer. In particular, the rules are adopted pursuant to, inter alia, §§ 1.08(a), 1.11(a) and (b), 1.14(e), 1.15(a), 1.34(a), and 1.35 of the Act, which require the Authority to, among other things: manage, conserve, preserve and protect the aquifer; adopt rules to carry out its powers and duties under the Act; regulate permits; manage withdrawals and points of withdrawals from the aquifer; limit withdrawals from new wells; prohibit transfers of water outside the Authority's boundaries; require compliance with permits, the Act, and Authority rules; and prohibit waste and pollution of the aquifer. For these reasons, it is not necessary to perform a RIAMER on the Subchapter I rules.

IV. TEXAS PRIVATE REAL PROPERTY RIGHTS PRESERVATION ACT.

Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act" ("TPRPRA"), requires governmental entities, under certain circumstances, to prepare a TIA in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the adoption of these rules.

First, the Authority has made a "categorical determination" that these Chapter 711 rules do not affect vested property rights and, as such, adoption of these rules is not an action that "may result in a taking." The rules at issue here implement a permitting program for the withdrawal of water from the Edwards Aquifer. The Act requires the Authority to implement a permitting system whereby existing users and other potential users of aquifer water may apply for and receive permits issued by the Authority allowing for the withdrawal of groundwater from the aquifer. Other types of permits are also required by the Act for well construction and related work. Certain other withdrawals are exempted by the Act from permitting requirements. The Act also specifies an interim authorization period prior to the issuance by the Authority of final permits during which certain existing users of the aquifer may continue to make withdrawals. The Act imposes a number of restrictions upon the use of the aquifer during the interim authorization period as well as after permits are issued. It also places limits on the ability to transfer permitted or interim authorization rights. These rules are intended to effectuate these various components of the Act.

TPRPRPA makes it clear that a TIA need only be performed when the proposed governmental action is one that "may result in a taking." See id., §§ 2007.043(a), 2007.041(a), 2007.042(a). If an action is one that has no potential to result in a taking, then no TIA need be performed. Adoption of the rules at issue here is not an action that "may result in a taking" for two reasons. The rules cannot result in the taking of a vested private real property right. Traditional takings doctrine dictates that, in order to constitute a compensable taking, the property right alleged to have been "taken" must rise to the level of a vested right. Prior to the adoption of the Act, a landowner's right to pump groundwater underlying his or her property derived from the common law English Rule, also known as the "Rule of Capture." The rules implement a permitting structure which is admittedly at odds with the Rule of Capture. However, a landowner's common law Rule of Capture right does not rise to the level of a vested property right. Under the common law, water underlying a landowner's property may be reduced to possession by the pumping of another. In other words, a landowner has no right to exclude others from the water underlying his land. As such, the landowner's expectancy of water does not rise to the level of a vested property right which could be "taken" by the passage of these rules and passage of these rules is not an action that may result in a taking.

Additionally, with respect to Edwards Aquifer water, any common law rights a landowner may have had in the past have been effectively abolished by the Legislature within the boundaries of the EAA by the passage of the Act. Under the old common law, a landowner was essentially free to drill a well and pump as much water as he pleased for whatever use and location of use he pleased. Passage of the Act changed the rules within the boundaries of the EAA. The basis for the right to withdraw groundwater under the Act changed from being an incident of the ownership of land to one based on use during the statutorily-defined "historical period." See Act § 1.16. Excluding "exempt" wells, a landowner must now obtain a permit prior to drilling a well and making withdrawals, and this permit may be issued only if there is "water available for permitting" or if certain aquifer conditions are met. Id. §§ 1.14, 1.15, 1.16, 1.18 and 1.19. The rate and total quantity of withdrawals are subject to limitation. Id. § 1.15(d). Regulation under the Act leaves no room for the common law to operate within the boundaries of the EAA with respect to Edwards Aquifer groundwater. As a result, there are no vested property rights which could be taken by the passage of these rules and no TIA need be prepared.

Second, the Authority's action in adopting these rules is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from the Texas Private Real Property Rights Preservation Act under § 2007.003(b)(4) of the Texas Government Code. See §§ 1.03(4), (9) - (14), (21), 1.07, 1.08(a), 1.10(i)(1), (2), 1.11(a), (b), (d)(2), (8), (10), (11), (h), 1.14(a) - (f), (h), 1.15(a) - (d), 1.16(a), (c) - (h), 1.17(a) - (d), 1.18, 1.19, 1.20, 1.21, 1.22(a)(1)-(4), 1.23(a), 1.25, 1.26, 1.28(b), 1.29, 1.31, 1.32, 1.33, 1.34, 1.35, 1.36 of the Act, §§ 36.101(a), 36.111, 36.113, 36.1131, 36.119(a), 49.211(a), and 49.221 of the Texas Water Code, and § 2001.004(1) of the APA.

This conclusion is directly supported and controlled by the decision in Edwards Aquifer Authority v. Bragg, 21 S.W.3d. 375, (Tex. App. San Antonio 2000, pet. filed) ( "EAA v. Bragg" ). In that case, the Plaintiffs sued to invalidate a set of rules adopted by the Authority (the "prior permitting rules") which were substantially similar to these rules and which were designed, like these rules, to implement the Authority's permitting program. The Fourth Court of Appeals held that the Authority's adoption of its prior permitting rules was expressly mandated by the Act and was therefore excepted from the operation of TPRPRPA. The holding in that case controls here.

Third, it is the position of the Authority that all valid actions of the Authority are excluded from the Texas Private Real Property Rights Preservation Act under § 2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the proposal of these rules.

Fourth, it is the position of the Authority that the adoption of these rules constitutes an action taken by a governmental entity to "to prohibit or restrict a condition or use of private real private real property if the governmental entity proves that the condition or use constitutes a public or private nuisance as defined by background principles of nuisance and property law of this state." Texas Government Code Annotated, § 2007.003(b)(6).

Fifth, it is the position of the Authority that the adoption of these rules constitutes an action which: "(A) is taken in response to a real and substantial threat to public health and safety; (B) is designed to significantly advance the health and safety purpose; and (C) does not impose a greater burden than is necessary to achieve the health and safety purpose." Texas Government Code Annotated, § 2007.003(b)(13). Accordingly, for the reasons stated above, a TIA need not be performed in connection with the proposal of these rules.

V. SUMMARY OF PUBLIC COMMENTS.

Five public hearings were held on the Chapter 711 rules and other rules proposed by the Authority on: Wednesday, August 9, 2000, at 6:00 p.m. at the Conference Center of the Edwards Aquifer Authority, 1615 N. St. Mary's Street, San Antonio, Texas; Tuesday, August 15, 2000 at 6:00 p.m. at the New Braunfels Civic Center, 380 S. Seguin Avenue, New Braunfels, Texas; August 17, 2000 at 6:00 p.m. at St. Paul's Lutheran Church, 1303 Avenue M, Hondo, Texas; Tuesday, August 22, 2000 at 6:00 p.m. at the Sgt. Willie De Leon Civic Center, 300 E. Main Street in Uvalde, Texas; and Thursday August 24, 2000 at the San Marcos Activities Center, 501 E. Hopkins, San Marcos, Texas.

At those hearings, public comments were received on the proposed Chapter 711 rules. In addition, written comments were received from members of the public regarding Chapter 711. The public comment period closed on September 11, 2000. Oral and/or written comments were provided by Inland Ocean, Inc. ("Inland"); Fulbright & Jaworski, L.L.P. on behalf of Vulcan Materials Co. ("Vulcan"); San Antonio Water System ("SAWS"); Earl & Brown ("Earl & Brown"); Bickerstaff, Heath, Smiley, Pollan, Kever & McDaniel, L.L.P. on behalf of the Texas Farm Bureau ("TFB"); Vinson & Elkins, L.L.P. ("V&E"); Edward G. Vaughan ("Vaughan"); Howard M. Schirmer ("Schirmer"); Bexar County Water Control and Improvement District No. 10 ("BCWCID"); W. M. Menard, Sr. ("Menard"); Howard B. Shadrock ("Shadrock"); Robert Grossenbacher ("Grossenbacher"); Verstraeten Bros. Farms, Inc. ("VBI"); Denis Zinsmeyer ("Zinsmeyer"); Cemex USA Construction, Inc. ("Cemex"); Steve Kosub ("Kosub"); Kirk Patterson ("Patterson"); City Public Service of San Antonio, Texas ("CPS"); Bexar County Farm Bureau ("BCFB"); Medina County Farm Bureau ("MCFB"); Gilliam Ranch and Gregory and Cora Rothe ("Gilliam and Rothe"); Bragg Pecan Farms, Inc. ("Bragg"); Dietrich J. Gembler III ("Gembler"); Tracy King ("King"); JoLynn Bragg ("Ms. Bragg"); Maurice Rimkus ("Rimkus"); Lawrence Friesenhahn ("Friesenhahn"); Rodney Reagan ("Reagan"); Richard Frenzel ("Frenzel"); Thomas Taggert on behalf of the City of San Marcos ("Taggert"); Russell Johnson, on behalf of SAWS ("Johnson"); Herb Faseler ("Faseler"); Suzanne (last name unknown) on behalf of East Medina County Special Utility District ("Suzanne"); Paul Aelvoet ("Aelvoet"); John (last name unknown) ("John"); and the Texas Department of Agriculture ("TDA").

While the commenters generally did not express support or opposition to adoption of the rules as a whole, they did, as discussed more fully below, suggest changes to and/or opposition to certain portions of the rules.

Section 711.1(2)

Vulcan commented upon § 711.1(2), which, as proposed, states:

(2) Existing user-A person or the successor in interest of a such person, who, on June 1, 1993, owned an existing well from which groundwater from the aquifer had been withdrawn and placed to beneficial use during the historical period.

Vulcan maintains that one need not be the well owner in order to be an "existing user," and that lessees, assigns, and easement holders should be considered "existing users" thereby entitled to ownership of initial regular permits. Vulcan further contends that ownership interests of lessees, easement holders, and other assignees may be limited in time, place of use, or purpose. Accordingly, while Vulcan does not seek any amendment to the definition of "existing user" in § 711.1(2), it seeks to add a definition in § 711.1 which would define "owned an existing well" to include those who are lessees, assignees, easement holders or others with a legal right to withdraw water from an aquifer well.

Authority staff received the above-referenced comment and disagrees with it. The basis for this determination is as follows. The sine qua non of an "existing user" is ownership of the point(s) of withdrawal (i.e. well(s)) from which the withdrawals are made during the historical period. It is correct that the Court in Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 n.3 (Tex. 1996) stated as follows:

This holding does not necessarily limit the definition of 'user' to individuals owning land. Under some circumstances, an entity that does not own the land or the well may be considered a "user" if the entity had some right to withdraw water.

The Authority does not necessarily disagree with this dicta of the Court. However, this discussion is not applicable to the definition of "existing user." There is a distinction between an "existing user" and a mere "user" of the aquifer. First, the Court noted that the term "user" was not defined by the Act. The term "existing user" is defined by the Act. See § 1.03(10). Second, the Court was careful to preserve this distinction in the above-cited footnote. Third, the discussion of "user" in footnote 3 was in relation to the nature of the "use" of groundwater from the aquifer and whether the "use" runs with the landowner personally, or with the land, and did not concern the issue of whether a mere "user" who owned no well could qualify as an "existing user." The Court stated as follows:

The Act does not define 'user' and does not specify whether the use of water runs with the land. It is therefore unclear whether a 'user' includes prior and future owners of the land, or whether a 'user' is only the landowner in possession of the land at the time a permit is requested (i.e. when the declaration of historical use is on file on or before December 30, 1996).

A review of the Act also shows that an "existing user" must own the well upon which the declaration for historical use is based. For example, § 1.17(a) makes clear that interim authorization status only extends to persons owning non-exempt producing wells. Further, in numerous sections the Act makes reference to the owner of a well having certain rights and duties, thereby confirming that proper applicants for initial regular permits must be the well owners. See §§1.03(21)(E) and (F) (relating to the definition of waste); 1.16(b) (evidentiary obligation of owners of irrigation wells); 1.16(c) (owners of exempt wells not required to file declarations of historical use); 1.17(a) (owners of producing wells may continue to withdraw under interim authorization); and 1.31(a) (owners of nonexempt wells).

In light of the above discussion, Authority staff has not modified § 711.1(2) and has not added a new definition of "owned an existing well" in §711.1 as suggested by Vulcan.

Section 711.1(5)

SAWS submitted comments regarding § 711.1(5) of the proposed rules. SAWS requests a clarification of the definition of "producing well." SAWS recommends § 711.1(5) read :

(5) Producing well- A well from which groundwater from the aquifer is capable of being withdrawn for a beneficial use.

SAWS does not explain the basis for this suggested change.

Authority staff received the above-referenced comment and agrees with it. The basis for this determination is that if a well is incapable of withdrawing water for beneficial use it is most likely an abandoned well. The Authority believes it is reasonable to treat all non-abandoned wells which are capable of withdrawing aquifer water as "producing wells." In light of the above discussion, Authority staff has modified §711.1(5) as suggested by SAWS.

Section 711.1(6)(E)

Earl & Brown submitted an unintelligible comment on a portion of the proposed definition of "waste" in § 711.1(6)(E).

Because the comment is unintelligible, no response is required by the Authority.

An unidentified speaker commented on § 711.1(6)(E) which defines, in part, "waste." The commentator stated that while the Authority holds agricultural producers accountable for waste, the rules only contain one minor rule regarding the waste that results from altered springflow. He feels the proposed rules are too focused on agriculture.

The Authority disagrees with this comment. The basis for this determination is as follows. The definition found in §711.1(6)(E) closely tracks the statutory definition found in § 1.03(21) of the Act. Further, the language of the definition is not in any way limited to agriculture, but applies to any practice that may result in waste. In light of the above discussion, the Authority has declined to revise § 711.1(6)(E).

Section 711.1(6)(J)

Bragg and Ms. Bragg commented on the definition of waste contained in §711.1(6)(J). They appear to support the definition agreeing that water use in an amount that is insufficient for crop production constitutes waste. Instead of recommending revisions to § 711.1(6)(J), they appear to recommend that each existing irrigation user be guaranteed a minimum of 2 acre-feet of water for seasonal crop irrigation or, for permanent crops such as pecans which allegedly have greater water requirements, that each existing irrigation user be guaranteed a minimum equal to whatever amount is necessary to complete a crop cycle. In order to make this feasible, Bragg suggests the Authority raise the 450,000 acre-feet withdrawal "cap" by 0.3% to account for all pecan farmers.

Authority staff received the above-referenced comments and agrees that water use which is insufficient for crop production constitutes waste. The Authority disagrees with the remainder of the comments. The Act is prescriptive regarding the calculation of maximum historical use, average historical use, and two acre-feet per irrigated acre in any one year during the historical period from 1972 to 1993. Irrigators of commercial pecan orchards, while entitled to at least a two acre-feet minimum, can receive a permit for more than two acre-feet if evidence of groundwater withdrawal from the aquifer, during the historical period, demonstrates that their historical average minimum exceeds two acre-feet per acre per year. The Authority, however, does not believe it has the statutory authority to increase the statutory irrigator minimum to an amount in excess of two acre feet per year. Further, the Authority does not believe that, at this time, it would be justified in raising the 450,000 acre-feet withdrawal "cap." Section 1.14(b) of the Act mandates that, until December 31, 2007, permitted withdrawals may not exceed 450,000 acre-feet of water per year. The chapter 711 rules are written to implement this 450,000 acre-feet cap. It is true that § 1.14(d) of the Act allows the Authority to, under limited circumstances, raise this cap. This can be done, however, only under very limited circumstances. Before determining that the cap may be raised, the Authority must first, through studies and implementation of various water management strategies, determine that additional supplies are available from the aquifer. The Authority must also undertake consultations with appropriate state and federal agencies in order to raise the cap. At this time, the Authority does not believe it has adequate data nor does it believe that sufficient water management strategies have been implemented or adequate consultations have taken place in order to justify raising the cap. While the Authority may, at some future date, attempt to raise the cap, it declines to do so at this time. In light of the above discussion, Authority staff has declined to modify § 711.1(6)(J).

Earl & Brown, on behalf of their clients, commented upon proposed rule § 711.1(6)(J), which defines "waste", in part, as:

Irrigation use of groundwater from the aquifer in a volume per irrigated acre that is so insufficient that a crop could not have been reasonably cultivated and produced.

Earl & Brown seeks the deletion of this item, arguing that there is no basis for it in the Act, and that the language is confusing and ambiguous.

The Authority disagrees with this comment. The basis for this determination is as follows. The Act delegates to the Authority broad discretion to limit waste of water, protect the aquifer, and maximize the beneficial use of water from the aquifer. See, e.g., Act §§ 1.08(a) and 1.14(a). It is true that § 1.16(e) of the Act provides that existing irrigation users may receive a permit for not less than two acre-feet a year for each acre of land the user actually irrigated in any one calendar year during the historical period. However, § 1.16(d)(2) dictates that groundwater first be beneficially used before it can qualify for the statutory irrigator minimum in § 1.16(e). The use of a quantity of aquifer water in a volume per acre that is insufficient to reasonably cultivate and produce a crop does not constitute a beneficial use and is, therefore, wasteful. The definition in § 711.1(6)(J) implements this beneficial use requirement. In light of the above discussion, the Authority has declined to revise § 711.1(6)(J).

Section 711.12(a)(4)

As proposed, rule § 711.12(a)(4) states that any person wishing to "install, equip, complete, alter, operate, or maintain a well pump installed or to be installed on a well designed for the withdrawal of groundwater from the aquifer" must first obtain a permit from the Authority. SAWS commented that the first word of this section, "install," is confusing and redundant of the later phrase "installed or to be installed" and suggests that it be deleted.

Authority staff agrees with the comment. The basis for this determination is that the word "install" is arguably synonymous with equip and is confusing because it is redundant in light of the phrase "installed or to be installed." In light of the above discussion, Authority staff has modified § 711.12(a)(4).

Sections 711.20 and 711.32

V&E commented upon proposed rules §§ 711.20 and 711.32 which are not a part of these proposed rules and which, therefore, require no response by the Authority.

Section 711.94(c)

SAWS commented upon proposed § 711.94(c). SAWS seeks clarification that a contract user only has a right to receive a permit if specifically granted by contract. SAWS proposes that the section read:

(c) Unless otherwise provided by contract, the beneficial use of groundwater by a contract user may only be claimed by a prior user or existing user in support of a declaration.

The Authority supports this suggested revision and will revise the rule. The revision clarifies the intent of the rule, which is to identify the appropriate users who may claim beneficial use by contract users. It also makes clear the Authority's conclusion that contract users may not themselves claim historical use and obtain an initial regular permit.

Section 711.94(d)

Both Earl & Brown and Faseler commented upon proposed §711.94(d), which states:

Irrigation use of groundwater from the aquifer in the volume of two acre-feet per irrigated acre is rebuttably presumed to constitute beneficial use without waste.

Earl & Brown proposes changing the word "rebuttably" to "irrebuttably." Faseler, on the other hand, believes the percolation rate should be used to determine how water is to be applied, not as a regulation.

The Authority disagrees with these comments. The purpose of including the phrase "rebuttably presumed" in the rule is not to affect the process by which irrigators are issued permits or to affect the eligibility of an irrigator for the statutory two acre-feet irrigator minimum. Instead, it is intended to facilitate the Authority's ability to prevent waste by irrigators once permits have been issued. Not all irrigation practices necessitate the use of two acre-feet of water per acre per year, nor are irrigators any more exempt than any other aquifer users from the requirement that aquifer water be beneficially used and not wasted. It is possible that an irrigator's practices may be wasteful even if his rate of use is below two acre-feet per acre per year. In that event, the Authority believes it needs to retain the right to rebut the presumption that usage of two acre-feet is not wasteful.

Section 711.96(b)(1)

Vaughan commented on proposed rule § 711.96(b)(1), which states:

(b) An Application for a groundwater withdrawal permit for a well that withdraws groundwater from multiple aquifers, including the Edwards Aquifer, may be granted by the board in an amount that does not exceed:

(1) for irrigation use, the pro rata share of the number of acres beneficially irrigated with the volume of aquifer water withdrawn from the well based on the percentage of aquifer water produced from the well, multiplied by two acre-feet; or. . .

Vaughan claims the Act provides existing irrigation users/ applicants "shall receive a permit for not less than two acre feet a year for each acre of land the user actually irrigated in any one calendar year during the historical period." Vaughan relays the calculation for historical users which he states gives such users a permit for "at least the average amount of water withdrawn annually during the historical period." Vaughan argues the legislative intent mandated irrigation permits of two acre feet per year based only upon the number of irrigated acres during the historical period.

The Authority disagrees with this comment. Based upon § 1.16(d)(2) of the Act, there is a statutory requirement that irrigation water must be beneficially used and not wasted. This necessarily means that the volume of groundwater applied to the land for irrigation purposes must be in sufficient minimum quantities to reasonably cultivate and produce a crop and thereby constitute beneficial use.

Pursuant to § 1.08(b) of the Act, the Authority has jurisdiction only over "groundwater within or withdrawn from the Edwards Aquifer." Thus, the Authority has no statutory authority to issue an initial regular permit for the irrigation of land by non-Edwards Aquifer water. Notwithstanding the rule, permit applicants or permit holders remain free to pump groundwater from aquifers other than the Edwards without any restrictions from the Authority.

Sections 711.172 - 711.176

Edward G. Vaughan generally protests proposed rules §§ 711.172 through 711.176 to the extent that they endeavor to limit the permit amount to below the supposed statutory minimum of two feet per acre. Vaughan cites § 1.16 of the Act and legislative intent as mandating that irrigators shall not receive a permit for less than two acre feet for each acre of land actually irrigated in any one calendar year during the historical period.

Authority staff received the above-referenced comment, and disagrees with it. The reasons for this disagreement are found in response to other comments to §711.172 and §711.176 below.

Section 711.96(b)(1)

Earl & Brown commented on proposed rule §711.96(b)(1). While the comment is difficult to interpret, Earl & Brown appears to be concerned that the wording of this provision improperly results in a double reduction of the permit amount. Earl & Brown suggests that the permit amount should be calculated by multiplying the total acreage irrigated times the percentage of Edwards Aquifer water produced times two acre-feet per acre.

The Authority agrees with the method of calculation suggested by Earl & Brown and states that it is consistent with the intent of the rule as originally proposed. In light of the comments, the Authority staff has modified §711.96 (b)(1) to clarify the wording of the method by which the permit amount for multiple aquifer wells is calculated to be consistent with this intent.

Section 711.96(b)(1) and (b)(2)

SAWS commented on proposed rule § 711.96(b)(1) and (b)(2), concurrently. SAWS, in order to clarify that only production of Edwards groundwater is at issue in the case of a commingled well, asks that the sections read:

(b)(1) ...based on the percentage of Edwards Aquifer water produced from the well,... and

(b)(2) ...actual amount of groundwater from the Edwards Aquifer.

Authority staff received the above-referenced comment, and agrees that only production of Edwards groundwater is at issue in the case of a commingled well. However, no amendment to these rules is necessary because "aquifer" is defined in Authority §702.1(b)(6) as "the Edwards Aquifer . . . ". In light of the above discussion, Authority staff has not modified §711.96 (b)(1) and §711.96 (b)(2) .

Section 711.96(b)(2)

Earl & Brown, on behalf of their clients, commented on proposed §711.96 (b)(2), which states:

(b) An application for a groundwater withdrawal permit for a well that withdraws groundwater from multiple aquifers, including the Edwards Aquifer, may be granted by the board in an amount that does not exceed: . . .

(2) for non-irrigation use, the actual amount of groundwater from the aquifer.

Earl & Brown claims the rule needs to be clarified to stipulate that the water withdrawn from the aquifer must be beneficially used.

Authority staff received the above-referenced comment, and agrees with it. The Authority notes that all withdrawals of groundwater from the aquifer are subject to the continuing duty to be placed to beneficial use. However, the Authority agrees that it is useful to reemphasize that principle in this rule. In light of the above discussion, Authority staff has modified §711.96 (b)(2).

Proposed Counterpart to § 711.96 for Edwards Water Commingled with Surface Water

SAWS proposes adding a new section similar to §711.96 which would address the situation of Edwards Aquifer water commingled with surface water before being put to a beneficial use.

Authority staff received the above-referenced comment, and agrees that such a rule may be worth considering. Under the procedural requirements of the APA, however, the Authority is limited in its ability to adopt new rules without first providing notice and an opportunity for the public to comment upon those rules. Therefore, the Authority declines to create such a rule at this time, but may consider such an option in future rulemaking efforts.

Further, Authority staff disagrees the change is entirely necessary because this fact situation is already covered by other rules. For example, in Section 711.1(6)(J) the definition of "waste" includes that if the well is too small to irrigate the claimed acreage with sufficient enough water to successfully raise a crop, then use of that water is per se waste. In evaluating the applications the staff will reduce the acreage for which an initial regular permit is issued to the amount that can reasonably be supported by the well.

Section 711.98(e), (f), and (g), §711.100

Section 711.98(e) states that initial regular permits may be retired in accordance with the following rules of the Authority: (1) the Springflow Maintenance Rules of Subchapter G of Chapter 715; (2) the equal percentage reduction rules of Subchapter G of Chapter 711; or (3) the regular permit retirement rules of Subchapter H of Chapter 715. Subchapters G and H of Chapter 715 have yet to be adopted by the Authority. SAWS objects to specifically identifying these Subchapters in favor of a more generic approach stating that permit may be retired in accordance with "future rules adopted by the Authority."

SAWS makes similar suggestions for §711.98(f) and (g), which identify rules by which initial regular permits may be suspended or interrupted, respectively. SAWS also suggests similar changes in § 711.100.

The Authority disagrees with these comments. The level of detail in the rules as proposed is greater than that suggested by SAWS. The Authority believes it is preferable to identify, as much as possible, the circumstances by which permits may be retired, suspended or interrupted and the location of the applicable rules. The fact that these rules will be developed at a future date does not diminish the need to provide the public with notice of the proposed location of the relevant rules.

Section 711.98(g)(3)

As proposed, § 711.98(g)(3) provides as follows:

(g) If in effect, initial regular permits may be interrupted in accordance with the following rules: ...

(3) the springflow maintenance rules pursuant to Subchapter G (relating to Springflow Maintenance Rules) of Chapter 715 (relating to Comprehensive Water Management Plan Implementation).

Bragg's comments express opposition not at this particular rule, but at the substance of any future springflow maintenance rules which might be adopted by the Authority. Bragg recommends that the Authority evaluate further the effect of groundwater use restrictions and their effect on springflows, with particular attention to: 1) quantifying the effects of water use restrictions imposed long distances from the springs on actual springflows; and 2) assessing springflow augmentation to protect endangered species dependent upon springflows.

The Authority declines to delete or revise § 711.98(g)(3) in response to this comment. All initial regular permits will likely be subject to at least some degree of spring flow maintenance rules pursuant to Chapter 715, Subchapter G of this title (relating to Springflow Maintenance Rules; Comprehensive Water Management Plan Implementation). The Authority believes it is appropriate to give the regulated community advance notice of that fact via § 711.98(g)(3). § 711.98(g)(3) does not itself set forth the substantive springflow maintenance rules. Instead, it merely provides a reference to those rules. The Authority acknowledges, however, that the issues raised by Bragg, regarding the substance of what the springflow maintenance rules should require, are relevant for consideration at the time those rules are drafted and considered for adoption. In light of the above discussion, Authority staff has not modified § 711.98(g)(3).

Section 711.98(i)

As proposed, § 711.98(i) states: "Initial regular permits may be canceled pursuant to Subchapter H of this Chapter (relating to Abandonment and Cancellation)." While SAWS appears, in the abstract, to acknowledge the need to cancel certain permits through the abandonment and cancellation process, SAWS also states that it needs to obtain pumping rights to be held in reserve for future use. Because SAWS is concerned about having such unused rights canceled by the Authority, it proposes deletion of § 711.98(i). SAWS also comments that unused rights serve a conservation purpose.

The Authority declines to delete § 711.98(i) in response to this comment. Section 1.16(g) of the Act provides that, once issued, initial regular permits remain in effect "until the permit is abandoned, cancelled, or retired." The Authority believes it is appropriate to give the regulated community advance notice of the limitations of initial regular permits and the circumstances under which such permits may be canceled. Further, § 711.98(i) does not set forth the substantive rules regarding when cancellation may take place. Instead, it merely provides a reference to those rules.

Section 711.98(j)(1)

Schirmer commented on rule § 711.98 (j)(1), which states, in part:

(j) . . . The board shall grant an application for an initial regular permit if the following elements are established by convincing evidence: . . .

(1) the applicant filed a declaration on or before December 30, 1996;. . .

Schirmer claims that, roughly 100 years ago, the owner of Comal Springs manually enhanced the flow of the springs. He claims that the current owner of Comal Springs was required to file a declaration on or before December 30, 1996 in order maintain this allegedly enhanced springflow. Having failed to do so, Schirmer apparently contends that flow at Comal Springs should be restricted by the Authority.

The Authority disagrees with the comment. Without even addressing the factual allegations raised by Schirmer, the Authority does not believe that a permit is required for springflows at Comal Springs. A primary objective of the Act is to preserve and protect springflows and the species which depend upon those springflows. This objective would be undermined by ordering the restriction of such springflows. Finally, the entire permitting structure, embodied in the Act, applies to withdrawals from the aquifer made by wells, not to natural springs. In light of the above discussion, Authority staff has not modified § 711.98 (j)(1).

Section 711.98(j)(12)

As proposed, § 711.98(j)(12) reads, in part:

. . . The board shall grant an application for an initial regular permit if the following elements are established by convincing evidence: . . .

(12) the well(s) does not qualify for exempt well status; . . .

Earl & Brown proposes that paragraph (12) should revised to read: "the well is not registered as an exempt well." Earl & Brown reasons that an owner of an exempt well may choose to apply for and receive a permit based upon his historical pumpage even though he could have otherwise foregone the permit process and simply operated his well as an exempt well.

The Authority disagrees. The Act makes it clear that wells which qualify as exempt are therefore exempt from the permitting requirement and the 450,000 and 400,000 acre-feet withdrawal caps. See §§ 1.14(b) and (c), 1.15(b), 1.16(c), and 1.33. In other words, no permit may be issued for such wells. A well that qualifies for exempt well status, and is therefore required to register as an exempt well, cannot simultaneously or alternatively be a permitted well. Exempt status derives from the purpose of use, location of the point of withdrawal, and well production capacity. Exempt well rights are not transferrable because they derive from the land where the well is located and the purpose of use. Issuance of a permit for an exempt well, as desired by Earl & Brown, would lead to results which are administratively absurd and were not intended by the Legislature. For example, the owner of an exempt well who chose to obtain a permit for that well ("Mr. X") could arguably transfer (sell) the permit to another landowner ("Mr. Y"). Mr. Y could then make withdrawals based upon the transferred permit apparently without regard to whether his use qualifies as exempt. However, even though he no longer owns a permit, Mr. X could continue to make exempt withdrawals from his well, assuming he met the criteria in § 1.33 of the Act. The result would be a doubling of the rights to withdraw aquifer water based upon the same historical use -- a result which could not have been intended by the Legislature when it passed the Act. In light of the above discussion, Authority staff has not modified §711.98(j)(12).

Section 711.98(k)

SAWS asked that § 711.98(k) be modified to read:

The board shall issue withdrawal amounts to an applicant for an initial regular permit pursuant to § 711.176 (relating to Groundwater Withdrawal Amount for Initial Regular Permits: Compensation for Step-Up Amounts) or as modified by 711.180 of this title (relating to Voluntary Waiver of Applications for Initial Regular Permits) of this chapter.

The Authority agrees with this comment and revises the rule accordingly. Section 711.180 authorizes the Authority to enter into agreed orders waiving all or a portion an applicant's claimed maximum historical use, PA amount, step up amount, base irrigation groundwater or unrestricted irrigation groundwater claimed in or proposed in a permit application. Thus, an applicant's ultimate permit amount may be affected by such an agreed order, and it is appropriate to acknowledge the effect § 711.180 can have upon the board's permit calculations.

Sections 711.98 - 711.110

TFB submitted comments generally regarding §§ 711.98 - 711.110 of the proposed rules. TFB notes that all of these sections, as proposed, require that the Board grant an application for a permit if certain elements are established by "convincing evidence." TFB asserts that although the Board, via the Act, is required to grant an initial regular permit only after the applicant establishes by "convincing evidence beneficial use of underground water from the aquifer," the Act does not require that all elements be proven by convincing evidence. Additionally, TFB contends this standard is required only for initial regular permits and is inappropriate for other permits, such as emergency or well-monitoring permits. Therefore, TFB suggests the "convincing evidence" burden of proof should only apply to proving beneficial use of groundwater for initial regular permits.

Authority staff received the above-referenced comment, and disagrees with it. The basis for this determination is that administrative efficiency and consistency is fostered by the uniform use of terminology applicable to the permitting process. In light of the above discussion, Authority staff has not modified §§ 711.98- 711.110 .

Section 711.102(d)

Section 711.102(d) provides the circumstances under which withdrawals pursuant to term permits may be interrupted. BCWCID identified a typographical error and commented that §711.102(d)(2) should be revised to read:

If in effect, term permits shall be interrupted in accordance with the following rules: . . .

(2) for wells completed in the San Antonio pool and within Atascosa and Medina counties, well TD 69-47-306 is equal to or less than 685 feet above mean sea level:

This comment has been rendered moot by nature of the fact that the Authority has elected to delete §711.102(d)(2) as proposed.

Section 711.102(g)

Earl & Brown identified a typographical error in § 711.102(g), which, as proposed, read:

The board shall issue a groundwater withdrawal amount to an applicant for an term permit in the amount that is consistent with Chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

Earl & Brown notes that the word "an" should be changed to "a."

The Authority staff agrees and has modified § 711.102(g).

Section 711.102(c)

Section 711.102(c) of the proposed rules states that term permits "are transferrable pursuant to Subchapter L (relating to Transfers) of this chapter." Subchapter L, which is in the process of being published as proposed rules, states that term permits are not transferrable except as to ownership. A mere transfer of ownership cannot alter the purpose of use, point of withdrawal, place of use or other permit characteristics. SAWS states that term permits should not be transferable and § 711.102(c) should make this fact clear. SAWS requests more clarity which would prevent a reader from having to reference another portion of the rules.

Authority staff received the above-referenced comment and agrees with it in part. The basis for this determination is that ownership is the only anticipated aspect of a term permit which may be transferred pursuant to Subchapter L (relating to Transfers) of this chapter. A mere transfer of ownership would not affect the term permit's purpose of use, point of withdrawal or place of use. In light of the above discussion, Authority staff has modified § 711.102(c) to read:

(c) Term permits are transferable only as to ownership, pursuant to Subchapter L (relating to Transfers) of this chapter.

Section 711.102(d)

As originally proposed, §711.102(d) identified the scenarios under which withdrawals pursuant to term permits may be interrupted. It identifies various index well levels as well as various rules which are not yet adopted by the Authority. SAWS objects to specifically referencing rules which are not yet adopted and instead favors a more generic approach of stating that term permits may be retired in accordance with "rules adopted by the Authority as allowed by § 1.14(f) and other sections of the Act." SAWS further objects to the use of index well TD 69-47-306 until "supporting hydrogeologic research under § 1.14(g) of the Act has been conducted."

The Authority disagrees with these comments. The level of detail in the rules as proposed is greater than that suggested by SAWS. The Authority believes it is preferable to identify, as much as possible, the circumstances by which term permits may be interrupted and the location of the applicable rules. The fact that these rules will be developed at a future date does not diminish the need to provide the public with notice of the proposed location of the relevant rules.

Similarly the Authority disagrees that additional hydrogeologic research is required before establishing additional index wells for any aquifer pool. Section 1.14(g) of the Act provides that additional index wells may be established for a pool (in this case, the San Antonio pool), if such additional index wells "aid the regulation of withdrawals from the pool." Nevertheless, the Authority has deleted §711.102(d)(2) as it was originally proposed and term permits will now only be interrupted based on index wells J-17 and J-27.

Section 711.102(f)(12), (g), and (h)

Section 711.102 deals with term permits and references and, in part, Chapter 715. SAWS objects to the references to Chapter 715 because those rules have not yet been adopted. SAWS proposes that § 711.102 be changed to read:

(f) The board shall grant an application for a term permit if the following elements are established by convincing evidence: . . .

(12) the proposed withdrawal of groundwater is consistent with the water available for permitting. . . .

(g) The board shall issue a groundwater withdrawal amount to an applicant for a term permit in the amount that is consistent with the water available for permitting.

(h) By January 15 of each year, the board by order shall determine the total quantity of groundwater that may be withdrawn from each pool of the aquifer for that calendar year pursuant to term permits. At any time by order of the Board this determination may be revised as appropriate based upon actual aquifer conditions.

Authority staff received the above-referenced comment and disagrees with it. The level of detail in the rule as proposed is greater than that suggested by SAWS. The Authority believes it is preferable to identify, as much as possible, the circumstances by which term permits shall be governed and the location of the applicable rules. The fact that these rules will be developed at a future date does not diminish the need to provide the public with notice of the proposed location of the relevant rules. In light of the above discussion, Authority staff has not modified §711.102(f)(12), (g) or (h).

Section 711.108(a)

Earl & Brown identified a typographical error in §711.108(a) which requires the addition of the word "the" as italicized below:

Any person proposing to perform any of the activities set forth in § 711.12(a)(2)-(5) of this title (relating to Activities Requiring a Permit) shall apply for a well construction permit.

The Authority staff agrees and has modified § 711.108(a) .

Section 711.108(c)

Earl & Brown and SAWS both commented upon rule §711.108(c) which states:

A well constructed pursuant to a well construction permit must be completed within 180 days of the issuance of the permit. The permit expires if the well has not been constructed within 180 days of the permit issuance. Upon expiration of the term, the permit automatically expires and is canceled.

Earl & Brown first asserts that confusion arises from the fact that the first sentence indicates the well must be "completed" within 180 days while the second sentence states the well must have been "constructed" within the 180 day period. Second, Earl & Brown proposes that the last sentence of § 711.108(c) be changed to read:

"Upon expiration of the term, in the event the permittee has not constructed/completed a groundwater withdrawal well within the term period, the permit then automatically expires and is canceled."

Due to the size and complexity of the large wells drilled by it, SAWS believes the 180-day period to construct a well should be lengthened to one year, with a mechanism in place to request extensions.

The Authority disagrees with the second comment from Earl & Brown. Upon the expiration of the term, and barring any extensions of the term by the Authority, a construction permit expires and is canceled regardless of whether the well has been completed or not.

The Authority agrees with the first comment from Earl & Brown. The Authority believes that the wording of the rule could be clarified by using the term "completed" consistently throughout.

The Authority also agrees with SAWS that there should be a mechanism for lengthening the 180-day term in response to special circumstances. Other commenters on the Chapter 707 rules, which were proposed concurrently with Chapter 711, have also pointed out that 180 days may, at times, be inadequate when there is a shortage or unavailability of water well drillers to construct a well. Accordingly, the Authority has revised § 711.108(c) to read:

A well constructed pursuant to a well construction permit must be completed within 180 days of the issuance of the permit. The permit term may be extended by one additional 180-day extension period by the general manager. In order to obtain such an extension, the holder of a well construction permit must submit a written request to the general manager explaining the need for the extension. If the holder of the well construction permit demonstrates a need for an extension and demonstrates that the permit holder's failure to complete the well within the original 180-day term is not due to the permit holder's own lack of diligence, then the general manager may authorize the extension. Upon expiration of the term, including any extension granted, the permit automatically expires and is canceled.

Section 711.108(d)(7)

SAWS and Earl & Brown identified a typographical error in §711.108(d)(7) which requires the revision of the word "beneficial" to "beneficially."

The Authority staff agrees and has modified § 711.108(d)(7) .

Section 711.108(d)(3)

Earl & Brown commented upon proposed rule §711.108(d)(3), which states:

"(3) the well head is or will be physically located within the boundaries of the authority;"

Earl & Brown suggests "authority" be changed to "Authority." The Authority agrees and will make the change .

Section 711.108(d)(5)

Earl & Brown commented upon proposed rule §711.108(d)(5). Earl & Brown suggests the word "aquifer," the last word in §711.108(d)(5), be capitalized to read "Aquifer."

The Authority disagrees and feels it is appropriate to refer to the aquifer in lower case.

Section 711.108(d)(6)

Earl & Brown commented upon proposed rule §711.108(d)(6), which provides that applications for well construction permits shall be granted if a number of conditions are established, including that "(6) the withdrawals are proposed to be placed to a beneficial use for domestic, livestock, irrigation, municipal, or industrial use; . . .".

Earl & Brown asserts this section would allow a well to qualify as an exempt well so long as the water is beneficially used for "domestic, livestock, irrigation, and municipal or industrial use," thereby expanding the definition of an exempt well, in conflict with the Act.

Authority staff received the above-referenced comment and disagrees with it. The basis for this determination is that §711.108(d)(6) has nothing to do with qualifying for exempt well status. Instead, it sets the criteria for granting a well construction permit. It does not expand the criteria for exempt wells. However, in order to provide additional clarity on this issue, the Authority has amended this section in order to more closely track the statutory definition for domestic or livestock use and to make other editorial changes. Accordingly, the section now reads:

(6) the withdrawals are proposed to be placed to a beneficial use for domestic or livestock use, irrigation use, municipal use, or industrial use;

Section 711.108(d)(9)

Earl & Brown commented upon proposed rule §711.108(d)(9) which identifies one of the required elements of a well construction application. The rules states:

(9) The quantity of groundwater the well would be capable of producing, if constructed, is consistent with the quantity of groundwater the applicant proposes to produce pursuant to exempt well status or pursuant to a groundwater withdrawal permit.

Earl & Brown comments that the provision should be clarified to mirror the language in the Act relating to exempt wells, found at § 1.33, which provides that a well producing 25,000 gallons of water a day or less for domestic or livestock use is exempt from metering requirements.

Authority staff received the above-referenced comment and disagrees with it. The basis for this determination is that a well with sufficient capacity to produce more than 25,000 gallons of water a day would require a meter to ensure it did not produce more than 25,000 gallons of water per day. By requiring that the well be constructed so that it is capable of only producing the quantity of groundwater the applicant proposes to produce for exempt status, the Authority ensures that the well does not exceed exempt well status and does not need a meter. In light of the above discussion, Authority staff has not modified §711.108 (d)(9).

Section 711.108(d)(11)

Earl & Brown commented upon proposed rule §711.108 (d)(11), which provides that applications for well construction permits shall be granted if a number of conditions are established, including that "(11) the proposed well construction and operation would not unreasonably negatively affect the aquifer or other permittees." Earl & Brown suggests that this provision be omitted because the term "unreasonably negatively affect the aquifer or other permittees" is vague, ambiguous, and inconsistent with the proposed rules. Earl & Brown argues that "unreasonably negatively" should not be used solely as a benchmark for exempt wells.

Authority staff received the above-referenced comment and disagrees with it. The basis for this determination is that §711.108(d)(11) provides a benchmark not only for exempt wells, but for the construction of any wells. It also provides protection for current aquifer users. The rule is consistent with the Authority's statutory duty to manage, conserve, preserve and protect the aquifer and its users. In light of the above discussion, the Authority has not modified §711.108(d)(11).

Section 711.108(d)(14)

Earl & Brown commented upon proposed rule §711.108(d)(14), which provides that applications for well construction permits shall be granted if a number of conditions are established, including that "(14) the application is in compliance with the Act;"

Earl & Brown suggests that, rather than making a general statement that "the application is in compliance with the Act," this provision should continue by listing what must be included in order for an applicant to be in compliance with the Act or, alternatively, incorporate requirements set forth in the Act.

The Authority disagrees. The requirements of the Act are set out in the text of the Act and are further developed in the text of the Authority's rules. To reincorporate these requirements into the confines of a single rule would result in needless duplication and confusion. Accordingly, the Authority declines to modify § 711.108(d)(14).

Section 711.108(d)(15)

Earl & Brown commented upon proposed rule §711.108(d)(15), which provides that applications for well construction permits shall be granted if a number of conditions are established, including that "(15) the application is in compliance with the rules of the Authority."

Earl & Brown suggests that, rather than making a general statement that "the application is in compliance with the rules of the Authority," this provision should continue by listing what must be included in order for an applicant to be in compliance with the rules.

The Authority disagrees. The requirements of the rules are set forth in the text of the Authority's rules. To reincorporate these requirements into the confines of a single rule would result in needless duplication and confusion. Accordingly, the Authority declines to modify § 711.108(d)(15).

Comment on Exempt Wells

Earl & Brown includes a "general comment" concerning whether and when, pursuant to § 1.33(c) of the Act, a well within or serving a subdivision requiring platting qualifies as exempt. This comment is not responsive to any of the Chapter 711 rules within this Final Order Adopting Rules. The Authority is in the process of publishing notice of its proposed exempt well rules. Earl & Brown is encouraged to comment on those rules at the appropriate time.

Section 711.112

Section 711.112 states that groundwater permits issued by the Authority "shall include" various components, including: "(13) The equal percentage reduction amount as calculated pursuant to §711.174 of this title . . . and subchapter H . . . of Chapter 715 of this title . . .; the amount that may be subject to restoration pursuant to § 711.172(h) of this chapter . . . and § 711.304 of the chapter . . . ." (Emphasis added.) SAWS recommends changing § 711.112 (13)to read:

(13) the amount that may be subject to restoration.

SAWS believes this change would add clarity to initial regular permits by identifying the permit amount that may be subject to restoration in the event that additional groundwater supplies become available for permitting.

Authority staff received the above-referenced comment and disagrees with it. The Authority believes that the rule already makes it clear that the "equal percentage reduction amount" is an "amount that may be subject to restoration" in the event that additional groundwater supplies become available for permitting, such as if the Authority raises the 450,000 or 400,000 acre-feet withdrawals caps. The Authority has declined to revise § 711.112 in response to this comment.

Section 711.112(17)

Section 711.112 states that groundwater permits issued by the Authority "shall include" various components, including: "(17) metering or alternative measuring method." SAWS asserts that permits will need to be reissued should a change in meters occur. This, according to SAWS, would be unnecessarily burdensome. SAWS suggests that the permit only have the "duty to meter" as a requirement and that meter registration be handled outside the permit process. SAWS requests that § 711.112(17) read:

(17) requirement to register meters or alternative metering method;

Authority staff received the above-referenced comment and disagrees. The basis for this determination is that the listing, required in § 711.112, merely identifies the issues that are to be addressed in all groundwater withdrawal permits issued by the Authority. The substantive issues raised in the rules do not direct the Authority on how to address the issues in a permit, but simply that the issues must be addressed. The Authority retains considerable flexibility in the permit drafting process regarding how to most effectively address each issue, required by this rule, to be a part of the permit. The Authority will draft its permits in such a way that permits need not necessarily be reissued upon meter changeouts. In light of the above discussion, Authority staff has not modified § 711.112(17).

Section 711.112(19)

Section 711.112 states that groundwater permits issued by the Authority "shall include" various components, including: "(19) conditions for suspension of withdrawals." SAWS believes permits should not able to be suspended, but rather limited, by future unwritten Authority rules. SAWS asserts that § 1.16(h) of the Act clearly recognizes permit limitations and only requires the Authority to notify permit holders "that the permit is subject to limitations." SAWS would have the rule read:

(19) conditions for limitation of withdrawals;

Authority staff received the above-referenced comment and disagrees with it. The basis for this determination is that the term "limitation" as used in § 1.16(h) of the Act is a generic term which encompasses several kinds of reduction strategies on a permittee's right to withdraw groundwater. These reduction strategies will be more fully developed in Chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation) and will include permit retirements, suspensions and interruptions. In light of the above discussion, Authority staff has not modified § 711.112(19) .

Section 711.112(21)

Section 711.112 states that groundwater permits issued by the Authority "shall include" various components, including: "(21) conditions for renewal." SAWS suggests that the rule read:

(21) conditions for renewal, if any;

The Authority received the above-referenced comment and agrees with it in concept. The basis for this determination is that not all groundwater withdrawal permits are renewable. Therefore, the Authority has modified § 711.112(21) as follows:

(21) conditions for renewal, if applicable;

Section 711.116

SAWS submitted comments regarding § 711.116 of the proposed rules which relates to the contents of well construction permits. SAWS states that before completion of a well, the withdrawal rate may not be known, but only estimated. Therefore, any limitations as to withdrawals are only appropriate for construction of exempt wells. SAWS maintains that all other wells would require transfer of permitted water rights before use. SAWS suggested that § 711.116 read:

(6) maximum estimated rate of withdrawal in gallons per minute;

(7) if an exempt well, restriction of production to 25,000 gallons of water a day or less for domestic or livestock use;

(8) ELIMINATE (8)

(16) any other appropriate conditions on the well construction as...

The Authority received the above-referenced comments and disagrees with them. The basis for this determination is that for enforcement purposes, the Authority is required to established clear and identifiable maximum or minimum parameters that must be met by permittees in order to be in compliance with a permit. The creation of compliance parameters based on estimated amounts would not provide the Authority with enforceable permit criteria. However, the Authority does recognize that the wording in §711.116(16) contains a typographical error which has been corrected.

Sections 711.130 and 711.134

TFB submitted comments regarding § 711.134, relating to Standard Conditions, of the proposed rules. Generally, TFB contends this section proposes standard permit conditions which the Authority intends to incorporate into every groundwater withdrawal permit. The section, according to TFB, is written in an awkward manner. TFB suggests the Authority re-write the section in an active voice as follows:

The Authority shall incorporate the following conditions into groundwater withdrawal permits: (1) The permittee shall comply with the requirements of Subchapter G of Chapter 713 of this title, relating to the construction operation, and maintenance of wells.

TFB maintains that, as presently written, the section is unclear as to who is to comply with the standard conditions. TFB has assumed that the permittee is to comply with the conditions and that the Authority will incorporate provisions similar to these in each permit. Additionally, TFB suggests the removal of the explanatory phrases in § 711.134(1), (2), (3), and (4) and replacing them in § 711.130. TFB believes these phrases in § 711.134 make the section cumbersome.

The Authority received the above-referenced comment and agrees with it. The basis for this determination is that the section would be more clearly understood by permittees. In light of the above discussion, Authority staff has modified § 711.130 and §711.134 to read:

Section 711.130 Purpose

The purpose of this subchapter is to establish the standard conditions required to be contained in a groundwater withdrawal permit issued by the authority for, among other things:

(1) the protection of the water quality of the groundwater of the aquifer;

(2) the protection of the water quality of the surface streams to which the aquifer provides springflow;

(3) the achievement of water conservation, and the maximization of the beneficial use of groundwater available for withdrawal from the aquifer;

(4) the protection of aquatic and wildlife habitat, and the protection of species that have been listed as threatened or endangered under applicable federal or state law; and

(5) the providing for instream uses, bays, and estuaries.

Section 711.134 Standard Conditions

Any groundwater withdrawal permit issued by the authority is subject to and the permittee shall comply with the following conditions:

(1) the construction, operation and maintenance of wells pursuant to subchapter C (relating to Well Construction, Operation and Maintenance) of chapter 713 of this title (relating to Water Quality);

(2) the abandonment and closure of wells pursuant to subchapter D (relating to Abandoned Wells; Well Closures) of chapter 713 of this title (relating to Water Quality);

(3) the spacing of wells pursuant to subchapter E (relating to Well Spacing) of chapter 713 of this title (relating to Water Quality);

(4) the installation, operation and maintenance of well fields pursuant to subchapter F (relating to Well Head Protection) of chapter 713 of this title (relating to Water Quality);

(5) the recharge of the aquifer pursuant to subchapter J of this chapter (relating to Aquifer Recharge, Storage and Recovery Project);

(6) taking no action that pollutes or contributes to the pollution of the aquifer;

(7) the beneficial use and utilization of groundwater withdrawn from the aquifer that is reused pursuant to subchapter I (relating to Reuse Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(8) not wasting groundwater within or withdrawn from the aquifer pursuant to subchapters E (relating to Permitted Wells) and I of this chapter (relating to Prohibitions);

(9) the beneficial use and utilization of groundwater withdrawn from the aquifer pursuant to subchapter C (relating to Groundwater Conservation Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(10) the beneficial use and utilization of groundwater withdrawn from the aquifer pursuant to subchapter D (relating to Demand Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(11) the interruption of the right to withdraw and beneficially use groundwater from the aquifer pursuant to subchapter E (relating to Drought Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation) ;

(12) the interruption of the right to withdraw and beneficially use groundwater from the aquifer pursuant to subchapter F (relating to Critical Period Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(13) the installation, operation and maintenance of meters and alternative measuring methods pursuant to subchapter M of this chapter (relating to Meters; Alternative Measuring Methods; and Reporting);

(14) the keeping and filing of reports pursuant to subchapter M of this chapter (relating to Meters; Alternative Measuring Methods; and Reporting), and any other applicable law or rule;

(15) the use of groundwater withdrawn from the aquifer only for an authorized beneficial use and without waste pursuant to subchapter E of this chapter (relating to Permitted Wells) and I (relating to Prohibitions);

(16) the retirement or interruption of the right to withdraw and beneficially use groundwater from the aquifer pursuant to subchapter G (relating to Springflow Maintenance Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(17) proportional adjustment pursuant to subchapter G (relating to Groundwater Available for Permitting, Proportional Adjustment, Equal Percentage Reductions) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(18) retirement by equal percentage reductions pursuant to subchapter G (relating to Groundwater Available for Permitting, Proportional Adjustment, Equal Percentage Reductions) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(19) retirement pursuant to subchapter H (relating to Withdrawal Reductions and Regular Permit Retirement Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(20) the acquisition of additional water supplies pursuant to subchapter J (relating to Alternative Water Supply Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(21) the provision of notice of changes in name and mailing address of the permitting pursuant to §707.105 of chapter 707 of this title (relating to Change of Name, Address or Telephone Number);

(22) the payment of all registration, application, aquifer management, and retirement fees pursuant to chapter 709 of this title (relating to Fees);

(23) the cessation of withdrawals under interim authorization status pursuant to subchapter D (relating to Interim Authorization) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(24) abandonment pursuant to subchapter H (relating to Abandonment and Cancellation) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(25) cancellation pursuant to subchapter H (relating to Abandonment and Cancellation) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(26) the restoration of equally proportionally reduced amounts pursuant to subchapter K (relating to Additional Groundwater Supplies) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(27) the transfer of the permit pursuant to subchapter L (relating to Transfers) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(28) the prohibition on the use of groundwater withdrawn from the aquifer at a place of use outside of the boundaries of the authority pursuant to § 711.220 of this chapter (relating to Place of Use Outside of Authority Boundaries);

(29) compliance with the terms and conditions of the permit;

(30) compliance with the act;

(31) compliance with the rules of the authority; and

(32) any other condition as may, in the discretion of the board be reasonable and appropriate.

Section 711.134

Menard comments on § 711.134 of the proposed rules as this section, among other things, relates to groundwater withdrawal permit conditions based on interruption. Menard objects to § 711.134 which, among other things, may result in the interruption of his permit rights to withdraw groundwater from the aquifer, allegedly thereby depriving him, without compensation, of the ability to beneficially use or lease groundwater.

The Authority received the above-referenced comment and disagrees with it. The basis for this determination is that interruptions of withdrawals under a statutory-based permitting system are temporary and triggered by aquifer or springflow conditions. Thus, interruptions are based upon the lack of available water. The Authority is not aware of any legal duty to compensate the owners of groundwater withdrawal permits for interruptions based on these conditions. Accordingly, the Authority has not modified § 711.134 based on this comment.

Howard B. Shadrock also commented upon § 711.134 of the proposed rules. Shadrock describes irrigation as drought "insurance" and expresses concern over losing that insurance and his inability to cover his costs. Shadrock basically complains that his right to irrigation can be interrupted and not provide him with the water he may need to irrigate during drought conditions.

The Authority received the above-referenced comment and is unable to formulate a response. The nature of the comment is such that it does not make a recommendation concerning a proposed rule, but rather makes observations as to an alleged affect of aquifer regulation during drought conditions. The Authority notes that § 711.134 merely catalogues all of the other sections or other subchapters of the Authority's rules that may impose permit conditions. This section does not itself state the substance of the conditions. The substantive section will be in the other sections or subsections and the Authority encourages commenters to provide comments on the substance of those rules at the appropriate time.

Earl & Brown commented upon proposed rule §711.134(1), which, as proposed, provided:

Any groundwater withdrawal permit issued by the authority is subject to the following conditions:

(1) the protection of the water quality of the native groundwater of the aquifer by: . . .

Earl & Brown suggests the term "native groundwater" should be clearly defined either in this provision or in the General Definition section of these proposed rules.

As shown above, this subsection has been deleted from § 711.134.

Grossenbacher commented on proposed rule § 711.134(4)(D) regarding "Standard Conditions"' and which reads as follows:

(4) the protection of aquatic and wildlife habitat, and the protection of species that have been listed as threatened or endangered under applicable federal or state law by:

(D) the interruption of the right to withdraw and beneficially use groundwater from the aquifer pursuant to Chapter 715, Subchapter F of this title (relating to Critical Period Management Rules; Comprehensive Water Management Plan Implementation);

Grossenbacher believes that this section creates a "use it or lose it" rule which is counterproductive and a confiscation of his water rights. Secondly, Grossenbacher comments on the transfer by sale or lease of water rights and the critical period management program of the Authority and its impact on transfers.

The Authority received the above-referenced comment and disagrees with it. Section 711.134(4)(D) is merely a reference to the subchapter that will contain the critical period management rules, and groundwater withdrawal permits will be subject to being conditioned based on those rules. Section 711.134(4)(D) does not itself contain the substance of those rules. Rather, it provides a handy cross-reference to the permittee of where the substance of those rules may be found. The Authority notes, however, that the critical period management plan is not conceived to contain a 10 year "use it or lose it" provision. Rather, this issue is addressed in the abandonment and cancellation rules which are pending proposal by the Authority. We encourage commenters to comment on the "use it or lose it" provisions that may be contained in those rules in proposed subchapter H of chapter 711 of this title.

As for Grossenbacher's comments on transfers, the Authority notes that the transfer rules are also not part of these proposed rules and any comments directed thereto are more appropriately made when the transfer rules are proposed in subchapter L of Chapter 711 of this title.

Schirmer and VBI also commented on proposed rule § 711.134(4)(D). They ask that it be deleted. Schirmer and VBI are Bexar County irrigation farmers and assert that Bexar County farmers are more adversely affected by the Authority's rules than farmers in Medina and Uvalde Counties. Schirmer encourages the Authority to develop an irrigation suspension program for Bexar County farmers.

The Authority received the above-referenced comments and disagrees with the request to delete § 711.134(4)(D). Section 711.134 merely catalogues all of the other sections or other subchapters of the Authority's rules that may impose permit conditions. This section does not itself state the substance of the conditions. The substantive section will be in the other sections or subsections and the Authority encourages comments to provide comments on the substance of those rules at the appropriate time.

SAWS also commented on section of § 711.134. SAWS concurs that withdrawals are limited as per § 1.14 of the Act, but objects to referencing as of yet unwritten rules in § 711.134. SAWS finds it unnecessary for the Authority to try to give meaning to every action in § 1.16(g) of the Act. SAWS comments that it would "hate to see" unused required rights canceled by the Authority because, according to SAWS, unused rights serve a conservation purpose and should not be canceled. SAWS seeks the following revisions:

(1) the protection of the water quality of the native groundwater of the aquifer by taking no action that pollutes or contributes to the pollution of the aquifer; and

ELIMINATE: (1)(A), (1)(B), (1)(C), (1)(D), (1)(E), and (1)(F);

(2)(A), (2)(B), (2)(C), (2)(D), (2)(E), and (2)(F);

(3)(B), (3)(C), (3)(D), (3)(E), (3)(F), (3)(G), and (3)(H);

(4)(A), (4)(B), (4)(C), (4)(D), (4)(E), (4)(H), and (4)(I);

(5)(A),(5)(B), (5)(C), (5)(D), (5)(E), and (5)(H); and (10).

Authority staff received the above-referenced comments and disagrees with them. The basis for this determination is that § 711.134 provides specific conditions of the permit and notice to the applicant that the permit is subject to additional rules that are consistent with the Act stated therein. Section 711.134 merely catalogues all of the other sections or other subchapters of the Authority's rules that may impose permit conditions. This section does not itself state the substance of the conditions. The substantive section will be in the other sections or subsections and the Authority encourages commenters to provide comments on the substance of those rules at the appropriate time. The Authority believes it is appropriate and helpful for the regulated public to be given notice of the relevant rules which may affect their permits.

TFB submitted comments relating to § 711.134(4)(J) of the proposed rules, which states:

Any groundwater withdrawal permit...is subject to the following conditions... . . .

(4) the protection of aquatic and wildlife habitat, and the protection of species that have been listed as threatened or endangered under applicable federal or state law by: . . .

(J) engaging in no conduct that violates the Endangered Species Act, 16 U.S.C. § § 1531-1544 (1998), or applicable state law, relative to listed threatened or endangered species; . . .

TFB seeks the deletion of this provision. TFB presumes that, as a condition of the permit, the provision would require the permittee to comply with the Endangered Species Act ("ESA"). TFB believes the provision is an indefinite requirement and questions what standards the Authority would apply in proving compliance. TFB also points out that the prohibitions of the ESA apply to all applicants whether it is stated in the Authority's rules or not.

The Authority agrees that the regulated community is required by federal law to comply with the ESA regardless of whether that fact is stated as a permit condition by the Authority. Therefore, the Authority has deleted § 711.134(4)(J).

Sections 711.164(b) and 711.170

Zinsmeyer's comments purport to relate to proposed §711.164(b) and §711.170. However, his comments do not appear to be directed at those rules. Section 711.164(b) identifies the 400,000 acre-feet "cap" which becomes effective beginning January 1, 2008. Section 711.170 identifies the amount of groundwater available for permitting for monitoring well permits. Zinsmeyer asserts that every irrigator is entitled to a permit for two acre-feet per acre. He also states that the "use it or lose it" proposal is contradictory in that a well owner will not conserve water if he loses his right to the amount he actually saved.

These comments seem to be directed towards rules which are not a part of this rulemaking package, but which the Authority is in the process of proposing for possible adoption at a later date and which will be located at Chapter 711, Subchapter H of this title (relating to Abandonment and Cancellation; Groundwater Withdrawal Permits). In light of the above discussion, Authority staff has not modified §§ 711.164(b) or 711.170.

Sections 711.166 and 711.168

Taggert commented on §§711.166 and 711.168 which relate to groundwater available for permitting for term and emergency permits. He states as follows:

These rules propose to exclude term and emergency permits from the statutory cap on annual withdrawals. Because of the potential impact of this element to the proposed rules on springflows, the City of San Marcos recommends that the EAA Board and Staff carefully analyze the quantity available for term permitting, and closely scrutinize the circumstances giving rise to emergency permits.

Authority staff received the above-referenced comment and agrees: 1) that term and emergency permits do not apply towards the caps; and 2) that the Authority should carefully analyze the quantity of water available for term and emergency permits. The rules, as written, are designed to foster this inquiry. No modification of §§711.166 and 711.168 is requested or warranted in response to this comment.

Section 711.166(b)(2)

SAWS commented upon proposed rule § 711.166(b)(2), which states that term permit applications are allowed for wells within the San Antonio pool and within Atascosa or Medina counties when well TD 69-47-306 is greater than 685 feet above mean sea level. SAWS maintains that reference to any index well, beyond those mentioned in the Act, should be avoided unless the supporting hydrogeologic research under § 1.14(g) has been conducted. SAWS seeks the deletion of § 711.166(b)(2).

The Authority disagrees that additional hydrogeologic research is required before establishing additional index wells for any aquifer pool. Section 1.14(g) of the Act provides that additional index wells may be established for a pool (in this case, the San Antonio pool), if such additional index wells "aid the regulation of withdrawals from the pool." Nevertheless, the Authority has deleted §711.166(b)(2) as it was originally proposed and term permits will now only be interrupted based on index wells J-17and J-27.

Section 711.168(b)

SAWS commented on § 711.168 (b) of the proposed rules which references index well TD 69-47-306 when discussing the availability of water for emergency permits. SAWS asserts that reference to any index wells, other than those mentioned in the Act, should be avoided unless the supporting hydrogeologic research under § 1.14(g) has been conducted. SAWS suggests amending § 711.168(b) by deleting the reference to well TD 69-47-306.

This comment has been rendered moot by nature of the fact that the Authority has deleted references to well TD 69-47-306 in this section.

Section 711.170(b)

SAWS comments on § 711.170 (b) of the proposed rules which references index well TD 69-47-306 when discussing the availability of water for monitoring well permits. SAWS asserts that reference to any index wells, other then those mentioned in the Act, should be avoided unless the supporting hydrogeologic research under § 1.14(g) has been conducted. SAWS suggests changing § 711.170(b) by deleting the reference to well TD 69-47-306.

The Authority received the above-referenced comment and disagrees that additional hydrogeologic research is required before establishing additional index wells for any aquifer pool. Section 1.14(g) of the Act provides that additional index wells may be established for a pool (in this case, the San Antonio pool), if such additional index wells "aid the regulation of withdrawals from the pool." In light of the above discussion, Authority staff has not modified § 711.170(b).

Section 711.172

Suzanne (last name unknown), with the East Medina County Special Utility District, commented on § 711.172, the proportional reduction rule. She states the decreases in water permits will not allow for the growth rates in Medina County. While she supports farmers getting two acre-feet, she is concerned that Medina County does not have funds like SAWS to transfer water from Canyon Lake or down from the coast.

The Authority received the above-referenced comment and agrees that the proportional adjustment process, which is mandated by the Act, will require some entities to obtain supplemental water supplies. The Authority believes this to be an unavoidable outcome mandated by the Act. The reductions required by the Act and implemented in § 711.172 will require many aquifer users to raise funds to secure other aquifer permits or alternative water sources. The Authority declines to modify § 711.172 in response to this comment.

Section 711.172(b)(1)

Several individuals and entities submitted comments regarding the definition of "historical average minimum" found at § 711.172(b)(1). That definition, as proposed, read as follows:

Historical average minimum-the minimum amount of groundwater from the aquifer, as determined by the authority, that an applicant, who operated a well in three or more years during the historical period, shall be authorized to withdraw in an initial regular permit equal to the average amount of groundwater withdrawn annually during the historical period calculated as follows:

Figure: 31 TAC Chapter 711 Preamble-1

Frenzal, of Bexar County Water and Control Improvement District #10, complains that the definition is hard to follow and needs reworking.

Cemex claims the definition of "historical average minimum" is flawed and should include a mechanism by which longer-term existing users (having operated a well for more than 10 years in the historical period) could eliminate up to five consecutive years of use from the calculation of their historical average. Cemex alleges that a straightforward average calculation prejudices longer-term existing users, as opposed to shorter-term existing users, because longer-term users would be unable to omit earlier years of lesser usage from the period used to calculate their historical average. Cemex points to a prior version of the Authority's rules which contained a mechanism like the one now sought by Cemex. Cemex alleges that the fact that the Authority previously considered such a mechanism to be a viable option, coupled with what Cemex believes to be the Texas Legislature's supposed acquiescence and affirmance of the Authority rule containing that mechanism, divests the Authority of the power to substitute a different rule at this time. Cemex also asserts that policy considerations support the use of a mechanism by which longer-term existing users could eliminate up to five consecutive years of use from the calculation of their historical average instead of a straightforward average calculation.

Making the same arguments as Cemex, Vulcan argues in favor of a mechanism allowing long-term existing users to elect to omit a period of time from the calculation used to arrive at their historical average. Vulcan also contends that the Authority's calculation method will use the "historical average minimum" as the "starting point" from which permits will be adjusted downward.

TFB contends that the calculation of the historical average minimum provided in this section skews the average downward for each well that has operated for three or more years during the historical period. TFB asserts the calculation includes years during the historical period when no water was withdrawn by the well under consideration and also includes the year of the well's installation in the calculation. This approach is inappropriate, according to TFB, because the above-mentioned years should not be added in the calculation in light of the fact that § 1.16(e) of the Act refers to the historical average minimum as the average of the amount of water actually withdrawn annually during the historical period. TFB suggests two alternative methods. Under the first method, TFB would: (1) exclude the year of well installation, any years in which no pumping occurred, and all years for which annual pumping fell outside three standard deviations of the statistical root mean square value; and (2) then calculate the average for the remaining years. A second method, which is the one apparently preferred by TFB, would be to establish a threshold amount of withdrawal for which years having a lesser withdrawal volume would not be included in the calculation of the average.

Johnson commented that the end result of the rule is that long-term users who are required to use an average over a long period of time are treated less fairly than short-time users. However, he stated that given the difficult compromise that had to be achieved to address allocation of historical use consistent with statutory guidelines, the rules as drafted and published are as close to the middle ground as can be accomplished.

Using arguments similar to those made by the TFB, Earl & Brown asserts that the minimum should not be calculated by including years during the historical period when no water was withdrawn by the well owner under consideration.

Kosub commented that the definition should be revised to make it clear that the concept of waste is incorporated and considered when an applicant's historical average minimum is calculated. Pursuant to the definition, as proposed, the minimum is based, in part, upon the "total aggregate withdrawals from the well (in AF/annum) during the historical period." Kosub wishes to see the definition revised to make it clear that withdrawals during the historical period which were wasted and not put to a beneficial use are not included in the calculation of the historical average minimum.

With respect to the comment from Frenzel, the Authority acknowledges that the definition is somewhat lengthy and hard to follow. The Authority believes, however, that this is, to some degree, an unavoidable consequence of the highly technical and complex subject matter. As explained more fully below, however, the Authority has slightly revised the definition in § 711.172(b)(1) in response to another comment and in order to clarify it.

The Authority disagrees with the comments submitted by Cemex and Vulcan. The Authority does not believe it is bound, as a matter of law or policy, to re-adopt its prior rule which included a mechanism by which longer-term existing users (having operated a well for more than 10 years in the historical period) could eliminate up to five consecutive years of use from the calculation of their historical average. The Authority declines to include such a mechanism in § 711.172(b)(1) or in the Chapter 711 rules generally because the Authority now believes that such a mechanism lacks a solid statutory basis. This change in position is based, in part, upon the Authority's two-and-a-half years of additional experience in working with the Act since the original rule, now sought by Cemex and Vulcan, was adopted. Section 1.16(e) of the Act states, in part, that an existing user "who operated a well for three or more years during the historical period shall receive a permit for at least the average amount of water withdrawn annually during the historical period ." (Emphasis added.) The Authority believes this wording sets out a straightforward averaging process, and does not allow for the exclusion of certain amounts of "water withdrawn annually during the historical period." For the same reasons, the Authority declines to adopt the TFB's and Earl & Brown's suggestions that certain years of low or no pumpage during the historical period be excluded from the calculation of the historical average minimum. The Authority agrees with the comments by Johnson.

It is true that the Authority has, in the past, taken the position now advocated by Cemex and Vulcan. However, the Authority, just like any administrative agency, must have the right and power to repeal, amend or revise its own rules. Administrative agencies may, when reconsidering the relevant facts, alter past interpretations or overturn past administrative rulings and practices. American Trucking Assns., Inc. v. Atchison, T. & S. F. R. Co., 387 U.S. 397, 416 (1967). "Agencies need sufficient latitude to adjust their rules to reflect actual experience and may even reverse their thinking if necessary." U.S. v. An Article of Drug Neo-Terramycin, 540 F.Supp. 363, 373 (N.D. Texas 1982)(citations omitted), aff'd 725 F.2d 986 (5th Cir. 1984).

The Authority does not agree with the assertion that the Texas Legislature has acquiesced or affirmed the Authority's prior rule on this point and that the Authority is therefore legally prohibited from abandoning its old rule or reinterpreting the Act. The old rule cited by Cemex and Vulcan, 31 TAC,§ 703.1, was adopted by the Authority effective March 1, 1998. The rule was invalidated by a Final Judgment issued by the Honorable Judge Joseph H. Hart on December 17, 1998 in a lawsuit styled Living Springs Artesian Springs, Ltd. v. Edwards Aquifer Authority, Cause No. 98-02644, in the District Court of Travis County, Texas, 353rd Judicial District. Thus, when the Texas Legislature convened the following month, in January 1999, there was no such rule in effect that the Legislature could, as Cemex and Vulcan contend, "endorse." As a result, there is no basis to contend that the Legislature "agreed," "acquiesced," or "affirmed" the Authority's prior rule.

The Authority also disagrees with Vulcan's assertion that the method used by the Authority to calculate permit amounts will use the "historical average minimum" as the "starting point" from which permits will then be adjusted downward. Section 711.172(g) describes the proportional adjustment process and uses, as the starting point from which permits are proportionately adjusted downward, each applicant's maximum historical use.

The Authority notes that the comment from Kosub is well taken. The intent of the Authority has always been that water withdrawn during the historical period, but which was not put to a beneficial use (i.e., was wasted), cannot be included in an applicant's "total aggregate withdrawals during the historical period" for purposes of calculating the applicant's historical average minimum. The Authority believes that the wording of § 711.172(b)(1) should be revised to make this intent clearer and that the definition could otherwise be clarified. Accordingly, the Authority has revised the rule to read as follows:

Historical average minimum- an amount, as determined by the authority, for an applicant who operated a well in three or more years during the historical period, equal to the average amount of groundwater withdrawn annually during the historical period and put to beneficial use, calculated as follows:

Figure: 31 TAC Chapter 711 Preamble-2

Section 711.172

Patterson asserts that proportional adjustment, without a "buydown" of permits to reach the 450,000 acre-feet cap, can be accomplished by amending § 711.172 so as to issue an interruptible permit to each applicant for the difference between the applicant's "minimum" permit (either the "historical average minimum" or the "irrigator minimum") and the applicant's permit calculated after the "first proportional reduction" to 450,000 af/y. Patterson suggests this approach because: (1) "buy-downs" are cost prohibitive; (2) the interruptible rights that would be issued to municipal, industrial, and agricultural permit applicants would become very valuable; and (3) the Authority has better uses to which the "buydown" funds could be put.

Authority staff received the above-referenced comment and disagrees with it. The Authority has concluded that an interruptible initial regular permit for the "step-up" amount may have the potential to negatively affect the Authority's other aquifer management programs that are designed to maintain aquifer and springflow levels. Additionally, the interruptibility criteria may well render this part of the initial regular permit unsuitable for the purposes of use for many permittees because the water would not be legally available for withdrawal after the aquifer dropped below certain index well levels earlier in the year and would likely remain unavailable for the remainder of the year. Finally, Authority assessment of this approach indicates that the overall economic effect on the region is less if a "step-up amount" withdrawal reduction program is adopted instead of the issuance of interruptible permits for the "step-up amount." In light of the above discussion, the Authority has not modified § 711.172.

Section 711.172(b)(2)

TFB submitted comments regarding proposed rule § 711.172(b)(2), which defines the "irrigator minimum" as follows:

(2) Irrigator minimum-the minimum amount of groundwater from the aquifer, as determined by the authority, that an applicant for irrigation use shall be authorized to withdraw in an initial regular permit equal to two acre-feet times each acre of land the applicant, or his contract user, prior user, or former existing user actually irrigated in any one calendar year during the historical period if the applicant, or his contract user, prior user, or former existing user:

(A) owned, leased, or otherwise had a legal right to irrigate the land during the historical period; and

(B) owned the well from which the land was irrigated.

TFB alleges that the rule is not clear and seeks clarification as to whether the applicant may have owned the well during the historical period, but leased the irrigated property and the use of the well to a prior user, contract user or former existing user.

The Authority agrees with the comment, in part. The applicant must be an existing user. See § 711.98(a); Act § 1.16(a). However, because the ownership of points of withdrawal and places of use has not been static since the inception and closure of the historical period, the Authority must account for transfers and the impact of transfers on existing user status. There are several types of possible "existing users." First, the classical existing user would be a person who on June 1, 1993, owned an existing aquifer well with historical usage and filed a declaration. This type of existing user would have been the sole owner of the well during the historical period and would not yet have transferred his interest in the well at the time the Authority issues the final initial regular permit. A second type of existing user would be a transferee of the first category of existing user where the transferee acquired his interest in the well during the historical period and has not yet transferred his interest in the well. A third type of existing user is one who acquired his interest in the well after the close of the historical period. A well owner who transferred his interest in the well during the historical period is referred to by the Authority as a "prior user." See § 711.1(4). An existing user who transferred his interest in the well after the close of the historical period is referred to by the Authority as a "former existing user." As defined by § 711.1(2), an existing user is a person, or the successor in interest of such a person, who, on June 1, 1993, owned an existing aquifer well with historical usage. The existing user is free to have owned the well during the historical period, but leased the irrigated property and the use of the well to a contract user, prior user, or former existing user. (If such a lease was made to a prior user or former existing user, then the prior user or former existing user would also be considered a contract user.) A contract user is defined in § 711.1(1) as a person who, during the historical period, withdrew and placed to beneficial use aquifer water pursuant to a contract or other legal right obtained from a prior user or existing user who owned the existing well. Thus, a contract user cannot have been the owner of the well and § 711.172(b)(2) is misleading to the extent it suggests the contract user must have owned the well. In light of the TFB comment and in order to make the definition more easily understandable, the Authority has modified § 711.172(b)(2) to read:

(2) Irrigator minimum- an amount, as determined by the authority, for an applicant for irrigation use, equal to two acre-feet times each acre of land the applicant, or his contract user, prior user, or former existing user actually irrigated in any one calendar year during the historical period if:

(A) the applicant, or his contract user, prior user, or former existing user owned, leased, or otherwise had a legal right to irrigate the land during the historical period; and

(B) the applicant, or his prior user or former existing user owned the well from which the land was irrigated.

Section 711.172(b)(3)(C)

Frenzel and SAWS commented on § 711.172(b)(3)(C), which states:

(3) Maximum historical use (MHU)-the amount of groundwater from the aquifer as determined by the authority that, unless proportionally adjusted, an applicant for an initial regular permit is authorized to withdraw equal to the greater of the following, as may be applicable: . . .

(C) for an applicant who has beneficial use without waste during the historical period, but, due to the applicant's activities not having been commenced and in operation for a full calendar year, the applicant does not have beneficial use for a full calendar year, the applicant's extrapolated maximum beneficial use calculated as follows: the amount of groundwater that would normally have been placed to beneficial use without waste by the applicant for a full calendar year during the historical period for the applied for purpose had the applicant's activities been commenced and in operation for a full calendar year during the historical period.

Frenzel expresses concern that the "extrapolation" allowed by this rule unfairly treats existing users with less than one year's full use during the historical period more favorably than long-term existing users.

SAWS urges "stricter adherence" to § 1.16(e) of the Act for less than one-year users and suggests that the rule read:

(b)(3)(C) for an applicant who has beneficial use without waste during the historical period for less than a full year, the amount of water that would normally be beneficially used without waste for the intended purpose for a calendar year.

The Authority disagrees with the Frenzel comment. The basis for this determination is that the Authority believes the extrapolation called for in the rule is directly mandated by § 1.16(e) of the Act, which states: "If a water user does not have historical use for a full year, then the authority shall issue a permit for withdrawal based on an amount of water that would normally be beneficially used without waste for the intended purpose for a calendar year."

The Authority also disagrees with the SAWS comment. Rather than merely parroting what § 1.16(e) of the Act says, the Authority believes that it is helpful and appropriate to "flesh out" in more detail the process by which the "extrapolation" for a full year's use will take place. In light of the above discussion, Authority staff has not modified §711.172(b)(3)(C).

Section 711.172(b)(4)

SAWS commented upon § 711.172(b)(4) of the proposed rules, which defines "operate a well" as "the withdrawal of groundwater from a well for a beneficial use." SAWS requests clarification regarding the commencement of a well's operation. SAWS suggests the well's operation begins after it is completed, regardless of withdrawals. Accordingly, SAWS proposes that § 711.172(b)(4) read:

(b)(4) Operate a well- the capability to withdraw groundwater from a well for a beneficial use.

Authority staff received the above-referenced comment and disagrees with it. Section 1.16(e) of the Act provides that, in order to be eligible for the historical average minimum, an applicant must have "operated a well for three or more years during the historical period." The Authority interprets this provision to mean that the applicant must have actually withdrawn water from a well in at least three years. The Authority disagrees with SAWS' suggestion that the phrase "operate a well" should include years in which a well was capable of being operated, but was not actually used to withdraw water. In light of the above discussion, the Authority has not modified § 711.172(b)(4).

Section 711.172

SAWS comments on § 711.172 in general. SAWS requests clarification of the calculations found within § 711.172 and asserts the rules should incorporate hypothetical examples. SAWS suggests grouping the terms "PA-1 amount +" and "SUAs" together, appropriately, in Figure 31 TAC §711.172(g)(8)(A).

The Authority received the above-referenced comment and disagrees with it. The basis for this determination is the commenter did not specify how the calculations found within § 711.172 could be clarified. Given the complexity of the subject matter, the Authority acknowledges that these rules are unavoidably difficult. It is not clear, however, that adding hypothetical examples would add to the clarity to the rules. In light of the above discussion, Authority staff has not modified § 711.172 in response to this comment.

Section 711.172(b)(5)

Earl & Brown commented upon proposed rule §711.172(b)(5), which, as proposed, provided:

(5) Step-up amount (SUA)-the amount of groundwater from the aquifer as determined by the authority that an applicant for an initial regular permit is authorized to withdraw equal to the difference between an applicant's irrigator or historical average minimum, if any, and the applicant's PA-1 amount as determined in subsection(g)(5) of this section.

Earl & Brown comments that the provision should clarify whether the step-up amount is to be "stepped up" with firm or uninterruptible rights or otherwise.

Authority staff received the above-referenced comment and believes the commenter misapprehends the nature of the definition. The definition of the step-up amount (SUA) in §711.172(b)(5) is but one part of the method used to calculate initial regular permit amounts. The definition does not specify whether SUAs are interruptible, nor should it. Instead, all groundwater withdrawal amounts authorized in initial regular permits may be subject to interruption, as is made clear in § 711.98(g). The Authority concedes, however, that the definition of SUA could be made clearer. Further, the Authority believes a provision must be made to account for irrigators who qualify for both of the minimums in order to ensure that such irrigators get the benefit of whichever minimum is larger. Accordingly, the Authority has modified § 711.172(b)(5) to read:

(5) Step-up amount (SUA)- the difference between an applicant's irrigator or historical average minimum, if any, and the applicant's PA-1 amount as determined in subsection(g)(5) of this section. Where an irrigator applicant qualifies for both an irrigator minimum and an historical average minimum, the SUA shall be equal to the difference between whichever of the applicant's minimums is greater and the applicant's PA-1 amount.

Sections 711.172 - 711.176

The TFB submitted comments generally regarding §§ 711.172-711.176 of the proposed rules. TFB maintains that these rules, operating together, do not guarantee the withdrawal minimums the Act expressly provides in § 1.16(e) which states:

An existing irrigation user shall receive a permit for not less that two acre-feet a year for each acre of land the user actually irrigated in any one calendar year during the historical period. An existing user who has operated a well for three or more years during the historical period shall receive a permit for at least the average amount of water withdrawn annually during the historical period. (Emphasis added by TFB).

TFB contends this is non-negotiable language which the Authority cannot ignore. However, according to TFB, proposed rules §§ 711.172-711.176 allow an applicant to receive an initial regular permit authorizing withdrawal of groundwater, from the aquifer, in an amount below that which the Act guarantees.

The Authority received the above-referenced comment, and disagrees with it. The Act does not guarantee that the initial regular permit minimums would always be able to be withdrawn in any particular year. In fact, sections of the Act, such as § 1.26 relating to critical period management, may specifically result in the inability to withdraw, in a year, the full groundwater amount allowed in an initial regular permit due to aquifer or springflow conditions.

Further, there is only one scenario under which certain applicants may not receive permits entitling them to withdraw the full minimum amount-if an applicant qualifies for a minimum, a PA-2 amount is calculated, and the applicant's minimum is greater than his PA-2 amount, then that applicant will receive a permit allowing him to withdraw only his PA-2 amount. It should be noted that the Authority believes there is a reasonable chance that this scenario will never occur because the Authority's withdrawal reduction (buy-down) program will be effective in achieving the cap. It should be further noted that even if this scenario does occur the applicant will be compensated by the Authority for the fair market value of the difference between the applicant's minimum and PA-2 amount.

Finally, the Authority needs the ability to implement this scenario, if necessary, based upon the realities of the permit program. Based upon its extensive review of the initial regular permit applications on file, it appears entirely likely that the aggregate of all permit minimums will exceed the 450,000 acre-foot cap, yet section 1.14(b) of the Act mandates that permitted withdrawals may not exceed the 450,000 cap. Thus, the Authority must have a mechanism in place in order to achieve the cap. Given that compensation is provided for the amount below the minimum which the applicant may not withdraw, the Authority believes the approach taken by it in § 711.176 is a reasonable way to achieve the cap. In light of the above discussion, the Authority has not modified §§711.172 through 711.176 in response to this comment.

Section 711.172(b)(1)

CPS made comments relating to § 711.172(b)(1)of the proposed rules. CPS suggests the Authority make clear what partial years are to be considered when determining the historical average minimum under this section.

The Authority received the above-referenced comment and disagrees with it. The basis for this determination is that § 711.172(b)(1) provides that any operation, by withdrawal of groundwater, of a well in a year counts as a year for purposes of determining eligibility for the historical average minimum. Therefore, there is no need to identify or provide for special calculation provisions for partial years. Accordingly, the Authority has not modified §711.172(b)(1) in response to this comment.

Section 711.172(b)(3)

CPS commented upon proposed rule § 711.172(b)(3). CPS contends the Authority should clarify how partial years will be treated when determining permitted amounts, particularly for maximum historic use amounts under this section.

Authority staff received the above-referenced comment and disagrees with it. The basis for this determination is that § 711.172(b)(3) provides that for purposes of determining maximum historical use, full calendar years are to be used. If a year is a partial year, the maximum historical use, as with any other full calendar year, is the maximum aggregate withdrawal for that full or partial year. The rule does not allow for the interpolation of the maximum historical use for a partial year except for the special statutorily-derived (1.16(e)) single partial year rule in § 711.172(b)(3)(C). Therefore, there is no need to identify or provide for special calculation provisions for partial years. Accordingly, the Authority has not modified § 711.172(b)(3).

Section 711.172(b)(5)

TFB submitted comments regarding proposed rule § 711.172(b)(5). TFB asserts the definition of "step-up amount" is ambiguous. As a result, TFB suggests defining the numerical amount as a mathematical equation.

The Authority received the above-referenced comment and agrees in part with it. The basis for this determination is the description for "step-up amount" found in § 711.172(g)(6) is derived from a mathematical equation. The Phase-1 proportionally adjusted amount is described in § 711.172(g)(5). However, as noted above, the Authority staff has modified § 711.172(b)(5) to clarify it.

Section 711.172(e)

Bragg submitted comments relating to proposed rule § 711.172(e), which states:

(e) Duty to Proportionally Adjust. If the total aggregate maximum historical use of all initial regular permits exceeds the amount of groundwater available for permitting in § 711.164(a) of this title (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits), the board shall, pursuant to this section, proportionally adjust the maximum historical use of each permit.

Bragg contends proportional adjustment for agriculture is detrimental and possibly fatal to the industry primarily because an amount less than 2 acre-feet is: 1) not enough to raise annual crops; and 2) will destroy investments and equipment, land purchases, and make improvement impossible. Bragg contends that § 1.14(d) of the Act gives the Authority the power to raise the amount of groundwater available for permitting.

Authority staff received the above-referenced comment and is unable to formulate a clear "agree or disagree" response. The commenter notes several detrimental effects that may be caused to the agricultural economy due to the operation of the rule. However, the commenter does not recommend that the rule be changed. Instead, Bragg recommends that the Authority invoke some other power, with which it has been endowed, to increase the groundwater available for permitting pursuant to § 1.14(d) of the Act. The Authority notes that § 1.16(e) of the Act requires that, if necessary, it perform a proportional adjustment process on all applicants for an initial regular permit. The legislature has not, however, authorized the Authority to consider economic impacts in the proportional adjustment process. Yet (as explained above) the Authority is required to conduct a proportional adjustment process if necessary under § 1.16(e) of the Act. The Authority agrees that § 1.14(d) creates a process whereby the groundwater available for permitting may be increased. However, the Authority may invoke this procedure only after a certain technical basis is determined to exist and after certain consultation procedures have been complied with. The decision to invoke § 1.l4(d) will be available in the event the technical data base is found to exist and the procedural steps occur. The Authority notes that it has proposed other rules to implement § 1.14(d) in subchapter K of this title. The Authority encourages the commenter to comment on those rules at the appropriate time. Accordingly, the Authority has not modified proposed § 711.172(e).

Section 711.172(g)(7) and (g)(8)

TFB submitted comments regarding proposed rule § 711.172(g)(7) and § 711.172(g)(8), which states:

(7) Phase 2-Proportional Adjustment Factor. If the total of all PA-1 amounts plus all step-up amounts remaining after the Board has issued agreed order pursuant to § 711.180 of this title (relating to Voluntary Waiver of Applications for Initial Regular Permits) exceeds 450,000 acre feet per annum, then the board shall calculate a Phase-2 proportional adjustment factor ("PA-2 Factor") as follows:

(8) Phase 2-Proportionally Adjusted Amount. The board shall then calculate a Phase-2 proportionally adjusted amount ("PA-2 amount") for each applicant issued an initial regular permit as follows:

(A) For all applicants eligible to receive a step-up amount:

(B) For all applicants not eligible to receive a step-up amount:

TFB suggests the formula given in § 711.172(g)(8)(A) may be incorrectly written. As written, TFB asserts that the formula applies the PA-2 factor only to the PA-1 amounts, not to SUAs. The formula is presently written as follows:

PA-2 amount = (PA-1 amounts + SUAs) - (PA-2 Factor * PA-1 amounts + SUAs).

TFB contends that the present formula reduces algebraically in the following manner:

PA-2 amount = (PA-1 amounts + SUAs) - (PA-2 Factor * PA-1 amounts + SUAs) which = (PA-1 amounts + SUAs) - (PA-2 Factor * PA-1 amounts) - SUAs

= PA-1 amounts - (PA-2 Factor * PA-1 amounts)

= PA-1 amounts * (1- PA-2 Factor)

TFB states that the reduction occurs because the PA-2 Factor does not operate on the SUAs term as written. The SUAs terms cancel each other. Therefore, the equation reduces down to that equation given in § 711.176(g)(8)(B). TFB maintains that if this is the intended equation for § 711.176(g)(8)(A), then the equations in § § 711.176(g)(8)(A) and 711.176(g)(8)(B) are identical eradicating the need for separate statements in (8)(A) and (B).

On the other hand, if the intent was to reduce the total quantity "(PA-1 amounts + SUAs)" proportionally to the multiplier "PA-2 Factor," the formula should be written as:

PA-2 amount = (PA-1 amounts + SUAs)

which = (PA-1 amounts + SUAs)

= PA-1 amounts * (1- PA-2 Factor) + SUAs * (1- PA-2 Factor)

= (PA-1 amounts + SUAs) * (1 - PA-2 Factor).

TFB asserts these two mathematical approaches give different results. The latter equation would produce a proportional reduction of the total quantity (PA-1 amount + SUA's) rather than only PA-1 amounts.

Grammatically, TFB contends that referring to "PA-1 amounts" and "SUAs" as plural was likely unintended because the formula appears to apply to an individual permit amount-a single quantity.

The Authority received the above-referenced comments and agrees with them. The determination is based on the intention that the formula be written as follows: PA-2 amount = (PA-1 amount + SUA) - (PA-2 Factor x (PA-1 amount + SUA)). In light of the above discussion, Authority staff has modified § 711.172(g)(8)(A).

Section 711.172(g)(9)

TFB submitted comments regarding proposed § 711.172(g)(9), which states:

the board shall issue a final initial regular permit to each eligible applicant...as provided in § 711.176(c)..."

TFB asks whether § 711.176(c) is the correct cross-reference. According to TFB, § 711.176(c) only applies to the issuance of permits where the irrigator or historical average minimum is greater than the PA-1 amount. TFB indicated that it is assuming that permits will be issued to applicants that do not have an irrigator minimum or a historical average minimum.

The Authority received the above-referenced comment and agrees with it. The basis for this determination is that § 711.176 should be amended to include a provision disposing of applications for those who do not qualify for a step-up amount or whose irrigator or historical average minimum is less than their PA-1 or PA-2 amount. By including these provisions, the Authority has reorganized §711.176 and §711.172(g)(9) to read:

§ 711.172(g)(9):

the board shall issue an initial regular permit to each eligible applicant...as provided in § 711.176(b) and (c). . ."

Section 711.176(b):

(b) If the aggregate maximum historical use of all applicants to be issued initial regular permits exceeds the amount of groundwater available for permitting in §711.164(a) of this chapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits), then an applicant shall receive an initial regular permit authorizing the withdrawal of groundwater from the aquifer in the following amount:

(1) if the applicant does not qualify for an irrigator or historical average minimum, and no PA-2 amount is calculated pursuant to § 711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), then in an amount equal to the applicant's PA-1 amount as calculated in §711.172(g)(4) and(5);

(2) if the applicant does not qualify for an irrigator or historical average minimum, and a PA-2 amount is calculated pursuant to § 711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), then in an amount equal to the applicant's PA-2 amount;

(3) if the applicant qualifies for an irrigator or historical average minimum, no PA-2 amount is calculated pursuant to § 711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), and the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) is less than the applicant's PA-1 amount as calculated in §711.172(g)(4) and (5), then in an amount equal to the applicant's PA-1 amount;

(4) if the applicant qualifies for an irrigator or historical average minimum, no PA-2 amount is calculated pursuant to § 711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), and the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) is greater than the applicant's PA-1 amount as calculated in §711.172(g)(4) and (5), then in an amount equal to the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two);

(5) if the applicant qualifies for an irrigator or historical average minimum, a PA-2 amount is calculated pursuant to § 711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), and the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) is less than the applicant's PA-2 amount, then in an amount equal to the applicant's PA-2 amount; or

(6) if the applicant qualifies for an irrigator or historical average minimum, a PA-2 amount is calculated pursuant to § 711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), and the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) is greater than the applicant's PA-2 amount, then in an amount equal to the applicant's PA-2 amount. In such a case, the difference between the applicant's PA-2 amount and the applicable minimum may not be withdrawn by the applicant, but instead, the authority shall provide to the applicant compensation for this amount at the fair market value as that term is defined in §11.0275, Texas Water Code (relating to Fair Market Value).

(c) Initial regular permits issued by the board pursuant to this section may be issued with a provisional groundwater withdrawal amount until the total amount of groundwater permitted for withdrawal in initial regular permits is finally determined following an opportunity for contested case hearings on all initial regular permit applications, as provided in § 711.172(f) of this chapter (relating to Proportional Adjustment of Initial Regular Permits). The authority may periodically issue Proportional Adjustment Orders in order to assure that the amount of groundwater permitted for withdrawal in initial regular permits does not exceed the amount available for permitted withdrawals under section 711.164 of this chapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits).

Section 711.174(b)

SAWS commented upon § 711.174(b) of the proposed rules. SAWS suggests that the proposed rule should reference only the Act or defined rule. SAWS proposes changing § 711.174 to read:

(b)...retirement of initial regular permits

The Authority received the above-referenced comment and disagrees with it. The basis for this determination is that the reference to proposed subchapter H of chapter 715 will provide a useful cross-reference to the relevant rules that will apply the equal percentage reduction process. By giving interested persons notice of the future location of these rules, such persons will be able to monitor developments in this regard and better understand the organization of the Authority's permit program rules. In light of the above discussion, Authority staff has not modified §711.174.

Section 711.176(b)

TFB commented on proposed rule § 711.176(b), which, as proposed, read:

(b) If the aggregate maximum historical use of all applicants for initial regular permits does not exceed the amount of groundwater available for permitting in § 711.164(a) of this title (relating to groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits), than an applicant shall receive an initial regular permit authorizing the withdraw of groundwater from the aquifer in the following amounts: . . .

TFB acknowledges § 711.176(b) provides that an the applicant will receive an initial regular permit authorizing an amount not less than the irrigator minimum, or the historical average minimum, if the aggregate maximum historical use of all applicants for initial regular permits exceeds 450,000 acre-feet each calendar year. However, the section does not expressly mention what amounts applicants with no irrigator or historical average minimum will be permitted to withdraw. TFB assumed applicants not qualifying for irrigation or historical average minimums will be issued an initial regular permit for their Phase 2 Proportionally Adjusted Amount. TFB also asserts that this section does not clearly define what amount an irrigator will be authorized to withdraw if his PA-2 amount exceeds his irrigation minimum. Therefore, TFB suggests the user should receive a permit for his PA-2 amount.

Additionally, TFB maintains that § 711.176(b) does not ensure that those minimums TFB considers to be guaranteed by the Act can actually be withdrawn. TFB argues that § 711.176(c) will, in fact, drop an irrigation user below his two-acre feet per acre irrigated.

As noted above, the Authority has modified §§ 711.172 and 711.176 in response to this and other comments.

Section 711.176(c)(1)

TFB submitted commented regarding proposed rule § 711.176(c)(1), which, as proposed, read:

(c) If the irrigator or historical average minimum is greater than the PA-1 amount as calculated in § 711.172(g)(5) of this title (relating to Proportional Adjustment of Initial Regular Permits), the groundwater withdrawal amount in a final initial regular permit shall be issued by the board at the irrigator or historical average minimum as follows:

First, TFB asserts that the threshold in the initial paragraph (provided above) is ambiguous. The paragraph seems to require that either the irrigator minimum or the historical average minimum exceed the PA-1 amount because it is triggered if a permit holder's (here an Initial Regular Permit) "irrigator or historical average minimum" is greater than a PA-1 amount. TFB contends it is uncertain whether this is the meaning that is intended since the same phraseology, "irrigator minimum" and "historical average minimum," is used elsewhere (TFB cites § § 711.172(b)(5), 711.172(g)(6)) in a vague manner and not capable of precise application numerically. Therefore, according to TFB, it is unclear whether the use of the wording in this section is intentionally or merely repetitive. Second, TFB maintains the section's requirement that the board issue "a final initial regular permit at the irrigator or historical average minimum" is unclear as well. TFB specifically poses the question of whether the section is meant to read "at the irrigator or historical average minimum, respectively" in reference to previous references to various different quantities. TFB is assuming an applicant may be able to receive assignment of both values.

As noted above, the Authority has modified §711.176 (c).

Section 711.176(c)

TFB submitted comments in reference to § 711.176(c)(1), which states:

(c) If the irrigator or historical average minimum is greater that the PA-1 amount as calculated in § 711.172(g)(5) of this title (relating to Proportional Adjustment of Initial Regular Permits), then the groundwater withdrawal amount in a final initial permit shall be issued by the board at the irrigator or historical average minimum as follows:

(1) the PA-1 amount shall be authorized to be withdrawn as a permitted withdrawal pursuant to the groundwater withdrawal schedule required by § 711.178 of this title (relating to Groundwater Withdrawal Schedules); and. . .

TFB comments that this section purports to allow a permit holder to withdraw the full PA-1 amount although it may be assumed, in some instances, the PA-1 amount will be greater than the PA-2 amount. TFB argues that this seems contradictory and ambiguous especially in light of what §§ 711.176(c)(2) and 711.176(c)(3) require.

The Authority has received the above-referenced comment, and agrees in part with it. As noted above, the Authority has modified § 711.176 in order to, among other things, specify when permit holders will be authorized to withdraw their PA-1 amount and when they will be authorized to withdraw their PA-2 amount.

Section 711.176(c)

TFB commented upon § 711.176(c)(2) of the proposed rules which states:

(c) If the irrigator or historical average minimum is greater that the PA-1 amount as calculated in § 711.172(g)(5) of this title (relating to Proportional Adjustment of Initial Regular Permits), then the groundwater withdrawal amount in a final initial permit shall be issued by the board at the irrigator or historical average minimum as follows:

(2) to the extent necessary, in order to satisfy groundwater available for permitted withdrawals under § 711.164(a) of this title (relating to Groundwater Available for Groundwater for Initial and Regular Permits), the step-up amount as calculated in § 711.172 (b)(5) and (g)(6) of this title (relating to Proportional Adjustment of Initial Regular Permits) may not be withdrawn; and . . .

TFB contends this section precludes withdrawal of step-up amounts as necessary to satisfy the 450,000 acre-foot limit of § 711.164(a), yet does not indicate a quantitative definition of the manner in which the Authority intends to implement the phrase "to the extent necessary."

SAWS also commented upon proposed rules § 711.176(c)(1), (c)(2), and (c)(3), concurrently. SAWS asserts concern that the step up amount is held hostage and unusable. Therefore, SAWS suggests that, if compensation is paid under a PA-2 adjustment, all water for which compensation is not received is available for pumping. SAWS proposes the following changes to § 711.176:

ELIMINATE (c)(1) and (c)(2)

and (c)(3) renumbered (c)(1) to read: less the amount that is proportionally adjusted pursuant to ...(relating to Fair Market Value).

The Authority has received the above-referenced comments, and agrees in part and disagrees in part. The section as written is intended to allow PA-1 water and step-up water to be withdrawn by a permittee as long as and until the aggregate amount of groundwater available for permitting (i.e. the 1.14(b) "cap") is exceeded by the issuance of initial regular permits. Because § 1.14(b) of the Act prevents the Authority from issuing initial regular permits in an amount that exceeds the cap, PA-1 and step-up water will not necessarily always be available to be withdrawn. If the Authority is required to engage in a phase-2 proportional adjustment, the amount of PA-1 water and step-up water (as may be applicable depending on if an applicant qualifies for a minimum or not) that is phase-2 proportionally adjusted will no longer be able to be withdrawn. However, the Authority agrees that the section could be more clearly stated. In light of the above discussion, Authority staff has modified § 711.176 as noted above.

Section 711.176(c)(2) and (3)

The BC Farm Bureau submitted comments regarding § 711.176(c)(2) and (3). The BC Farm Bureau maintains the two-acre foot irrigator minimum should not be subject to a proportional adjustment. According to the BC Farm Bureau, the Act does not provide compensation in lieu of statutory minimums, but it does provide certain guarantees for historical users, which should extend to agricultural users.

Frenzel also inquired into whether the irrigator minimum was subject to proportional adjustment.

The MC Farm Bureau submitted comments regarding proposed rules § 711.176 (c) (2) and (c)(3), concurrently. MC Farm Bureau contends the Legislature recognized the importance of the two acre foot minimum for agriculture and that minimum should not be subject to a proportional adjustment. MC Farm Bureau claims that while the Act does provide historical users some specified "guarantees," it does not make provisions for compensation in lieu of statutory minimums.

The Authority has received the above-referenced comments and disagrees with them. The basis for this determination is that by virtue of § 1.14(b) of the Act, the Authority may not issue initial regular permits in an amount that exceeds the caps established in those sections. At the same time, by virtue of § 1.16(e) of the Act, the Authority is required to issue certain initial regular permits with either an irrigator minimum or historical average minimum, if applicable. In the event the aggregate of the minimums exceeds the cap, the Authority must have a procedure to adjust the permits to equal the cap. The legislature in § 1.16(e) of the Act provided a procedure known as "proportional adjustment" to accomplish this objective. In addition, as for the payment of proportionally adjusted water below a recognized minimum in order to meet the § 1.14(b) cap, the legislature (in § 1.29(a)(1) of the Act) authorized an allocation procedure for the costs of this withdrawal reduction process. Accordingly, the Authority has not modified § 711.176 in response to these comments.

Section 711.176(c)(3)

TFB commented upon § 711.176(c)(3) of the proposed rules, which states:

(c) If the irrigator or historical average minimum is greater than the PA-1 amount as calculated in § 711.172(g)(5) of this title (relating to Proportional Adjustment of Initial Regular Permits), then the groundwater withdrawal amount in a final initial permit shall be issued by the board at the irrigator or historical average minimum as follows:

(3) the amount that is proportionally adjusted pursuant to § 711.172(g)(7) and (8) of this title (relating to Proportional Adjustment of Initial Regular Permits) may not be withdrawn, but instead the authority shall provide compensation for this amount at the fair market value as that term is defined in § 11.0275, Texas Water Code, (relating to Fair Market Value).

TFB claims the section is ambiguous and/or mathematically imprecise. Specifically, TFB argues there is not clear identification as to what numerical quantity is intended by the phrase "the amount that is proportionally adjusted pursuant to § 711.172(g)(7) and (8)." If applied literally, TFB contends this wording identifies the quantity "(PA-1 amounts + SUAs)" in Section 711.176(g)(8)(A), and "(PA-1)" in § 711.172(g)(8)(B) because those are the quantities "proportionally adjusted" by a proportional reduction. Alternatively, TFB asserts the reference perhaps should be to the quantitative amount of the proportional reduction-the decrement of the reduction.

Furthermore, TFB explains that questions regarding whether or not § 711.172(g)(8)(A) is correctly written/worded, extends to § 711.176(c)(3). TFB contends that if the right hand side of the equation in § 711.172(g)(8)(A) is written as

(PA-1 amounts + SUAs) - (PA-2 Factor * PA-1 amounts + SUAs)

then the quantity acted on by proportional reduction is only the quantity "PA-1 amounts," it being the only quantity multiplied by "PA-2 Factor." On the other hand, if the right hand side should have been written as

(PA-1 amounts + SUAs) - PA-2 Factor * (PA-1 amounts + SUAs),

then the quantity" (PA-1 amounts + SUAs)" is the quantity proportionally reduced.

As stated above, TFB claims this ambiguity extends to § 711.176(c)(3). Specifically, it extends to the part of the subsection which states that the quantity that is "proportionally adjusted" may not be withdrawn, and to that portion which states that permit holders will be compensated for this quantity.

The Authority received the above-referenced comment and agrees with it in part, and disagrees in part. The basis for this determination is that the comments really relate to §711.172(g)(7) and (8) which, as noted above, have been revised. In light of the above discussion, Authority staff, as discussed above for § 711.172(g)(7) and § 711.172(g)(8), has modified § 711.172(g)(8)(A), but not § 711.176 in response to this comment.

Section 711.176(c)(3)

John (last name unknown) commented on the use of the term "fair market value" in § 711.176(c)(3) in relation to the amount the Authority is required to compensate the landowner when the Authority is required to take away from the two acre feet minimum. He believes the rules should state how that amount is determined and how it is defined.

The Authority received the above-referenced comment, and disagrees with it. The basis for this determination is that the term "fair market value" is defined in § 11.0275, Texas Water Code, to mean as follows:

Whenever the law requires the payment of fair market value for a water right, fair market value shall be determined by the amount of money that a willing buyer would pay a willing seller, neither of which is under any compulsion to buy or sell, for the water in an arm-length transaction and shall not be limited to the amount of money that the owner of the water right has paid or is paying for the water.

The Authority believes that this statutory definition is adequate for purposes of § 711.176. The Authority has not modified § 711.176 in response to this comment.

Section 711.176(c)(3)

Inland, submitted comments relating to proposed rule § 711.176(c)(3). Inland asserts that the Authority's "buy-down" to the 450,000 ac. ft. level is premature and would be extremely costly and detrimental to municipalities. According to Inland, under-allocated municipal interests will transfer money to the irrigators and the over-allocated irrigators will transfer withdrawal permits to the municipalities. Therefore, Inland contends that the Authority has interjected itself into the buy-down so that the base rights that are not being used and cannot otherwise be transferred are legitimately bought and retired.

Authority staff received the above-referenced comment, and disagrees with it. The basis for this determination is that no withdrawal reductions (referred to by the commenter as a "buy-down") to the §1.14(b) cap will occur unless it is required due to the aggregate of the minimums exceeding the §1.14(b) cap. If this occurs, the implementation of the program would not be premature, but instead would occur at the appropriate time as required by the Act. Whether the withdrawal reduction program is "costly and detrimental to municipalities" because they are "under-allocated" and irrigators are "over-allocated" is largely a function of the irrigator and historical average minimums as established by the legislature in § 1.16(e) of the Act. The Authority is unable to affect the initial regular permit "allocation" process by altering the statutorily established minimums in the face of convincing evidence presented by an applicant for an initial regular permit, whether the applicant is an irrigator, municipal or industrial applicant. As for the Authority's "interjection" into the withdrawal reduction process, this is the role that the Authority has been assigned by the legislature through the Act. Finally, for purposes of achieving the §1.14(b) cap, there is no practical difference between the Authority accomplishing the withdrawal reduction by acquiring the waiver by an applicant of its step-up water, base irrigation groundwater, or other categories of water as long as the waiver results in the §1.14(b) cap being achieved. Moreover, after the Authority has issued initial regular permits, the retirement of permitted rights (whether (1) base irrigation groundwater, (2) unrestricted irrigation groundwater of irrigators, or (3) other municipal or industrial rights) may also be implemented to lessen the need for withdrawal reductions to meet the §1.14(b) cap. Accordingly, the Authority has not modified § 711.176 in response to this comment.

Section 711.178

The MC Farm Bureau comments on proposed rule §711.178. The MC Farm Bureau asserts a requirement for withdrawal schedules for irrigators does not serve a useful purpose and would result in unpredictable and unreliable estimates related to water resource management planning. In this regard, it comments that the annual water use report should be sufficient information for the Authority. The MC Farm Bureau is also concerned about the impact of § 711.178(e) on the 2.0 acre-foot per acre per year irrigator minimum and the 110% monthly withdrawal limitation. The MC Farm Bureau suggests either the deletion of §711.178 or the exemption of irrigators from the requirement to submit withdrawal schedules.

Bragg has a similar comment to § 711.178. Bragg comments that agricultural irrigation is based on initial soil moisture (rainfall), evaporation, and specific plant use requirements. Due to the fact rainfall cannot be predicted, either in the short or long term, farmers are unable to predict their irrigation needs. Therefore, Bragg recommends that this paragraph be deleted.

BC Farm Bureau also commented upon proposed rule § 711.178. The BC Farm Bureau contends § 711.178 should be entirely deleted or exempt agricultural users from submitting withdrawal schedules. The BC Bureau maintains requiring the submission of these schedules serves no real purpose and would result in inaccurate estimates and unreliable planning. Further, it argues that the Authority already requires an annual report of groundwater pumping.

Rimkus commented on § 711.178(b), stating the requirement to file, by November 1 of the year after a permit is issued, the amount of water he plans to withdraw each month, is unreasonable. He suggests requiring the following information: 1) what are an irrigator's planting intentions for next year? (acres and crops), and 2) is pre-irrigation planned? Mr. Rimkus states an agriculture expert can take this information and prepare a forecast of the amount of water needed.

Friesenhahn also commented on § 711.178, stating he cannot predict water needs for the following year.

Reagan commented on § 711.178 and believes that it does not follow the legislature's intent. Reagan states there was never any intent to require anyone to meet any schedule for using water. Reagan believes that unless the Authority gets better at predicting the weather, farmers cannot be expected to forecast water usage.

Gilliam Ranch and Gregory and Cora Rothe also commented § 711.178 (e) and (f). Gilliam Ranch and the Rothes maintain that the Act does not give the EAA specific regulatory authority over pumping on a monthly basis. Gilliam and the Rothes are concerned that § 711.178(e) could effectively limit pumping to less than the two acre feet per acre provided by the Act if an irrigator decides to accelerate pumping for the purposes of crop rotation or compensating for dry weather. Gilliam and the Rothes believe predicting water levels is not a reasonable justification for this rule and recommend that § 711.178 (e) and (f) be removed.

TFB also submitted comments relating to § 711.178(e) of the proposed rules. TFB expressed concern over the possibility that this section will undermine the irrigator minimum established in § 1.16(e) of the Act. TFB asserts that a permittee, in any given year, may not actually be able to use his allotted two-acre feet per acre irrigated because in some months, when water is actually needed, the irrigator's use is limited by the schedule that results from pure guesswork. Other months, the irrigators may not need the water due to sufficient rainfall. TFB argues that this limitation is not authorized by the Act and also claims that the Authority did not provide an explanation about how the value of 110% was determined as the appropriate amount.

Gembler also commented on § 711.178 by saying that this rule will not work because irrigators do not know how much it will rain.

Vaughan also comments on § 711.178. Vaughan states that § 711.178 is unworkable from an irrigator's standpoint. First, Vaughan claims the proposed rule requires farmers to guess or speculate what crops will be located in a particular location before such estimations are actually feasible. Specifically, Vaughan addresses § 711.178 (e), which states: "No permittee may withdraw groundwater from the aquifer during any month in excess of 110% of the scheduled monthly amount." Such a provision will adversely affect farming by causing farmers to guess both: (1) the amount of rainfall that will occur and (2) how much water they will require, months in advance. Vaughan argues that the cost of taking time to produce and review paperwork will outweigh the benefits of receiving information that he contends is conjecture at best. As a result, Vaughan predicts that farmers will overestimate their usage early in the year and the carry forward the unused portions of water for the rest of the year.

Grossenbacher also commented on § 711.178 of the proposed rules. He states the rule, in general, is hard to understand. Specifically, under § 711.178, he contends it is nearly impossible for irrigation farmers to provide monthly projections, a year in advance, regarding the amount of water they intend to use as outlined in the proposed rule. SAWS also commented upon proposed rule § 711.178(e) and (f). Specifically, SAWS expresses concern over monthly pumping limits imposed by these subsections. SAWS asserts there is no grant of authority in the Authority's enabling act that allows for withdrawal limits at times other than may be imposed pursuant to a critical period program. It recommends that subsections (e) and (f) be deleted.

CPS also commented upon proposed rule § 711.178(e). CPS objects to the requirement that a permittee may not withdraw groundwater from the aquifer during any month in excess of 110% of this planned monthly amount. CPS asserts this cap is too restrictive because it is not possible to accurately plan water usage a year in advance. CPS suggests one of the following alternatives be considered in lieu of § 711.178(e): (1) the deletion of § 711.178(e); (2) the amendment of § 711.178(e) to allow withdrawal of 125% of the planned monthly amount; or (3) a new § 711.178(g) allowing for a permittee to adjust the monthly schedule on a quarterly or semi-annual basis.

SAWS commented upon proposed rule § 711.178(b). Specifically, SAWS suggests that § 711.178(b) read:

No later than December 20th of the first year after a groundwater withdrawal permit has been issued to a permittee and continuing each year thereafter, a permittee shall file with the Authority an anticipated groundwater withdrawal schedule on a form approved by the Authority containing the following information: . . .

Friesenhahn commented on § 711.178(b)(3) which requires a permittee to provide "any other information as determined by the board or the general manager." He feels this type of general language is unacceptable.

In response to these public comments, the Authority has elected not to adopt § 711.178 at this time and hereby withdraws the rule.

Section 711.180

SAWS submitted comments regarding proposed rule § 711.180. SAWS asserts that the Authority should use only the most generic terms in describing what an applicant may voluntarily waive. According to SAWS, the Authority's current statement, as to restriction in transfer of irrigation rights, will be challenged and does not follow state law regarding disposal of property rights. SAWS suggests amending § 711.180 to read:

...waiver of all or part of an applicant's maximum historical use, PA amount, or step-up amount.

The Authority received the above-referenced comment and disagrees with it. The references to base irrigation and unrestricted irrigation groundwater is necessary to properly delineate the full range of application features that may be waived and to make this section conform to the substantive content of the transfer rules to be found in subchapter L of this chapter that have recently been proposed. Also, inclusion of these types of groundwater, in the application waiver rules, will assist the Authority in its withdrawal reduction and retirement programs. Accordingly, the Authority has not modified § 711.180.

Section 711.220

Menard's remarks involve the cancellation of groundwater withdrawal permits under § 711.220.

The Authority has received the above-referenced comment and is unable to respond to it at this time. The basis for this determination is that this section is not a proposed section under this Final Order Adopting Rules. Section 711.220 is in the process of being proposed in subchapter H of this chapter in another Notice of Proposed Rule of the Authority. The Authority encourages Mr. Menard to comment on § 711.220 at that time.

Section 711.230

SAWS commented upon proposed rule § 711.230. SAWS maintains that water may be stored within the Edwards Aquifer through an "Aquifer Recharge and Storage Permit" for recovery at a later date. According to SAWS such storage should not be misconstrued as wasteful or subject to a waste determination. SAWS proposes that § 711.230 read:

A person may not waste groundwater withdrawn from the aquifer.

The Authority received the above-referenced comment and disagrees with it. The basis for this determination is that if the Authority issues aquifer recharge and storage permits, under other permitting rules of the Authority, it will necessarily have found that the activity will not constitute the waste of groundwater within the aquifer. However, waste can occur due to the injection of water into the Aquifer and the facts, at some time, may show effects on water quality or that the aquifer has no storage capacity in the area injected. The Authority will need to be able to take appropriate enforcement action in such cases. Accordingly, the Authority has not modified § 711.230.

Section 711.232

Schirmer commented upon proposed rule § 711.232 relating to pollution of the aquifer. Schirmer asserts users over the recharge zone to the north of Bexar County continue to engage in new development and meter installation which, he contends, contributes to the pollution of the Aquifer. Schirmer recommends the Authority enforce § 711.232 to limit further pollution.

Menard also commented upon proposed rule § 711.232. Menard believes pollution and building over the recharge zone of the aquifer is a further restriction on his property right and lowers its value. Menard suggests stricter planning, guidance, and enforcement of the section.

Verstraeten also made comments regarding § 711.232. Verstraeten stated his concern regarding municipal water systems' leasing and purchase of pumping rights in Uvalde and Medina Counties pumping out in Bexar County which he believes prematurely lowers Bexar County water levels. Verstraeten requests that any municipal water system that supplies water over the recharge zone should be responsible for any pollution of the aquifer that occurs as a result. Verstraeten suggests enforcement of § 711.232 by the Authority.

Authority staff received the above-referenced comments and agrees with them. The basis for this determination is that the commenters request that the Authority enforce this rule as written. Accordingly, the Authority has not modified § 711.232.

Section 711.234

SAWS made comments regarding proposed rule § 711.234. SAWS is concerned that the Authority makes a distinction that nuisances exist for exempt wells while the same occurrences are permit violations for permitted wells. SAWS suggests the first sentence of § 711.234 be changed to read:

For exempt wells, the following are declared nuisances:

Furthermore, SAWS maintains that water is capable of being stored in the Aquifer, through an "Aquifer Recharge and Storage Permit," for later recovery. SAWS argues that such storage should not be misconstrued as wasteful or subject to a waste determination. Accordingly, SAWS requests that § 711.234 (1) read:

(1) the wasting of groundwater withdrawn from the aquifer;

The Authority received the above-referenced comment and disagrees with it. The basis for this determination is that this section makes no distinction between exempt and non-exempt wells. The owner of any well that withdraws groundwater at a rate in excess of the permitted amounts will be deemed to be a nuisance. As to the comment concerning waste and aquifer recharge and storage permits, the Authority refers the commenter to its response to § 711.230. Accordingly, the Authority has not modified § 711.234.

Section 711.328

Vulcan made comments to proposed § 711.328 relating to transfer of ownership. Section 711.328 is not a proposed rule that is the subject of this Final Order Adopting Rules. Vulcan's comments focus on certain legal arguments related to the nature of an "existing user." Vulcan also suggests clarification of this section and certain amendments.

The Authority has received the above-referenced comment and is unable to respond to the comment at this time. The basis for this determination is that this section is not a proposed section under this Final Order Adopting Rules. Section 711.328 is in the process of being proposed in subchapter L of this chapter in another Notice of Proposed Rule of the Authority. The Authority encourages Vulcan to comment on § 711.328 at that time.

Comments on the Chapter 711 rules generally

Representative Tracy King

Tracy King, State Representative for the 43rd District which includes Medina and Uvalde Counties and four other counties, gave a general comment not directed to any specific rule. He does not favor this legislation and does not like being forced to regulate groundwater. Rep. King wants the Authority to remember two guarantees in the statute: 1) two-acre feet minimum, and 2) the historical minimum guarantees. Rep. King advises the Authority to avoid court challenges by keeping in mind the intent of the legislature.

The Authority received the above-referenced comment and agrees with it. The basis for this determination is that the legislature created two statutory permit minimums in § 1.16(e) of the Act, an irrigator minimum and a historical average minimum. The Authority has accounted for these minimums in §711.172(b)(1) and (2), 711.172(g)(6), and §711.176(b)(1) and (2). No specific action is requested to be taken relative to any particular section of the proposed rules. In light of this, the Authority has not modified any of the proposed rules.

Inland

Inland generally commented on the Chapter 711 rules without reference to any specific rule. Inland asserts the municipalities in the region are being asked to shoulder an inequitable burden because they have not been granted their maximum historical beneficial use while other historical users, who have no current needs, have been given their maximum historical use. Therefore, Inland contends that the Authority is dividing the region through unfair and inequitable treatment of municipal interests and not utilizing legislatively provided mechanisms (§ 1.14(d)) which could ensure fairness.

The Authority received the above-referenced comment and disagrees with it. The basis for this determination is that no existing user of groundwater from the aquifer that will be granted an initial regular permit will likely receive a permit for their maximum historical use. All such permits will likely be issued after a time where the maximum historical use will have been proportionally adjusted. To the extent that the proportional adjustment process may result in an "equitable" or "inequitable" allocation of the water resources from the aquifer is a decision that has already been made by the Texas Legislature by the passage of Edwards Aquifer Authority Act. The Authority, through its rulemaking process, is generally unable to make reallocations of groundwater from the aquifer in a way that is contrary to the intent of the legislature as expressed in the Act. The Authority agrees that § 1.14(d) creates a process whereby the groundwater available for permitting may be increased. However, the Authority may invoke this procedure only after a certain technical basis is determined to exist and after certain consultation procedures have been complied with. The decision to invoke § 1.l4(d) will be available in the event the technical data base is found to exist and the procedural steps occur. Accordingly, the Authority has not modified and proposed sections in chapter 711.

TFB

TFB asserts that the Authority was required by the Texas Private Real Property Rights Preservation Act to prepare a "takings impact assessment" or "TIA" before providing notice of the proposed adoption of the Chapter 711 rules.

The Authority disagrees. Chapter 2007 of the Texas Government Code, also known as the "Texas Private Real Property Rights Preservation Act" ("TPRPRA"), requires governmental entities, under certain circumstances, to prepare a TIA in connection with certain covered categories of proposed governmental actions. Based on the following reasons, the Authority has determined that it need not prepare a TIA in connection with the adoption of these rules.

First, the Authority has made a "categorical determination" that these Chapter 711 rules do not affect vested property rights and, as such, adoption of these rules is not an action that "may result in a taking." The rules at issue here implement a permitting program for the withdrawal of water from the Edwards Aquifer. The Act requires the Authority to implement a permitting system whereby existing users and other potential users of aquifer water may apply for and receive permits issued by the Authority allowing for the withdrawal of groundwater from the aquifer. Other types of permits are also required by the Act for well construction and related work. Certain other withdrawals are exempted by the Act from permitting requirements. The Act also specifies an interim authorization period prior to the issuance by the Authority of final permits during which certain existing users of the aquifer may continue to make withdrawals. The Act imposes a number of restrictions upon the use of the aquifer during the interim authorization period as well as after permits are issued. It also places limits on the ability to transfer permitted or interim authorization rights. These rules are intended to effectuate these various components of the Act.

TPRPRPA makes it clear that a TIA need only be performed when the proposed governmental action is one that "may result in a taking." See id., §§ 2007.043(a), 2007.041(a), 2007.042(a). If an action is one that has no potential to result in a taking, then no TIA need be performed. Adoption of the rules at issue here is not an action that "may result in a taking" for two reasons.

The rules cannot result in the taking of a vested private real property right. Traditional takings doctrine dictates that, in order to constitute a compensable taking, the property right alleged to have been "taken" must rise to the level of a vested right. Prior to the adoption of the Act, a landowner's right to pump groundwater underlying his or her property derived from the common law English Rule, also known as the "Rule of Capture." The rules implement a permitting structure which is admittedly at odds with the Rule of Capture. However, a landowner's common law Rule of Capture right does not rise to the level of a vested property right. Under the common law, water underlying a landowner's property may be reduced to possession by the pumping of another. In other words, a landowner has no right to exclude others from the water underlying his land. As such, the landowner's expectancy of water does not rise to the level of a vested property right which could be "taken" by the passage of these rules and passage of these rules is not an action that may result in a taking.

Additionally, with respect to Edwards Aquifer water, any common law rights a landowner may have had in the past have been effectively abolished by the Legislature within the boundaries of the EAA by the passage of the Act. Under the old common law, a landowner was essentially free to drill a well and pump as much water as he pleased for whatever use and location of use he pleased. Passage of the Act changed the rules within the boundaries of the EAA. The basis for the right to withdraw groundwater under the Act changed from being an incident of the ownership of land to one based on use during the statutorily-defined "historical period." See Act § 1.16. Excluding "exempt" wells, a landowner must now obtain a permit prior to drilling a well and making withdrawals, and this permit may be issued only if there is "water available for permitting" or if certain aquifer conditions are met. Id. §§ 1.14, 1.15, 1.16, 1.18 and 1.19. The rate and total quantity of withdrawals are subject to limitation. Id. § 1.15(d). Regulation under the Act leaves no room for the common law to operate within the boundaries of the EAA with respect to Edwards Aquifer groundwater. As a result, there are no vested property rights which could be taken by the passage of these rules and no TIA need be prepared.

Second, the Authority's action in adopting these rules is an action that is reasonably taken to fulfill an obligation mandated by state law and is thus excluded from the Texas Private Real Property Rights Preservation Act under § 2007.003(b)(4) of the Texas Government Code. See §§ 1.03(4), (9) - (14), (21), 1.07, 1.08(a), 1.10(i)(1), (2), 1.11(a), (b), (d)(2), (8), (10), (11), (h), 1.14(a) - (f), (h), 1.15(a) - (d), 1.16(a), (c) - (h), 1.17(a) - (d), 1.18, 1.19, 1.20, 1.21, 1.22(a)(1)-(4), 1.23(a), 1.25, 1.26, 1.28(b), 1.29, 1.31, 1.32, 1.33, 1.34, 1.35, 1.36 of the Act, §§ 36.101(a), 36.111, 36.113, 36.1131, 36.119(a), 49.211(a), and 49.221 of the Texas Water Code, and § 2001.004(1) of the APA.

This conclusion is directly supported and controlled by the decision in Edwards Aquifer Authority v. Bragg, 21 S.W.3d 375 (Tex. App. San Antonio 2000, pet. filed) ( "EAA v. Bragg" ). In that case, the Plaintiffs sued to invalidate a set of rules adopted by the Authority (the "prior permitting rules") which were substantially similar to these rules and which were designed, like these rules, to implement the Authority's permitting program. The Fourth Court of Appeals held that the Authority's adoption of its prior permitting rules was expressly mandated by the Act and was therefore excepted from the operation of TPRPRPA. The holding in that case controls here.

Third, it is the position of the Authority that all valid actions of the Authority are excluded from the Texas Private Real Property Rights Preservation Act under § 2007.003(b)(11)(C) of the Texas Government Code as actions of a political subdivision taken under its statutory authority to prevent waste or protect the rights of owners of interest in groundwater. Accordingly, a TIA need not be prepared in connection with the proposal of these rules.

Fourth, it is the position of the Authority that the adoption of these rules constitutes an action taken by a governmental entity to "to prohibit or restrict a condition or use of private real private real property if the governmental entity proves that the condition or use constitutes a public or private nuisance as defined by background principles of nuisance and property law of this state." Texas Government Code Annotated, § 2007.003(b)(6).

Fifth, it is the position of the Authority that the adoption of these rules constitutes an action which: "(A) is taken in response to a real and substantial threat to public health and safety; (B) is designed to significantly advance the health and safety purpose; and (C) does not impose a greater burden than is necessary to achieve the health and safety purpose." Texas Government Code Annotated, § 2007.003(b)(13). Accordingly, for the reasons stated above, a TIA need not be performed in connection with the proposal of these rules.

TDA

The TDA commented generally that the Authority should have prepared a "small business effects statement" prior to proposing the adoption of the Chapter 711 rules, pursuant to § 2006.002(d) of the Texas Government Code.

The Authority disagrees for the following reasons. Chapter 2006 of the Texas Government Code, subchapter A, requires state agencies to prepare a small business effects statement (SBES) prior to proposing, for adoption, a rule that would have an adverse economic effect on small businesses. By the statute's express terms, this requirement applies only to a "state agency." The term "state agency" is defined, for the purposes of Chapter 2006, subchapter A, as "a department, board, bureau, commission, division, office, council or other agency of the state." Id. § 2006.001(3).

Section 2006.002 does not apply to the Authority because the Authority does not meet the definition of the term "state agency" as set out forth in Chapter 2006. Section 1.02(a) of the Act creates the Authority as a "conservation and reclamation district" under Article XVI, § 59 of the Texas Constitution. Conservation and reclamation districts created under this authority have long been considered to be "political subdivisions" of the State of Texas. See, e.g., Guaranty Petroleum Corp. v. Armstrong, 609 S.W.2d 529, 530 (Tex. 1980). In Guaranty Petroleum, the Texas Supreme Court explained the difference between political subdivisions and state agencies as follows:

A political subdivision differs from a department, board or agency of the State. A political subdivision has jurisdiction over a portion of the State; a department, board or agency of the State exercises its jurisdiction throughout the State. Members of the governing body of a political subdivision are elected in local elections or are appointed by locally elected officials; those who govern departments, boards or agencies of the State are elected in statewide elections or are appointed by State officials.

Guaranty Petroleum, 609 S.W.2d at 531 (emphasis added).

This opinion makes clear that state agencies are characterized by having statewide jurisdiction and are governed by persons who are elected in statewide elections or are appointed by state officials. Political subdivisions like the Authority, on the other hand, have jurisdiction over only a portion of the state and are governed by persons who are elected in local elections or are appointed by locally elected officials. These principles have been reiterated by the Texas Supreme Court in Lohec v. Galveston County Commissioners Court, 841 S.W.2d 361, 364 (Tex. 1992) (noting that "statewide jurisdiction" is "a trait required of entities recognized as department, boards, or agencies of the state") and Monsanto Company v. Cornerstones Municipal Utility District, 865 S.W.2d 937, 939-40 (Tex. 1993).

Because the Authority has jurisdiction over only a portion of the State and because the members of its governing body are elected in local elections or are appointed by locally elected officials, the Authority is a political subdivision and not a state agency, and is not subject to the SBES requirement found in Chapter 2006 of the Government Code.

No revisions to the Chapter 711 are required in response to this comment.

Subchapter A. DEFINITIONS

31 TAC §711.1

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The new sections are adopted pursuant to the following statutory provisions:

Section 1.01 of the Act contains the findings of the Texas Legislature that the Edwards Aquifer is a distinctive natural resource and that a special regional management district (the Authority) is required for the effective control of the resource to protect terrestrial and aquatic life, domestic and municipal water supplies, existing industries, and the economic development of the state.

Section 1.03(1) defines the "Edwards Aquifer."

Section 1.03(4) of the Act defines "beneficial use" to mean the use of water that is economically necessary for a purpose authorized by law when reasonable intelligence and reasonable diligence are used in applying the water to that purpose. The concept of beneficial use is incorporated into the permitting rules of Chapter 711.

Section 1.03(9) of the Act defines "domestic or livestock use." This concept is incorporated into the exempt well rules found within Chapter 711.

Section 1.03(10) of the Act defines "existing user" as a person who has withdrawn and beneficially used underground water from the aquifer on or before June 1, 1993. This concept is incorporated into the Chapter 711 rules, while also accounting for the beneficial use requirement and including the successors in interest of existing users within the definition.

Section 1.03(11) of the Act defines "industrial use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(12) of the Act defines "irrigation use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(13) of the Act defines "livestock." The Chapter 711 rules incorporate this concept when determining whether a well qualifies as "exempt" from permitting requirements.

Section 1.03(14) of the Act defines "municipal use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(21) of the Act defines "waste." This concept is incorporated into the Chapter 711 rules, while also including other practices which are considered wasteful under the Act or under the long-standing water law concept of beneficial use.

Section 1.07 of the Act provides, in part, that the actions taken by the Authority pursuant to the Act may not be construed as depriving or divesting owners of their ownership rights as landowners in underground water, subject to rules adopted by the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer. These rules further those objectives.

Section 1.08(b) makes it clear that the Authority's powers apply only to water within or withdrawn from the Edwards Aquifer, and not to surface water.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rule governing procedures of the board and the authority." This section provides broad rulemaking authority to implement the various substantive and procedures programs set forth in the Act related to the Edwards Aquifer, including the permitting program.

Section 1.11(b) of the Act requires the Authority to "ensure compliance with permitting, metering, and reporting requirements and . . . regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, requires the Authority to adopt and enforce the Chapter 711 rules.

Section 1.11(d)(2) of the Act empowers the Authority to enter into contracts. Pursuant to this section, the Authority may enter into contracts with well owners concerning meters and reimbursement for same under Subchapter M of the Chapter 711 rules.

Section 1.11(d)(8) of the Act provides that the Authority may close abandoned, wasteful or dangerous wells. The Authority's rules relating to the requirement of beneficial use and the prohibition of waste, as well as the closure of abandoned wells derive in part from this statutory authority.

Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 of the Texas Water Code and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) Chapter 32 imposes certain duties upon drillers of water wells and the owners of those wells. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 derive in part from this statutory authority.

Section 1.11(d)(11) of the Act provides that the Authority may require to be furnished with copies of the water well drillers' logs that are required by Chapter 32 of the Texas Water Code.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. This section essentially provides that the Authority is required to comply with the APA for its rulemaking, even though the Authority is a political subdivision and not a state agency that would generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.13 of the Act requires the Authority to allow credit to be given for certified reuse of aquifer water. The Authority will likely adopt rules implementing this section. This concept is acknowledged in Subchapter F.

Section 1.14(a) of the Act provides that authorizations to withdraw aquifer water shall be limited in order to: protect water quality of the aquifer and surface streams to which the aquifer contributes springflow; achieve water conservation; maximize beneficial use of water from the aquifer; protect aquatic and wildlife habitat as well as federally or state-designated threatened or endangered species; and provide for instream uses, bays and estuaries. The Chapter 711 rules are adopted, in large part, pursuant to these statutory mandates.

Section 1.14(b) of the Act imposes, subject to certain limitations, an initial aquifer withdrawal "cap" for permitted withdrawals of 450,000 acre-feet per year, until December 31, 2007. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(c) of the Act imposes, subject to certain limitations, an aquifer withdrawal "cap" for permitted withdrawals of 400,000 acre-feet per year, beginning January 1, 2008. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(d) of the Act provides that either of the caps listed above may be raised by the Authority if, through studies and implementation of certain strategies, the authority, in consultation with state and federal agencies, determines the caps may be raised.

Section 1.14(e) of the Act requires the Authority to prohibit withdrawals from new wells drilled after the effective date of the Act unless the "caps" are raised and then only on an interruptible basis. The Chapter 711 rules incorporate this prohibition.

Section 1.14(f) of the Act entitles the Authority to allow (or not allow) permitted withdrawals on an uninterruptible basis when certain index wells are at or above the following measurements: for the San Antonio pool, when well J-17 is at or above 650 mean sea level (msl); and for the Uvalde Pool, when well J-27 is at or above 865 msl. The section also imposes the duty on the Authority to limit additional withdrawals to ensure that springflows are not affected during critical drought conditions. The Chapter 711 rules incorporate these concepts by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.14(g) of the Act allows the Authority to, by rule, define other pools within the aquifer in accordance with hydrogeologic research, and to establish index wells for any pool to monitor the level of the aquifer to aid the regulation of withdrawals from the pools.

Section 1.14(h) of the Act provides that the Authority generally must ensure, by December 31, 2012, that continuous minimum springflows of Comal and San Marcos Springs are maintained to protect threatened and endangered species to the extent required by federal law. The Chapter 711 rules incorporate this requirement by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.15(a) of the Act directs the Authority "to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by the Act." This section is implemented through the Chapter 711 rules.

Section 1.15(b) of the Act states that "except as provided by §§1.17 and 1.33 of this article, a person may not withdraw water from the aquifer or begin construction of a well or other works designed for the withdrawal of water from the aquifer without obtaining a permit from the authority." This section is implemented through the Chapter 711 rules.

Section 1.15(c) of the Act allows the Authority to issue regular permits, term permits, and emergency permits. This section is implemented through the Chapter 711 rules.

Section 1.15(d) of the Act provides that each permit issued by the Authority must specify the maximum rate and total volume of water that the user may withdraw annually. This section is implemented through the Chapter 711 rules.

Section 1.16(a) of the Act allows an existing user to apply for an initial regular permit by filing a declaration of historical use documenting use of aquifer water during the period from June 1, 1972 through May 31, 1993. The initial regular permits issued pursuant to the Chapter 711 rules will be based upon such.

Section 1.16(b) of the Act, in conjunction with Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996)(holding that declarations must be filed within six months after the effective date of the Act, i.e., December 30, 1996) provides that an existing user's declaration of historical use (permit application) must be file on or before December 30, 1996, and the applicant must timely pay all application fees required by the Authority. It further requires irrigation applicants to submit, as part of their applications, documentation regarding the number of acres irrigated during the historical period.

Section 1.16(c) of the Act provides that an owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under § 1.33 of the Act is not required to file a declaration of historical use.

Section 1.16(d) of the Act requires the Board to grant an initial regular permit to an existing user who: (1) files a declaration and pays fees as required by this section; and (2) establishes by convincing evidence beneficial use of underground water from the aquifer. This requirement is incorporated into the Chapter 711 rules.

Section 1.16(e) of the Act explains the quantity of water to be permitted under an initial regular permit. Pursuant to this section, if enough water is available, each existing user shall be permitted for an amount equal to the user's maximum beneficial use during the historical period. If there is not enough water available, then this section requires the Authority to "proportionately adjust" permit amounts downward in order to meet the withdrawals "caps" discussed above. However, this section also creates certain "permit minimums" for existing irrigation users and for those existing users who have operated a well for three or more years during the historical period. This section also requires the Authority to extrapolate water use on an annual basis for those existing users who do not have a full year's use during the historical period. These concepts are incorporated into Chapter 711, primarily in Subchapter G.

Section 1.16(f) requires the Authority to equitably treat persons whose historic use was affected by participation in a federal program, such as agricultural subsidy programs. This concept is incorporated in the Chapter 711 rules.

Section 1.16(g) of the Act provides that initial regular permits do not have a term and remain in effect until abandoned, cancelled or retired. These concepts are incorporated in the Chapter 711 rules.

Section 1.16(h) of the Act requires the Authority to notify each permit holder of the limitations to which the permit is subject. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter F.

Section 1.17(a) of the Act provides that a person who, on the effective date of this article, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the Authority, if: "(1) the well is in compliance with all statutes and rules relating to well construction, approval, location, spacing, and operation; and (2) by March 1, 1994, the person files a declaration of historical use on a form as required by the authority."

Section 1.18 of the Act allows the Authority, in certain circumstances, to issue additional regular permits. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.19 of the Act allows the Authority to issue term permits and places certain limitations and conditions on the right to withdraw water under such a permit. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.20 of the Act allows the Authority to issue emergency permits under certain circumstances and subject to certain conditions. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.21 of the Act sets out a process by which the Authority is to implement a plan for reducing the withdrawal "cap" from 450,000 to 400,000 acre-feet per year by January 1, 2008. The plan must be enforceable and include various water conservation, reuse, retirement, and other management measures. If, on or after January 1, 2008, total permitted withdrawals still exceed the 400,000 acre-feet cap, then the Authority must implement "equal percentage reductions" of all permits in order to reach the cap. This concept is implemented in Chapter 711, primarily in Subchapter G.

Section 1.22 of the Act provides that the Authority may acquire permitted aquifer rights to be used for: holding in trust for sale or transfer to other users; holding in trust as a means of managing aquifer demand; holding for resale or retirement as a means of achieving pumping reductions required by the Act; or retiring the rights. These concepts are implemented in part in Chapter 711.

Section 1.23(a) of the Act provides that the Authority may require certain permittees to submit and implement water conservation plans and water reuse plans. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.25 of the Act requires the Authority to develop and implement a comprehensive water management plan and, in conjunction with the SCTWAC and other water districts, to develop and implement a plan for providing alternative water supplies, with oversight by state agencies and the Edwards Aquifer Legislative Oversight Committee. The alternative supplies plan shall consider alternative technologies, financing issues, costs and benefits, and environmental issues. These concepts are implemented, in part, in Chapter 711, primarily through Subchapter F.

Section 1.26 of the Act requires the Authority to prepare and coordinate implementation of a critical period management plan which meets certain, enumerated criteria. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.29 of the Act authorizes the imposition of various types of fees on various types of permits. The Chapter 711 rules acknowledge this fee provision, primarily in Subchapter E.

Section 1.31 of the Act provides that nonexempt well owners must install and maintain meters or alternative measuring devices to measure the flow rate and cumulative amount of water withdrawn from each well. These concepts are implemented in the Chapter 711 rules.

Section 1.32 of the Act requires permittees to submit annual water use reports to the Authority. This section is acknowledged in Subchapter F.

Section 1.33 of the Act provides the criteria for exempt wells -- i.e., wells that produce no more than 25,000 gallons of water per day for domestic and livestock use and that are not within or serving a subdivision requiring platting. The section explains that such wells are exempt from metering requirements. However, such wells must be registered with the Authority. These concepts are implemented in Chapter 711.

Section 1.34 of the Act imposes certain limitations upon the ways in which aquifer water and/or water rights may be transferred (alienated). First, aquifer water must be used within the Authority's boundaries. Second, the section allows the Authority to establish rules by which a person may install water conservation equipment and sell the water conserved. Third, the section further provides that a holder of a permit for irrigation use may not transfer more than 50 percent of the irrigation rights initially permitted and that the user's remaining irrigation water rights must be used in accordance with the original permit and must pass with transfer of the irrigated land. These concepts are implemented, in part, in Chapter 711.

Section 1.35 of the Act prohibits: withdrawing aquifer water except as authorized by a permit; violating permit terms or conditions; wasting aquifer water; polluting or contributing to the pollution of the aquifer; or violating the Act or an Authority rule. These concepts are implemented in Chapter 711.

Section 1.36 of the Act empowers the Authority to enter orders enforcing the terms and conditions of permits, orders, or rules, and to draft rules suspending permits for failure to pay required fees or violations of permits, orders or rules. These concepts are implemented, in part, in Chapter 711.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This rulemaking is in furtherance of this legislative mandate.

Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711derive in part from this statutory authority and implement this chapter and the supporting rules.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.101(a) empowers the Authority to make and enforce rules to provide for conserving, preserving, protecting, and recharging of the groundwater in order to, among other things, prevent waste and carry out the duties provided elsewhere in Chapter 36. This requirement is implemented, in large part, through Chapter 711.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.111 requires the Authority to require aquifer users to keep and maintain reports of drilling, equipping, and completing water wells and the production and uses of groundwater. Chapter 711 implements these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. The section further specifies the permitted format and contents of permit applications, and lays out criteria for the district to consider when ruling on a permit application. The section also provides that permits may be issued subject to the district's rules and other restrictions. The Chapter 711 rules incorporate these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.1131 specifies what may be included as elements of a permit issued by a district.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.115 provides that no person may drill a well, alter the size of a well or well pump, or operate a well without first obtaining a permit from the Authority.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that drilling a well without a required permit or operating a well at a higher rate of production than the rate approved for the well is declared to be illegal, wasteful per se, and a nuisance. This concept is incorporated into Chapter 711, primarily in the definition of waste found in § 711.1.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.211(a) endows districts such as the Authority with the "functions, powers, authority, rights, and duties that will permit accomplishment of the purposes for which it was created or the purposes authorized by the constitution, this code, or any other law." This broad delegation of powers is incorporated into the Chapter 711 rules.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.221 empowers representatives of the Authority to enter land and perform tests and other inspections. This authority is incorporated into Chapter 711, primarily in § 711.416.

16 TAC, Chapter 76. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation (TDLR).) The TDLR's rules implementing Chapter 32 are found at 16 TAC, Chapter 76. These rules impose numerous duties upon well drillers and well owners related to well construction, operation, and plugging. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 implement, in part, the rules found in 16 TAC, Chapter 76.

§711.1.Definitions.

The following words and terms, when used in this chapter, shall have the following meanings, unless the context clearly indicates otherwise:

(1)

Contract user--A person who:

(A)

withdrew or purchased groundwater from the aquifer during the historical period pursuant to a contract or other legal right obtained from a prior user or an existing user, from an existing well owned by the prior user or an existing user; and

(B)

placed the groundwater to beneficial use.

(2)

Existing user--A person or the successor in interest of a such a person, who, on June 1, 1993, owned an existing well from which groundwater from the aquifer had been withdrawn and placed to beneficial use during the historical period,

(3)

Historical use--The lawful withdrawing and placing to beneficial use of groundwater from the aquifer during the historical period.

(4)

Prior user--A person who owned an existing well during the historical period and withdrew groundwater from the aquifer from the well and placed it to beneficial use during the historical period, and during the historical period conveyed the ownership interest in the well to another person.

(5)

Producing well--A well from which groundwater from the aquifer is capable of being withdrawn for a beneficial use.

(6)

Waste --

(A)

Withdrawal of groundwater from the aquifer at a rate and amount that causes or threatens to cause intrusion into the reservoir of water unsuitable for agricultural, gardening, domestic or stock-raising purposes;

(B)

The flowing or producing of wells from the aquifer if the water produced is not used for a beneficial purpose;

(C)

Escape of groundwater from the aquifer to any other reservoir that does not contain groundwater;

(D)

Pollution or harmful alteration of groundwater in the aquifer by salt water or other deleterious matter admitted from another stratum or from the surface of the ground;

(E)

Willfully or negligently causing, suffering or permitting groundwater from the aquifer to escape into any river, creek, natural watercourse, depression, lake, reservoir, drain, sewer, street, highway, road, or road ditch, or onto any land other than that of the owner of the well, unless:

(i)

such discharge is authorized by permit, rule, or order issued by the commission under Chapter 26, Water Code; and

(ii)

after discharge, the groundwater from the aquifer is beneficially used by the existing user, applicant or permittee making the discharge;

(F)

Groundwater pumped from the aquifer for irrigation that escapes as irrigation tailwater onto land, other than that of the well owner, unless permission has been granted by the occupant of the land receiving the discharge;

(G)

For water produced from an artesian well, "waste" has the meaning assigned by the Water Code, §11.205;

(H)

Constructing, installing, drilling, equipping, completing, altering, operating, maintaining, or making withdrawals from a well without a required permit;

(I)

Withdrawal of water that is substantially in excess of the volume or rate reasonably required for a beneficial use; or

(J)

Irrigation use of groundwater from the aquifer in a volume per irrigated acre that is so insufficient that a crop could not have been reasonably cultivated and produced.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007355

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter B. GENERAL PROVISIONS

31 TAC §§711.10, 711.12, 711.14

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The new sections are adopted pursuant to the following statutory provisions:

Section 1.01 of the Act contains the findings of the Texas Legislature that the Edwards Aquifer is a distinctive natural resource and that a special regional management district (the Authority) is required for the effective control of the resource to protect terrestrial and aquatic life, domestic and municipal water supplies, existing industries, and the economic development of the state.

Section 1.03(1) defines the "Edwards Aquifer."

Section 1.03(4) of the Act defines "beneficial use" to mean the use of water that is economically necessary for a purpose authorized by law when reasonable intelligence and reasonable diligence are used in applying the water to that purpose. The concept of beneficial use is incorporated into the permitting rules of Chapter 711.

Section 1.03(9) of the Act defines "domestic or livestock use." This concept is incorporated into the exempt well rules found within Chapter 711.

Section 1.03(10) of the Act defines "existing user" as a person who has withdrawn and beneficially used underground water from the aquifer on or before June 1, 1993. This concept is incorporated into the Chapter 711 rules, while also accounting for the beneficial use requirement and including the successors in interest of existing users within the definition.

Section 1.03(11) of the Act defines "industrial use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(12) of the Act defines "irrigation use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(13) of the Act defines "livestock." The Chapter 711 rules incorporate this concept when determining whether a well qualifies as "exempt" from permitting requirements.

Section 1.03(14) of the Act defines "municipal use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(21) of the Act defines "waste." This concept is incorporated into the Chapter 711 rules, while also including other practices which are considered wasteful under the Act or under the long-standing water law concept of beneficial use.

Section 1.07 of the Act provides, in part, that the actions taken by the Authority pursuant to the Act may not be construed as depriving or divesting owners of their ownership rights as landowners in underground water, subject to rules adopted by the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer. These rules further those objectives.

Section 1.08(b) makes it clear that the Authority's powers apply only to water within or withdrawn from the Edwards Aquifer, and not to surface water.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rule governing procedures of the board and the authority." This section provides broad rulemaking authority to implement the various substantive and procedures programs set forth in the Act related to the Edwards Aquifer, including the permitting program.

Section 1.11(b) of the Act requires the Authority to "ensure compliance with permitting, metering, and reporting requirements and . . . regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, requires the Authority to adopt and enforce the Chapter 711 rules.

Section 1.11(d)(2) of the Act empowers the Authority to enter into contracts. Pursuant to this section, the Authority may enter into contracts with well owners concerning meters and reimbursement for same under Subchapter M of the Chapter 711 rules.

Section 1.11(d)(8) of the Act provides that the Authority may close abandoned, wasteful or dangerous wells. The Authority's rules relating to the requirement of beneficial use and the prohibition of waste, as well as the closure of abandoned wells derive in part from this statutory authority.

Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 of the Texas Water Code and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) Chapter 32 imposes certain duties upon drillers of water wells and the owners of those wells. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 derive in part from this statutory authority.

Section 1.11(d)(11) of the Act provides that the Authority may require to be furnished with copies of the water well drillers' logs that are required by Chapter 32 of the Texas Water Code.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. This section essentially provides that the Authority is required to comply with the APA for its rulemaking, even though the Authority is a political subdivision and not a state agency that would generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.13 of the Act requires the Authority to allow credit to be given for certified reuse of aquifer water. The Authority will likely adopt rules implementing this section. This concept is acknowledged in Subchapter F.

Section 1.14(a) of the Act provides that authorizations to withdraw aquifer water shall be limited in order to: protect water quality of the aquifer and surface streams to which the aquifer contributes springflow; achieve water conservation; maximize beneficial use of water from the aquifer; protect aquatic and wildlife habitat as well as federally or state-designated threatened or endangered species; and provide for instream uses, bays and estuaries. The Chapter 711 rules are adopted, in large part, pursuant to these statutory mandates.

Section 1.14(b) of the Act imposes, subject to certain limitations, an initial aquifer withdrawal "cap" for permitted withdrawals of 450,000 acre-feet per year, until December 31, 2007. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(c) of the Act imposes, subject to certain limitations, an aquifer withdrawal "cap" for permitted withdrawals of 400,000 acre-feet per year, beginning January 1, 2008. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(d) of the Act provides that either of the caps listed above may be raised by the Authority if, through studies and implementation of certain strategies, the authority, in consultation with state and federal agencies, determines the caps may be raised.

Section 1.14(e) of the Act requires the Authority to prohibit withdrawals from new wells drilled after the effective date of the Act unless the "caps" are raised and then only on an interruptible basis. The Chapter 711 rules incorporate this prohibition.

Section 1.14(f) of the Act entitles the Authority to allow (or not allow) permitted withdrawals on an uninterruptible basis when certain index wells are at or above the following measurements: for the San Antonio pool, when well J-17 is at or above 650 mean sea level (msl); and for the Uvalde Pool, when well J-27 is at or above 865 msl. The section also imposes the duty on the Authority to limit additional withdrawals to ensure that springflows are not affected during critical drought conditions. The Chapter 711 rules incorporate these concepts by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.14(g) of the Act allows the Authority to, by rule, define other pools within the aquifer in accordance with hydrogeologic research, and to establish index wells for any pool to monitor the level of the aquifer to aid the regulation of withdrawals from the pools.

Section 1.14(h) of the Act provides that the Authority generally must ensure, by December 31, 2012, that continuous minimum springflows of Comal and San Marcos Springs are maintained to protect threatened and endangered species to the extent required by federal law. The Chapter 711 rules incorporate this requirement by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.15(a) of the Act directs the Authority "to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by the Act." This section is implemented through the Chapter 711 rules.

Section 1.15(b) of the Act states that "except as provided by §§1.17 and 1.33 of this article, a person may not withdraw water from the aquifer or begin construction of a well or other works designed for the withdrawal of water from the aquifer without obtaining a permit from the authority." This section is implemented through the Chapter 711 rules.

Section 1.15(c) of the Act allows the Authority to issue regular permits, term permits, and emergency permits. This section is implemented through the Chapter 711 rules.

Section 1.15(d) of the Act provides that each permit issued by the Authority must specify the maximum rate and total volume of water that the user may withdraw annually. This section is implemented through the Chapter 711 rules.

Section 1.16(a) of the Act allows an existing user to apply for an initial regular permit by filing a declaration of historical use documenting use of aquifer water during the period from June 1, 1972 through May 31, 1993. The initial regular permits issued pursuant to the Chapter 711 rules will be based upon such.

Section 1.16(b) of the Act, in conjunction with Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996)(holding that declarations must be filed within six months after the effective date of the Act, i.e., December 30, 1996) provides that an existing user's declaration of historical use (permit application) must be file on or before December 30, 1996, and the applicant must timely pay all application fees required by the Authority. It further requires irrigation applicants to submit, as part of their applications, documentation regarding the number of acres irrigated during the historical period.

Section 1.16(c) of the Act provides that an owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under § 1.33 of the Act is not required to file a declaration of historical use.

Section 1.16(d) of the Act requires the Board to grant an initial regular permit to an existing user who: (1) files a declaration and pays fees as required by this section; and (2) establishes by convincing evidence beneficial use of underground water from the aquifer. This requirement is incorporated into the Chapter 711 rules.

Section 1.16(e) of the Act explains the quantity of water to be permitted under an initial regular permit. Pursuant to this section, if enough water is available, each existing user shall be permitted for an amount equal to the user's maximum beneficial use during the historical period. If there is not enough water available, then this section requires the Authority to "proportionately adjust" permit amounts downward in order to meet the withdrawals "caps" discussed above. However, this section also creates certain "permit minimums" for existing irrigation users and for those existing users who have operated a well for three or more years during the historical period. This section also requires the Authority to extrapolate water use on an annual basis for those existing users who do not have a full year's use during the historical period. These concepts are incorporated into Chapter 711, primarily in Subchapter G.

Section 1.16(f) requires the Authority to equitably treat persons whose historic use was affected by participation in a federal program, such as agricultural subsidy programs. This concept is incorporated in the Chapter 711 rules.

Section 1.16(g) of the Act provides that initial regular permits do not have a term and remain in effect until abandoned, cancelled or retired. These concepts are incorporated in the Chapter 711 rules.

Section 1.16(h) of the Act requires the Authority to notify each permit holder of the limitations to which the permit is subject. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter F.

Section 1.17(a) of the Act provides that a person who, on the effective date of this article, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the Authority, if: "(1) the well is in compliance with all statutes and rules relating to well construction, approval, location, spacing, and operation; and (2) by March 1, 1994, the person files a declaration of historical use on a form as required by the authority."

Section 1.18 of the Act allows the Authority, in certain circumstances, to issue additional regular permits. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.19 of the Act allows the Authority to issue term permits and places certain limitations and conditions on the right to withdraw water under such a permit. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.20 of the Act allows the Authority to issue emergency permits under certain circumstances and subject to certain conditions. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.21 of the Act sets out a process by which the Authority is to implement a plan for reducing the withdrawal "cap" from 450,000 to 400,000 acre-feet per year by January 1, 2008. The plan must be enforceable and include various water conservation, reuse, retirement, and other management measures. If, on or after January 1, 2008, total permitted withdrawals still exceed the 400,000 acre-feet cap, then the Authority must implement "equal percentage reductions" of all permits in order to reach the cap. This concept is implemented in Chapter 711, primarily in Subchapter G.

Section 1.22 of the Act provides that the Authority may acquire permitted aquifer rights to be used for: holding in trust for sale or transfer to other users; holding in trust as a means of managing aquifer demand; holding for resale or retirement as a means of achieving pumping reductions required by the Act; or retiring the rights. These concepts are implemented in part in Chapter 711.

Section 1.23(a) of the Act provides that the Authority may require certain permittees to submit and implement water conservation plans and water reuse plans. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.25 of the Act requires the Authority to develop and implement a comprehensive water management plan and, in conjunction with the SCTWAC and other water districts, to develop and implement a plan for providing alternative water supplies, with oversight by state agencies and the Edwards Aquifer Legislative Oversight Committee. The alternative supplies plan shall consider alternative technologies, financing issues, costs and benefits, and environmental issues. These concepts are implemented, in part, in Chapter 711, primarily through Subchapter F.

Section 1.26 of the Act requires the Authority to prepare and coordinate implementation of a critical period management plan which meets certain, enumerated criteria. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.29 of the Act authorizes the imposition of various types of fees on various types of permits. The Chapter 711 rules acknowledge this fee provision, primarily in Subchapter E.

Section 1.31 of the Act provides that nonexempt well owners must install and maintain meters or alternative measuring devices to measure the flow rate and cumulative amount of water withdrawn from each well. These concepts are implemented in the Chapter 711 rules.

Section 1.32 of the Act requires permittees to submit annual water use reports to the Authority. This section is acknowledged in Subchapter F.

Section 1.33 of the Act provides the criteria for exempt wells -- i.e., wells that produce no more than 25,000 gallons of water per day for domestic and livestock use and that are not within or serving a subdivision requiring platting. The section explains that such wells are exempt from metering requirements. However, such wells must be registered with the Authority. These concepts are implemented in Chapter 711.

Section 1.34 of the Act imposes certain limitations upon the ways in which aquifer water and/or water rights may be transferred (alienated). First, aquifer water must be used within the Authority's boundaries. Second, the section allows the Authority to establish rules by which a person may install water conservation equipment and sell the water conserved. Third, the section further provides that a holder of a permit for irrigation use may not transfer more than 50 percent of the irrigation rights initially permitted and that the user's remaining irrigation water rights must be used in accordance with the original permit and must pass with transfer of the irrigated land. These concepts are implemented, in part, in Chapter 711.

Section 1.35 of the Act prohibits: withdrawing aquifer water except as authorized by a permit; violating permit terms or conditions; wasting aquifer water; polluting or contributing to the pollution of the aquifer; or violating the Act or an Authority rule. These concepts are implemented in Chapter 711.

Section 1.36 of the Act empowers the Authority to enter orders enforcing the terms and conditions of permits, orders, or rules, and to draft rules suspending permits for failure to pay required fees or violations of permits, orders or rules. These concepts are implemented, in part, in Chapter 711.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This rulemaking is in furtherance of this legislative mandate.

Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711derive in part from this statutory authority and implement this chapter and the supporting rules.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.101(a) empowers the Authority to make and enforce rules to provide for conserving, preserving, protecting, and recharging of the groundwater in order to, among other things, prevent waste and carry out the duties provided elsewhere in Chapter 36. This requirement is implemented, in large part, through Chapter 711.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.111 requires the Authority to require aquifer users to keep and maintain reports of drilling, equipping, and completing water wells and the production and uses of groundwater. Chapter 711 implements these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. The section further specifies the permitted format and contents of permit applications, and lays out criteria for the district to consider when ruling on a permit application. The section also provides that permits may be issued subject to the district's rules and other restrictions. The Chapter 711 rules incorporate these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.1131 specifies what may be included as elements of a permit issued by a district.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.115 provides that no person may drill a well, alter the size of a well or well pump, or operate a well without first obtaining a permit from the Authority.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that drilling a well without a required permit or operating a well at a higher rate of production than the rate approved for the well is declared to be illegal, wasteful per se, and a nuisance. This concept is incorporated into Chapter 711, primarily in the definition of waste found in § 711.1.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.211(a) endows districts such as the Authority with the "functions, powers, authority, rights, and duties that will permit accomplishment of the purposes for which it was created or the purposes authorized by the constitution, this code, or any other law." This broad delegation of powers is incorporated into the Chapter 711 rules.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.221 empowers representatives of the Authority to enter land and perform tests and other inspections. This authority is incorporated into Chapter 711, primarily in § 711.416.

16 TAC, Chapter 76. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation (TDLR).) The TDLR's rules implementing Chapter 32 are found at 16 TAC, Chapter 76. These rules impose numerous duties upon well drillers and well owners related to well construction, operation, and plugging. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 implement, in part, the rules found in 16 TAC, Chapter 76.

§711.12.Activities Requiring a Permit.

(a)

Except as provided in § 711.14 of this title (relating to Withdrawals Not Requiring a Groundwater Withdrawal Permit) and subsection (b) of this section, a person desiring to engage in any of the following activities is required to obtain a permit from the Authority before the commencement of the activity:

(1)

withdraw groundwater from the aquifer;

(2)

construct, install, drill, equip, complete, alter, operate, or maintain a well, or other works, designed for the withdrawal of groundwater from the aquifer;

(3)

construct, install, drill, equip, complete, alter, operate, or maintain a well, or other works, designed for the monitoring of the water quality or level of the aquifer,

(4)

equip, complete, alter, operate, or maintain a well pump installed or to be installed on a well designed for the withdrawal of groundwater from the aquifer;

(5)

construct, install, drill, equip, complete or alter a well or other works designed to withdraw groundwater from an aquifer other than the Edwards Aquifer, but that intersects the Edwards Aquifer;

(6)

recharge water into the aquifer; or

(7)

store water within the aquifer.

(b)

The requirement to obtain a well construction permit under subsection (a)(2)-(4) of this section does not apply to the performance of routine operation and maintenance after construction and installation of a well if the well is:

(1)

an existing non-exempt well that qualifies for interim authorization status under the Act, § 1.17, and subchapter D of this chapter (relating to Interim Authorization);

(2)

an existing non-exempt well for which a groundwater withdrawal permit has been issued by the board; or

(3)

an existing exempt well.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007356

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter E. PERMITTED WELLS

31 TAC §§711.90, 711.92, 711.94, 711.96, 711.98, 711.100, 711.102, 711.104, 711.108, 711.110, 711.112, 711.116, 711.118

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The new sections are adopted pursuant to the following statutory provisions:

Section 1.01 of the Act contains the findings of the Texas Legislature that the Edwards Aquifer is a distinctive natural resource and that a special regional management district (the Authority) is required for the effective control of the resource to protect terrestrial and aquatic life, domestic and municipal water supplies, existing industries, and the economic development of the state.

Section 1.03(1) defines the "Edwards Aquifer."

Section 1.03(4) of the Act defines "beneficial use" to mean the use of water that is economically necessary for a purpose authorized by law when reasonable intelligence and reasonable diligence are used in applying the water to that purpose. The concept of beneficial use is incorporated into the permitting rules of Chapter 711.

Section 1.03(9) of the Act defines "domestic or livestock use." This concept is incorporated into the exempt well rules found within Chapter 711.

Section 1.03(10) of the Act defines "existing user" as a person who has withdrawn and beneficially used underground water from the aquifer on or before June 1, 1993. This concept is incorporated into the Chapter 711 rules, while also accounting for the beneficial use requirement and including the successors in interest of existing users within the definition.

Section 1.03(11) of the Act defines "industrial use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(12) of the Act defines "irrigation use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(13) of the Act defines "livestock." The Chapter 711 rules incorporate this concept when determining whether a well qualifies as "exempt" from permitting requirements.

Section 1.03(14) of the Act defines "municipal use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(21) of the Act defines "waste." This concept is incorporated into the Chapter 711 rules, while also including other practices which are considered wasteful under the Act or under the long-standing water law concept of beneficial use.

Section 1.07 of the Act provides, in part, that the actions taken by the Authority pursuant to the Act may not be construed as depriving or divesting owners of their ownership rights as landowners in underground water, subject to rules adopted by the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer. These rules further those objectives.

Section 1.08(b) makes it clear that the Authority's powers apply only to water within or withdrawn from the Edwards Aquifer, and not to surface water.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rule governing procedures of the board and the authority." This section provides broad rulemaking authority to implement the various substantive and procedures programs set forth in the Act related to the Edwards Aquifer, including the permitting program.

Section 1.11(b) of the Act requires the Authority to "ensure compliance with permitting, metering, and reporting requirements and . . . regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, requires the Authority to adopt and enforce the Chapter 711 rules.

Section 1.11(d)(2) of the Act empowers the Authority to enter into contracts. Pursuant to this section, the Authority may enter into contracts with well owners concerning meters and reimbursement for same under Subchapter M of the Chapter 711 rules.

Section 1.11(d)(8) of the Act provides that the Authority may close abandoned, wasteful or dangerous wells. The Authority's rules relating to the requirement of beneficial use and the prohibition of waste, as well as the closure of abandoned wells derive in part from this statutory authority.

Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 of the Texas Water Code and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) Chapter 32 imposes certain duties upon drillers of water wells and the owners of those wells. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 derive in part from this statutory authority.

Section 1.11(d)(11) of the Act provides that the Authority may require to be furnished with copies of the water well drillers' logs that are required by Chapter 32 of the Texas Water Code.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. This section essentially provides that the Authority is required to comply with the APA for its rulemaking, even though the Authority is a political subdivision and not a state agency that would generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.13 of the Act requires the Authority to allow credit to be given for certified reuse of aquifer water. The Authority will likely adopt rules implementing this section. This concept is acknowledged in Subchapter F.

Section 1.14(a) of the Act provides that authorizations to withdraw aquifer water shall be limited in order to: protect water quality of the aquifer and surface streams to which the aquifer contributes springflow; achieve water conservation; maximize beneficial use of water from the aquifer; protect aquatic and wildlife habitat as well as federally or state-designated threatened or endangered species; and provide for instream uses, bays and estuaries. The Chapter 711 rules are adopted, in large part, pursuant to these statutory mandates.

Section 1.14(b) of the Act imposes, subject to certain limitations, an initial aquifer withdrawal "cap" for permitted withdrawals of 450,000 acre-feet per year, until December 31, 2007. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(c) of the Act imposes, subject to certain limitations, an aquifer withdrawal "cap" for permitted withdrawals of 400,000 acre-feet per year, beginning January 1, 2008. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(d) of the Act provides that either of the caps listed above may be raised by the Authority if, through studies and implementation of certain strategies, the authority, in consultation with state and federal agencies, determines the caps may be raised.

Section 1.14(e) of the Act requires the Authority to prohibit withdrawals from new wells drilled after the effective date of the Act unless the "caps" are raised and then only on an interruptible basis. The Chapter 711 rules incorporate this prohibition.

Section 1.14(f) of the Act entitles the Authority to allow (or not allow) permitted withdrawals on an uninterruptible basis when certain index wells are at or above the following measurements: for the San Antonio pool, when well J-17 is at or above 650 mean sea level (msl); and for the Uvalde Pool, when well J-27 is at or above 865 msl. The section also imposes the duty on the Authority to limit additional withdrawals to ensure that springflows are not affected during critical drought conditions. The Chapter 711 rules incorporate these concepts by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.14(g) of the Act allows the Authority to, by rule, define other pools within the aquifer in accordance with hydrogeologic research, and to establish index wells for any pool to monitor the level of the aquifer to aid the regulation of withdrawals from the pools.

Section 1.14(h) of the Act provides that the Authority generally must ensure, by December 31, 2012, that continuous minimum springflows of Comal and San Marcos Springs are maintained to protect threatened and endangered species to the extent required by federal law. The Chapter 711 rules incorporate this requirement by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.15(a) of the Act directs the Authority "to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by the Act." This section is implemented through the Chapter 711 rules.

Section 1.15(b) of the Act states that "except as provided by §§1.17 and 1.33 of this article, a person may not withdraw water from the aquifer or begin construction of a well or other works designed for the withdrawal of water from the aquifer without obtaining a permit from the authority." This section is implemented through the Chapter 711 rules.

Section 1.15(c) of the Act allows the Authority to issue regular permits, term permits, and emergency permits. This section is implemented through the Chapter 711 rules.

Section 1.15(d) of the Act provides that each permit issued by the Authority must specify the maximum rate and total volume of water that the user may withdraw annually. This section is implemented through the Chapter 711 rules.

Section 1.16(a) of the Act allows an existing user to apply for an initial regular permit by filing a declaration of historical use documenting use of aquifer water during the period from June 1, 1972 through May 31, 1993. The initial regular permits issued pursuant to the Chapter 711 rules will be based upon such.

Section 1.16(b) of the Act, in conjunction with Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996)(holding that declarations must be filed within six months after the effective date of the Act, i.e., December 30, 1996) provides that an existing user's declaration of historical use (permit application) must be file on or before December 30, 1996, and the applicant must timely pay all application fees required by the Authority. It further requires irrigation applicants to submit, as part of their applications, documentation regarding the number of acres irrigated during the historical period.

Section 1.16(c) of the Act provides that an owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under § 1.33 of the Act is not required to file a declaration of historical use.

Section 1.16(d) of the Act requires the Board to grant an initial regular permit to an existing user who: (1) files a declaration and pays fees as required by this section; and (2) establishes by convincing evidence beneficial use of underground water from the aquifer. This requirement is incorporated into the Chapter 711 rules.

Section 1.16(e) of the Act explains the quantity of water to be permitted under an initial regular permit. Pursuant to this section, if enough water is available, each existing user shall be permitted for an amount equal to the user's maximum beneficial use during the historical period. If there is not enough water available, then this section requires the Authority to "proportionately adjust" permit amounts downward in order to meet the withdrawals "caps" discussed above. However, this section also creates certain "permit minimums" for existing irrigation users and for those existing users who have operated a well for three or more years during the historical period. This section also requires the Authority to extrapolate water use on an annual basis for those existing users who do not have a full year's use during the historical period. These concepts are incorporated into Chapter 711, primarily in Subchapter G.

Section 1.16(f) requires the Authority to equitably treat persons whose historic use was affected by participation in a federal program, such as agricultural subsidy programs. This concept is incorporated in the Chapter 711 rules.

Section 1.16(g) of the Act provides that initial regular permits do not have a term and remain in effect until abandoned, cancelled or retired. These concepts are incorporated in the Chapter 711 rules.

Section 1.16(h) of the Act requires the Authority to notify each permit holder of the limitations to which the permit is subject. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter F.

Section 1.17(a) of the Act provides that a person who, on the effective date of this article, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the Authority, if: "(1) the well is in compliance with all statutes and rules relating to well construction, approval, location, spacing, and operation; and (2) by March 1, 1994, the person files a declaration of historical use on a form as required by the authority."

Section 1.18 of the Act allows the Authority, in certain circumstances, to issue additional regular permits. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.19 of the Act allows the Authority to issue term permits and places certain limitations and conditions on the right to withdraw water under such a permit. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.20 of the Act allows the Authority to issue emergency permits under certain circumstances and subject to certain conditions. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.21 of the Act sets out a process by which the Authority is to implement a plan for reducing the withdrawal "cap" from 450,000 to 400,000 acre-feet per year by January 1, 2008. The plan must be enforceable and include various water conservation, reuse, retirement, and other management measures. If, on or after January 1, 2008, total permitted withdrawals still exceed the 400,000 acre-feet cap, then the Authority must implement "equal percentage reductions" of all permits in order to reach the cap. This concept is implemented in Chapter 711, primarily in Subchapter G.

Section 1.22 of the Act provides that the Authority may acquire permitted aquifer rights to be used for: holding in trust for sale or transfer to other users; holding in trust as a means of managing aquifer demand; holding for resale or retirement as a means of achieving pumping reductions required by the Act; or retiring the rights. These concepts are implemented in part in Chapter 711.

Section 1.23(a) of the Act provides that the Authority may require certain permittees to submit and implement water conservation plans and water reuse plans. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.25 of the Act requires the Authority to develop and implement a comprehensive water management plan and, in conjunction with the SCTWAC and other water districts, to develop and implement a plan for providing alternative water supplies, with oversight by state agencies and the Edwards Aquifer Legislative Oversight Committee. The alternative supplies plan shall consider alternative technologies, financing issues, costs and benefits, and environmental issues. These concepts are implemented, in part, in Chapter 711, primarily through Subchapter F.

Section 1.26 of the Act requires the Authority to prepare and coordinate implementation of a critical period management plan which meets certain, enumerated criteria. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.29 of the Act authorizes the imposition of various types of fees on various types of permits. The Chapter 711 rules acknowledge this fee provision, primarily in Subchapter E.

Section 1.31 of the Act provides that nonexempt well owners must install and maintain meters or alternative measuring devices to measure the flow rate and cumulative amount of water withdrawn from each well. These concepts are implemented in the Chapter 711 rules.

Section 1.32 of the Act requires permittees to submit annual water use reports to the Authority. This section is acknowledged in Subchapter F.

Section 1.33 of the Act provides the criteria for exempt wells -- i.e., wells that produce no more than 25,000 gallons of water per day for domestic and livestock use and that are not within or serving a subdivision requiring platting. The section explains that such wells are exempt from metering requirements. However, such wells must be registered with the Authority. These concepts are implemented in Chapter 711.

Section 1.34 of the Act imposes certain limitations upon the ways in which aquifer water and/or water rights may be transferred (alienated). First, aquifer water must be used within the Authority's boundaries. Second, the section allows the Authority to establish rules by which a person may install water conservation equipment and sell the water conserved. Third, the section further provides that a holder of a permit for irrigation use may not transfer more than 50 percent of the irrigation rights initially permitted and that the user's remaining irrigation water rights must be used in accordance with the original permit and must pass with transfer of the irrigated land. These concepts are implemented, in part, in Chapter 711.

Section 1.35 of the Act prohibits: withdrawing aquifer water except as authorized by a permit; violating permit terms or conditions; wasting aquifer water; polluting or contributing to the pollution of the aquifer; or violating the Act or an Authority rule. These concepts are implemented in Chapter 711.

Section 1.36 of the Act empowers the Authority to enter orders enforcing the terms and conditions of permits, orders, or rules, and to draft rules suspending permits for failure to pay required fees or violations of permits, orders or rules. These concepts are implemented, in part, in Chapter 711.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This rulemaking is in furtherance of this legislative mandate.

Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711derive in part from this statutory authority and implement this chapter and the supporting rules.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.101(a) empowers the Authority to make and enforce rules to provide for conserving, preserving, protecting, and recharging of the groundwater in order to, among other things, prevent waste and carry out the duties provided elsewhere in Chapter 36. This requirement is implemented, in large part, through Chapter 711.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.111 requires the Authority to require aquifer users to keep and maintain reports of drilling, equipping, and completing water wells and the production and uses of groundwater. Chapter 711 implements these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. The section further specifies the permitted format and contents of permit applications, and lays out criteria for the district to consider when ruling on a permit application. The section also provides that permits may be issued subject to the district's rules and other restrictions. The Chapter 711 rules incorporate these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.1131 specifies what may be included as elements of a permit issued by a district.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.115 provides that no person may drill a well, alter the size of a well or well pump, or operate a well without first obtaining a permit from the Authority.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that drilling a well without a required permit or operating a well at a higher rate of production than the rate approved for the well is declared to be illegal, wasteful per se, and a nuisance. This concept is incorporated into Chapter 711, primarily in the definition of waste found in § 711.1.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.211(a) endows districts such as the Authority with the "functions, powers, authority, rights, and duties that will permit accomplishment of the purposes for which it was created or the purposes authorized by the constitution, this code, or any other law." This broad delegation of powers is incorporated into the Chapter 711 rules.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.221 empowers representatives of the Authority to enter land and perform tests and other inspections. This authority is incorporated into Chapter 711, primarily in § 711.416.

16 TAC, Chapter 76. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation (TDLR).) The TDLR's rules implementing Chapter 32 are found at 16 TAC, Chapter 76. These rules impose numerous duties upon well drillers and well owners related to well construction, operation, and plugging. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 implement, in part, the rules found in 16 TAC, Chapter 76.

§711.94.Beneficial Use.

(a)

Groundwater withdrawn from the aquifer must:

(1)

have been placed to beneficial use without waste during the historical period; or

(2)

be placed to beneficial use without waste after the historical period.

(b)

Unless otherwise provided by contract, the beneficial use of groundwater by a contract user inures to the benefit of a prior user or an existing user from whose well the contract user made withdrawals.

(c)

Unless otherwise provided by contract, the beneficial use of groundwater by a contract user may only be claimed by a prior user or existing user in support of a declaration.

(d)

Irrigation use of groundwater from the aquifer in the volume of two acre-feet per irrigated acre is rebuttably presumed to constitute beneficial use without waste.

(e)

The irrigation of multiple or successive crops is a beneficial use to the extent it does not constitute waste.

(f)

For a prior user or an existing user whose historic use has been affected by a requirement of, or participation in, a federal program, a beneficial use credit shall be given for the amount that would have been withdrawn and beneficially used during the historical period by such prior user or existing user but for the operation of the federal program. If the use was for irrigation purposes, the credit is based on irrigation use on comparable acres on a similarly situated farm that is not in the federal program. If the use was for non-irrigation purposes, the credit is based upon the use of a comparable and similarly situated user whose uses were not affected by participation in a federal program.

(g)

Unless otherwise provided by contract, the beneficial use of groundwater during the historical period on the same place of use by multiple existing users each owning different wells is shared pro rata based on the number of existing users who irrigated the place of use during the historical period with the sum total of each existing user's pro rata share not exceeding two acre-feet per irrigated acre.

§711.96.Non-Aquifer Groundwater.

(a)

The Authority may not issue to an applicant a groundwater withdrawal permit to withdraw groundwater from an aquifer other than the Edwards Aquifer.

(b)

An application for a groundwater withdrawal permit for a well that withdraws groundwater from multiple aquifers, including the Edwards Aquifer, may be granted by the board in an amount that does not exceed:

(1)

for irrigation use, the number of acres beneficially irrigated with the water withdrawn from the well multiplied by the percentage of aquifer water produced from the well, multiplied by two acre-feet; or

(2)

for non-irrigation use, the actual amount of groundwater withdrawn from the aquifer and placed to beneficial use.

§711.98.Initial Regular Permits.

(a)

An existing user may apply for an initial regular permit.

(b)

Initial regular permits are transferable pursuant to subchapter L of this chapter (relating to Transfers).

(c)

The term of an initial regular permit is perpetual.

(d)

If in effect, initial regular permits may be proportionally adjusted in accordance with the proportional adjustment rules pursuant to subchapter G of this chapter (relating to Groundwater Available for Permitting; Proportional Adjustment; and Equal Percentage Reduction).

(e)

If in effect, initial regular permits may be retired in accordance with the following rules:

(1)

the springflow maintenance rules pursuant to subchapter G (relating to Springflow Maintenance Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(2)

the equal percentage reduction rules pursuant to subchapter G of this chapter (relating to Groundwater Available for Permitting, Proportional Adjustment, Equal Percentage Reduction); or

(3)

the regular permit retirement rules pursuant to subchapter H (relating to Withdrawal Reductions and Regular Permit Retirement Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

(f)

If in effect, initial regular permits may be suspended in accordance with the following rules:

(1)

the demand management rules pursuant to subchapter D (relating to Demand Management) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation); or

(2)

the groundwater trust pursuant to subchapter N of this chapter (relating to Groundwater Trust).

(g)

If in effect, initial regular permits may be interrupted in accordance with the following rules:

(1)

the drought management rules pursuant to subchapter E (relating to Drought Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(2)

the critical period management rules pursuant to subchapter F (relating to Critical Period Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation); or

(3)

the springflow maintenance rules pursuant to subchapter G (relating to Springflow Maintenance Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

(h)

Initial regular permits may be abandoned pursuant to subchapter H of this chapter (relating to Abandonment and Cancellation).

(i)

Initial regular permits may be canceled pursuant to subchapter H of this chapter (relating to Abandonment and Cancellation).

(j)

Subject to the duty of the board to determine the amount of groundwater that may be withdrawn under an initial regular permit, the board shall grant an application for an initial regular permit if the following elements are established by convincing evidence:

(1)

the applicant filed a declaration on or before December 30, 1996;

(2)

the applicant paid the application fee on or before December 30, 1996;

(3)

the application identifies an existing well(s);

(4)

on June 1, 1993, the applicant, or a prior user who is the applicant's predecessor or in interest, owned the well;

(5)

the well head is physically located within the boundaries of the authority;

(6)

the well is a withdrawal point for groundwater;

(7)

the groundwater withdrawn from the well immediately prior to its intake into the well casing was physically located within and discharged directly from the aquifer;

(8)

at the time of the withdrawals, the well was operated by:

(A)

the applicant;

(B)

a prior user who is the applicant's predecessor in interest to the ownership of the well; or

(C)

a contract user;

(9)

the withdrawals were made during the historical period;

(10)

the place of use at which the withdrawals were beneficially used is physically located within the boundaries of the authority;

(11)

the withdrawals were placed to a beneficial use for irrigation, municipal, or industrial use;

(12)

the well(s) does not qualify for exempt well status;

(13)

the application is in compliance with the Act; and

(14)

the application is in compliance with the rules of the Authority.

(k)

The board shall issue withdrawal amounts to an applicant for an initial regular permit pursuant to §711.176 of this title (relating to Groundwater Withdrawal Amount for Initial Regular Permits; Compensation for Phase-2 Proportional Amounts) or as modified by §711.180 of this title (relating to Voluntary Waiver of Applications for Initial Regular Permits) of this chapter.

§711.100.Additional Regular Permits.

(a)

Any person owning a well, or proposing to construct a well, may apply for an additional regular permit if:

(1)

final determinations have been made by the board on all applications for initial regular permits filed with the authority on or before December 30, 1996; and

(2)

the board has issued an order stating that the authority is accepting for filing applications for additional regular permits.

(b)

Unless the board has issued the order authorizing applications for additional regular permits to be filed with the authority, the general manager may not process any application received and must return the application to the applicant along with any application fee submitted. When the general manager is authorized to accept for filing applications for additional regular permits, they shall be processed in the order in which they are received according to the official date and time stamp of the authority on the application.

(c)

Additional regular permits are transferable pursuant to subchapter L of this chapter (relating to Transfers).

(d)

The term of an additional regular permit is perpetual.

(e)

If in effect, additional regular permits may be retired in accordance with the following rules:

(1)

the springflow maintenance rules pursuant to subchapter G (relating to Springflow Maintenance Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(2)

the equal percentage reduction rules pursuant to subchapter G of this chapter (relating to Groundwater Available for Permitting; Proportional Adjustment; Equal Percentage Reduction); or

(3)

the regular permit retirement rules pursuant to subchapter H (relating to Withdrawal Reductions and Regular Permit Retirement Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

(f)

If in effect, additional regular permits may be suspended in accordance with the following rules:

(1)

the demand management rules pursuant to subchapter D (relating to Demand Management) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation); or

(2)

the groundwater trust pursuant to subchapter N of this chapter (relating to Groundwater Trust).

(g)

If in effect, additional regular permits may be interrupted in accordance with the following rules:

(1)

the drought management rules pursuant to subchapter E (relating to Drought Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(2)

the critical period management rules pursuant to subchapter F (relating to Critical Period Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation); or

(3)

the springflow maintenance rules pursuant to subchapter G (relating to Springflow Maintenance Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

(h)

Additional regular permits may be abandoned pursuant to subchapter H of this chapter (relating to Abandonment and Cancellation).

(i)

Additional regular permits may be canceled pursuant to subchapter H of this chapter (relating to Abandonment and Cancellation).

(j)

Subject to the duty of the board to determine the amount of groundwater that may be withdrawn under an additional regular permit, the board shall grant an application for an additional regular permit if the following elements are established by convincing evidence:

(1)

the applicant paid the application fee;

(2)

the application identifies an existing or proposed well(s);

(3)

the well head is physically located within the boundaries of the authority;

(4)

the well is a withdrawal point for groundwater;

(5)

the groundwater proposed to be withdrawn from the well immediately prior to its intake into the well casing will be physically located within and discharged directly from the aquifer;

(6)

the place of use at which the withdrawals are proposed to be beneficially used is physically located within the boundaries of the authority;

(7)

the withdrawals are proposed to be placed to a beneficial use for irrigation, municipal, or industrial use;

(8)

there remains water available for permitting after the board has made final determinations on:

(A)

all applications for initial regular permits;

(B)

any restorations of proportional adjustments or equal percentage reductions pursuant to § 711.304 of this title (relating to Allocation of Additional Groundwater Supplies ) of this chapter; and

(C)

all prior applications for additional regular permits;

(9)

the well does not qualify for exempt well status;

(10)

the proposed withdrawal of groundwater is consistent with chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(11)

the application is in compliance with the Act; and

(12)

the application is in compliance with the rules of the Authority.

(k)

The board shall issue a groundwater withdrawal amount to an applicant for an additional regular permit in an amount that is consistent with chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

§711.102.Term Permits.

(a)

Any person owning a well, or proposing to construct a well, may apply for a term permit.

(b)

Unless the board has issued an order authorizing applications for term permits to be filed with the authority, the general manager may not process any application received and must return the application to the applicant along with any application fee submitted. When the general manager is authorized to accept for filing applications for term permits, they shall be processed in the order in which they are received according to the official date and time stamp of the authority on the application.

(c)

Term permits are transferable only as to ownership pursuant to subchapter L of this chapter (relating to Transfers).

(d)

If in effect, term permits shall be interrupted in accordance with the following rules:

(1)

for wells completed in the San Antonio pool, the level of the aquifer for the San Antonio pool is equal to or less than 665 feet above mean sea level as measured at well J-17;

(2)

for wells completed in the Uvalde pool, the level of the aquifer for the Uvalde pool is equal to or less than 865 feet above mean sea level as measured at well J-27;

(3)

the drought management rules pursuant to subchapter E (relating to Drought Management Rules) of chapter 715 (relating to Comprehensive Water Management Plan Implementation);

(4)

the critical period management rules pursuant to subchapter F (relating to Critical Period Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation); or

(5)

the springflow maintenance rules pursuant to subchapter G (relating to Springflow Maintenance Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

(e)

A term permit may be issued for any period the Authority considers feasible not to exceed ten years. Upon expiration of the term, the permit automatically expires and is canceled.

(f)

Subject to the duty of the board to determine the amount of groundwater that may be withdrawn under a term permit, the board shall grant an application for a term permit if the following elements are established by convincing evidence:

(1)

the applicant paid the application fee;

(2)

the application identifies an existing or proposed well(s);

(3)

the well head is physically located within the boundaries of the authority;

(4)

the well is a withdrawal point for groundwater;

(5)

the groundwater proposed to be withdrawn from the well immediately prior to its intake into the well casing will be physically located within and discharged directly from the aquifer;

(6)

the withdrawals are proposed to be placed to a beneficial use;

(7)

the place of use at which the withdrawals are proposed to be beneficially used is physically located within the boundaries of the authority;

(8)

groundwater is available for permitting from the San Antonio or Uvalde pools, as appropriate;

(9)

the well does not qualify for exempt well status;

(10)

the applicant is in compliance with other groundwater withdrawal permits, if any;

(11)

the proposed withdrawal of groundwater under the term permit, if granted, would not unreasonably negatively affect other permittees;

(12)

the proposed withdrawal of groundwater is consistent with chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(13)

the proposed use of groundwater is economically feasible in relation to the proposed length of the term;

(14)

if applicable, the applicant has or will have an approved existing on-site sewer systems, or has been granted an application to construct such a system by the appropriate regulatory agency;

(15)

the applicant will take all reasonable measures to ensure conservation of water withdrawn;

(16)

the applicant has no other source of water from a municipal distribution system;

(17)

the application is in compliance with the Act; and

(18)

the application is in compliance with the rules of the Authority.

(g)

The board shall issue a groundwater withdrawal amount to an applicant for a term permit in the amount that is consistent with chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

(h)

By January 15 of each year, the board by order shall determine the total quantity of groundwater that may be withdrawn from each pool of the aquifer for that calendar year pursuant to term permits. At any time by order of the Board this determination may be revised as appropriate based upon actual aquifer conditions to be consistent with chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation).

§711.108.Well Construction Permits

(a)

Any person proposing to perform any of the activities set forth in § 711.12(a)(2)-(5) of this chapter (relating to Activities Requiring a Permit) shall apply for a well construction permit.

(b)

Well construction permits are not transferable pursuant to subchapter L of this chapter (relating to Transfers).

(c)

A well constructed pursuant to a well construction permit must be completed within 180 days of the issuance of the permit. The permit term may be extended by one additional 180-day extension period by the general manager. In order to obtain such an extension, the holder of a well construction permit must submit a written request to the general manager explaining the need for the extension. If the holder of the well construction permit demonstrates a need for an extension and demonstrates that the permit holder's failure to complete the well within the original 180-day term is not due to the permit holder's own lack of diligence, then the general manager may authorize the extension. Upon expiration of the term, including any extension granted, the permit automatically expires and is canceled.

(d)

The general manager shall grant an application for a well construction permit if the following elements are established by convincing evidence:

(1)

the applicant paid the application fee;

(2)

the application identifies a proposed or an existing well(s);

(3)

the well head is or will be physically located within the boundaries of the Authority;

(4)

the well is a withdrawal point for groundwater;

(5)

the groundwater proposed to be withdrawn from the well immediately prior to its intake into the well casing will be physically located within and discharged directly from the aquifer;

(6)

the withdrawals are proposed to be placed to a beneficial use for domestic or livestock use, irrigation use, municipal use, or industrial use;

(7)

the place of use at which the withdrawals are proposed to be beneficially used is physically located within the boundaries of the authority;

(8)

the applicant has a legal right to make withdrawals from the well;

(9)

the quantity of groundwater the well would be capable of producing, if constructed, is consistent with the quantity of groundwater the applicant proposes to produce pursuant to exempt well status or pursuant to a groundwater withdrawal permit;

(10)

the applicant is in compliance with other permits the applicant holds from the Authority;

(11)

the proposed well construction and operation would not unreasonably negatively affect the aquifer or other permittees;

(12)

the well will be constructed, operated and maintained consistent with all applicable local, state, and federal well construction, operation, and maintenance law;

(13)

the well will be constructed, operated and maintained consistent with chapter 713 this title (relating to Water Quality);

(14)

the application is in compliance with the Act; and

(15)

the application is in compliance with the rules of the Authority.

§711.112.Contents of Groundwater Withdrawal Permits.

Groundwater withdrawal permits issued by the Authority shall contain the following:

(1)

name, address and telephone number of the owner of the permit;

(2)

name, address and telephone number of an authorized representative, if any, of the owner;

(3)

permit category;

(4)

permit term;

(5)

purpose of use;

(6)

maximum rate of withdrawal in gallons per minute;

(7)

maximum volume of withdrawals by purpose in acre-feet on an annual basis;

(8)

if applicable, maximum historical use as defined in § 711.172(B)(3) of this chapter (relating to Proportional Adjustment of Initial Regular Permits);

(9)

if applicable, historical average or irrigator minimum as defined in § 711.172(b)(1) and (2), respectively, of this chapter (relating to Proportional Adjustment of Initial Regular Permits);

(10)

if applicable, Phase-1 proportionally adjusted amount as calculated pursuant to § 711.172(g)(5) of this chapter (relating to Proportional Adjustment of Initial Regular Permits);

(11)

if applicable, Step-up amount as calculated pursuant to § 711.172(g)(6) of this chapter (relating to Proportional Adjustment of Initial Regular Permits);

(12)

if applicable, Phase-2 proportionally adjusted amount as calculated pursuant to § 711.172(g)(8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits);

(13)

if applicable, the equal percentage reduction amount as calculated pursuant to § 711.174 of this chapter (relating to Equal Percentage Reduction of Initial Regular Permits) and subchapter H (relating to Withdrawal Reductions) and Regular Permit Retirement Rules of chapter 715 (relating to Comprehensive Management Plan Implementation of this title); the amount that may be subject to restoration pursuant to § 711.172(h) of this chapter (relating to Proportional Adjustment of Initial Regular Permits) and § 711.304 of the chapter (relating to Allocation of Additional Groundwater Supplies);

(14)

location of the point(s) of withdrawal;

(15)

place of use;

(16)

source of groundwater;

(17)

metering or alternative measuring method;

(18)

conditions for retirement of permits;

(19)

conditions for suspension of withdrawals;

(20)

conditions for interruption of withdrawals;

(21)

conditions for renewal, if applicable;

(22)

reporting requirements;

(23)

notice that the permit is subject to the limitations provided in the Act and these rules;

(24)

the standard groundwater withdrawal conditions set forth in subchapter F of this chapter (relating to Standard Groundwater Withdrawal Conditions);

(25)

any other appropriate conditions on the withdrawal of groundwater from the aquifer as determined by the Authority; and

(26)

any other information required by the board to implement the Act or the Authority's rules.

§711.116.Contents of Well Construction Permits.

Well construction permits issued by the Authority shall contain the following:

(1)

name, address and telephone number of the owner of the permit;

(2)

name, address and telephone number of an authorized representative, if any, of the owner;

(3)

permit category;

(4)

permit term;

(5)

purpose of use of the well;

(6)

maximum rate of withdrawal in gallons per minute;

(7)

maximum volume of withdrawals by purpose in acre-feet on an annual basis;

(8)

legal description of the location of the well, including:

(A)

county;

(B)

section, block and survey;

(C)

labor and league;

(D)

number of feet to the two nearest non-parallel property lines (legal survey lines); and

(E)

other adequate legal description, as may be required by the Authority;

(9)

identification of the specific legal authority of the applicant to make withdrawals of groundwater from the aquifer from the well;

(10)

the source of groundwater;

(11)

size of the pump, pumping rate, pumping method, and other construction specifications for metering or alternative measuring method;

(12)

internal diameter, total well depth, depth of cement casing, size, and other well construction specifications as appropriate;

(13)

reporting requirements;

(14)

notice that the permit is subject to the limitations provided in the Act and these rules;

(15)

any other appropriate conditions on the well construction as determined by the Authority; and

(16)

any other information required by the board to implement the Act or the Authority's rules.

§711.118.Contents of Monitoring Well Permits.

Monitoring well permits issued by the Authority shall contain the following:

(1)

name, address and telephone number of the owner of the permit;

(2)

name, address and telephone number of an authorized representative, if any, of the owner;

(3)

permit category;

(4)

permit term;

(5)

purpose of use of the well;

(6)

maximum rate of withdrawal in gallons per minute;

(7)

maximum volume of withdrawals by purpose in acre-feet on an annual basis;

(8)

legal description of the location of the well, including:

(A)

county;

(B)

section, block and survey;

(C)

labor and league;

(D)

number of feet to the two nearest non-parallel property lines (legal survey lines); and

(E)

other adequate legal description, as may be required by the Authority;

(9)

purpose of the monitoring activity;

(10)

the source of groundwater;

(11)

size of the pump, pumping rate, pumping method, and other construction specifications for metering or alternative measuring method;

(12)

internal diameter, total well depth, depth of cement casing, size, and other well construction specifications as appropriate;

(13)

construction specification for other monitoring equipment to be installed in and associated with the well;

(14)

reporting requirements;

(15)

notice that the permit is subject to the limitations provided in the Edwards Aquifer Act and these rules;

(16)

any other appropriate conditions on the construction well as determined by the Authority; and

(17)

any other information required by the board to implement the Act or the Authority's rules.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007357

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter F. STANDARD GROUNDWATER WITHDRAWAL PERMIT CONDITIONS

31 TAC §§711.130, 711.132, 711.134

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The new sections are adopted pursuant to the following statutory provisions:

Section 1.01 of the Act contains the findings of the Texas Legislature that the Edwards Aquifer is a distinctive natural resource and that a special regional management district (the Authority) is required for the effective control of the resource to protect terrestrial and aquatic life, domestic and municipal water supplies, existing industries, and the economic development of the state.

Section 1.03(1) defines the "Edwards Aquifer."

Section 1.03(4) of the Act defines "beneficial use" to mean the use of water that is economically necessary for a purpose authorized by law when reasonable intelligence and reasonable diligence are used in applying the water to that purpose. The concept of beneficial use is incorporated into the permitting rules of Chapter 711.

Section 1.03(9) of the Act defines "domestic or livestock use." This concept is incorporated into the exempt well rules found within Chapter 711.

Section 1.03(10) of the Act defines "existing user" as a person who has withdrawn and beneficially used underground water from the aquifer on or before June 1, 1993. This concept is incorporated into the Chapter 711 rules, while also accounting for the beneficial use requirement and including the successors in interest of existing users within the definition.

Section 1.03(11) of the Act defines "industrial use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(12) of the Act defines "irrigation use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(13) of the Act defines "livestock." The Chapter 711 rules incorporate this concept when determining whether a well qualifies as "exempt" from permitting requirements.

Section 1.03(14) of the Act defines "municipal use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(21) of the Act defines "waste." This concept is incorporated into the Chapter 711 rules, while also including other practices which are considered wasteful under the Act or under the long-standing water law concept of beneficial use.

Section 1.07 of the Act provides, in part, that the actions taken by the Authority pursuant to the Act may not be construed as depriving or divesting owners of their ownership rights as landowners in underground water, subject to rules adopted by the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer. These rules further those objectives.

Section 1.08(b) makes it clear that the Authority's powers apply only to water within or withdrawn from the Edwards Aquifer, and not to surface water.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rule governing procedures of the board and the authority." This section provides broad rulemaking authority to implement the various substantive and procedures programs set forth in the Act related to the Edwards Aquifer, including the permitting program.

Section 1.11(b) of the Act requires the Authority to "ensure compliance with permitting, metering, and reporting requirements and . . . regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, requires the Authority to adopt and enforce the Chapter 711 rules.

Section 1.11(d)(2) of the Act empowers the Authority to enter into contracts. Pursuant to this section, the Authority may enter into contracts with well owners concerning meters and reimbursement for same under Subchapter M of the Chapter 711 rules.

Section 1.11(d)(8) of the Act provides that the Authority may close abandoned, wasteful or dangerous wells. The Authority's rules relating to the requirement of beneficial use and the prohibition of waste, as well as the closure of abandoned wells derive in part from this statutory authority.

Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 of the Texas Water Code and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) Chapter 32 imposes certain duties upon drillers of water wells and the owners of those wells. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 derive in part from this statutory authority.

Section 1.11(d)(11) of the Act provides that the Authority may require to be furnished with copies of the water well drillers' logs that are required by Chapter 32 of the Texas Water Code.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. This section essentially provides that the Authority is required to comply with the APA for its rulemaking, even though the Authority is a political subdivision and not a state agency that would generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.13 of the Act requires the Authority to allow credit to be given for certified reuse of aquifer water. The Authority will likely adopt rules implementing this section. This concept is acknowledged in Subchapter F.

Section 1.14(a) of the Act provides that authorizations to withdraw aquifer water shall be limited in order to: protect water quality of the aquifer and surface streams to which the aquifer contributes springflow; achieve water conservation; maximize beneficial use of water from the aquifer; protect aquatic and wildlife habitat as well as federally or state-designated threatened or endangered species; and provide for instream uses, bays and estuaries. The Chapter 711 rules are adopted, in large part, pursuant to these statutory mandates.

Section 1.14(b) of the Act imposes, subject to certain limitations, an initial aquifer withdrawal "cap" for permitted withdrawals of 450,000 acre-feet per year, until December 31, 2007. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(c) of the Act imposes, subject to certain limitations, an aquifer withdrawal "cap" for permitted withdrawals of 400,000 acre-feet per year, beginning January 1, 2008. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(d) of the Act provides that either of the caps listed above may be raised by the Authority if, through studies and implementation of certain strategies, the authority, in consultation with state and federal agencies, determines the caps may be raised.

Section 1.14(e) of the Act requires the Authority to prohibit withdrawals from new wells drilled after the effective date of the Act unless the "caps" are raised and then only on an interruptible basis. The Chapter 711 rules incorporate this prohibition.

Section 1.14(f) of the Act entitles the Authority to allow (or not allow) permitted withdrawals on an uninterruptible basis when certain index wells are at or above the following measurements: for the San Antonio pool, when well J-17 is at or above 650 mean sea level (msl); and for the Uvalde Pool, when well J-27 is at or above 865 msl. The section also imposes the duty on the Authority to limit additional withdrawals to ensure that springflows are not affected during critical drought conditions. The Chapter 711 rules incorporate these concepts by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.14(g) of the Act allows the Authority to, by rule, define other pools within the aquifer in accordance with hydrogeologic research, and to establish index wells for any pool to monitor the level of the aquifer to aid the regulation of withdrawals from the pools.

Section 1.14(h) of the Act provides that the Authority generally must ensure, by December 31, 2012, that continuous minimum springflows of Comal and San Marcos Springs are maintained to protect threatened and endangered species to the extent required by federal law. The Chapter 711 rules incorporate this requirement by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.15(a) of the Act directs the Authority "to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by the Act." This section is implemented through the Chapter 711 rules.

Section 1.15(b) of the Act states that "except as provided by §§1.17 and 1.33 of this article, a person may not withdraw water from the aquifer or begin construction of a well or other works designed for the withdrawal of water from the aquifer without obtaining a permit from the authority." This section is implemented through the Chapter 711 rules.

Section 1.15(c) of the Act allows the Authority to issue regular permits, term permits, and emergency permits. This section is implemented through the Chapter 711 rules.

Section 1.15(d) of the Act provides that each permit issued by the Authority must specify the maximum rate and total volume of water that the user may withdraw annually. This section is implemented through the Chapter 711 rules.

Section 1.16(a) of the Act allows an existing user to apply for an initial regular permit by filing a declaration of historical use documenting use of aquifer water during the period from June 1, 1972 through May 31, 1993. The initial regular permits issued pursuant to the Chapter 711 rules will be based upon such.

Section 1.16(b) of the Act, in conjunction with Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996)(holding that declarations must be filed within six months after the effective date of the Act, i.e., December 30, 1996) provides that an existing user's declaration of historical use (permit application) must be file on or before December 30, 1996, and the applicant must timely pay all application fees required by the Authority. It further requires irrigation applicants to submit, as part of their applications, documentation regarding the number of acres irrigated during the historical period.

Section 1.16(c) of the Act provides that an owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under § 1.33 of the Act is not required to file a declaration of historical use.

Section 1.16(d) of the Act requires the Board to grant an initial regular permit to an existing user who: (1) files a declaration and pays fees as required by this section; and (2) establishes by convincing evidence beneficial use of underground water from the aquifer. This requirement is incorporated into the Chapter 711 rules.

Section 1.16(e) of the Act explains the quantity of water to be permitted under an initial regular permit. Pursuant to this section, if enough water is available, each existing user shall be permitted for an amount equal to the user's maximum beneficial use during the historical period. If there is not enough water available, then this section requires the Authority to "proportionately adjust" permit amounts downward in order to meet the withdrawals "caps" discussed above. However, this section also creates certain "permit minimums" for existing irrigation users and for those existing users who have operated a well for three or more years during the historical period. This section also requires the Authority to extrapolate water use on an annual basis for those existing users who do not have a full year's use during the historical period. These concepts are incorporated into Chapter 711, primarily in Subchapter G.

Section 1.16(f) requires the Authority to equitably treat persons whose historic use was affected by participation in a federal program, such as agricultural subsidy programs. This concept is incorporated in the Chapter 711 rules.

Section 1.16(g) of the Act provides that initial regular permits do not have a term and remain in effect until abandoned, cancelled or retired. These concepts are incorporated in the Chapter 711 rules.

Section 1.16(h) of the Act requires the Authority to notify each permit holder of the limitations to which the permit is subject. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter F.

Section 1.17(a) of the Act provides that a person who, on the effective date of this article, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the Authority, if: "(1) the well is in compliance with all statutes and rules relating to well construction, approval, location, spacing, and operation; and (2) by March 1, 1994, the person files a declaration of historical use on a form as required by the authority."

Section 1.18 of the Act allows the Authority, in certain circumstances, to issue additional regular permits. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.19 of the Act allows the Authority to issue term permits and places certain limitations and conditions on the right to withdraw water under such a permit. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.20 of the Act allows the Authority to issue emergency permits under certain circumstances and subject to certain conditions. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.21 of the Act sets out a process by which the Authority is to implement a plan for reducing the withdrawal "cap" from 450,000 to 400,000 acre-feet per year by January 1, 2008. The plan must be enforceable and include various water conservation, reuse, retirement, and other management measures. If, on or after January 1, 2008, total permitted withdrawals still exceed the 400,000 acre-feet cap, then the Authority must implement "equal percentage reductions" of all permits in order to reach the cap. This concept is implemented in Chapter 711, primarily in Subchapter G.

Section 1.22 of the Act provides that the Authority may acquire permitted aquifer rights to be used for: holding in trust for sale or transfer to other users; holding in trust as a means of managing aquifer demand; holding for resale or retirement as a means of achieving pumping reductions required by the Act; or retiring the rights. These concepts are implemented in part in Chapter 711.

Section 1.23(a) of the Act provides that the Authority may require certain permittees to submit and implement water conservation plans and water reuse plans. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.25 of the Act requires the Authority to develop and implement a comprehensive water management plan and, in conjunction with the SCTWAC and other water districts, to develop and implement a plan for providing alternative water supplies, with oversight by state agencies and the Edwards Aquifer Legislative Oversight Committee. The alternative supplies plan shall consider alternative technologies, financing issues, costs and benefits, and environmental issues. These concepts are implemented, in part, in Chapter 711, primarily through Subchapter F.

Section 1.26 of the Act requires the Authority to prepare and coordinate implementation of a critical period management plan which meets certain, enumerated criteria. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.29 of the Act authorizes the imposition of various types of fees on various types of permits. The Chapter 711 rules acknowledge this fee provision, primarily in Subchapter E.

Section 1.31 of the Act provides that nonexempt well owners must install and maintain meters or alternative measuring devices to measure the flow rate and cumulative amount of water withdrawn from each well. These concepts are implemented in the Chapter 711 rules.

Section 1.32 of the Act requires permittees to submit annual water use reports to the Authority. This section is acknowledged in Subchapter F.

Section 1.33 of the Act provides the criteria for exempt wells -- i.e., wells that produce no more than 25,000 gallons of water per day for domestic and livestock use and that are not within or serving a subdivision requiring platting. The section explains that such wells are exempt from metering requirements. However, such wells must be registered with the Authority. These concepts are implemented in Chapter 711.

Section 1.34 of the Act imposes certain limitations upon the ways in which aquifer water and/or water rights may be transferred (alienated). First, aquifer water must be used within the Authority's boundaries. Second, the section allows the Authority to establish rules by which a person may install water conservation equipment and sell the water conserved. Third, the section further provides that a holder of a permit for irrigation use may not transfer more than 50 percent of the irrigation rights initially permitted and that the user's remaining irrigation water rights must be used in accordance with the original permit and must pass with transfer of the irrigated land. These concepts are implemented, in part, in Chapter 711.

Section 1.35 of the Act prohibits: withdrawing aquifer water except as authorized by a permit; violating permit terms or conditions; wasting aquifer water; polluting or contributing to the pollution of the aquifer; or violating the Act or an Authority rule. These concepts are implemented in Chapter 711.

Section 1.36 of the Act empowers the Authority to enter orders enforcing the terms and conditions of permits, orders, or rules, and to draft rules suspending permits for failure to pay required fees or violations of permits, orders or rules. These concepts are implemented, in part, in Chapter 711.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This rulemaking is in furtherance of this legislative mandate.

Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711derive in part from this statutory authority and implement this chapter and the supporting rules.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.101(a) empowers the Authority to make and enforce rules to provide for conserving, preserving, protecting, and recharging of the groundwater in order to, among other things, prevent waste and carry out the duties provided elsewhere in Chapter 36. This requirement is implemented, in large part, through Chapter 711.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.111 requires the Authority to require aquifer users to keep and maintain reports of drilling, equipping, and completing water wells and the production and uses of groundwater. Chapter 711 implements these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. The section further specifies the permitted format and contents of permit applications, and lays out criteria for the district to consider when ruling on a permit application. The section also provides that permits may be issued subject to the district's rules and other restrictions. The Chapter 711 rules incorporate these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.1131 specifies what may be included as elements of a permit issued by a district.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.115 provides that no person may drill a well, alter the size of a well or well pump, or operate a well without first obtaining a permit from the Authority.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that drilling a well without a required permit or operating a well at a higher rate of production than the rate approved for the well is declared to be illegal, wasteful per se, and a nuisance. This concept is incorporated into Chapter 711, primarily in the definition of waste found in § 711.1.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.211(a) endows districts such as the Authority with the "functions, powers, authority, rights, and duties that will permit accomplishment of the purposes for which it was created or the purposes authorized by the constitution, this code, or any other law." This broad delegation of powers is incorporated into the Chapter 711 rules.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.221 empowers representatives of the Authority to enter land and perform tests and other inspections. This authority is incorporated into Chapter 711, primarily in § 711.416.

16 TAC, Chapter 76. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation (TDLR).) The TDLR's rules implementing Chapter 32 are found at 16 TAC, Chapter 76. These rules impose numerous duties upon well drillers and well owners related to well construction, operation, and plugging. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 implement, in part, the rules found in 16 TAC, Chapter 76.

§711.130.Purpose.

The purpose of this subchapter is to establish the standard conditions required to be contained in a groundwater withdrawal permit issued by the authority for, among other things:

(1)

the protection of the water quality of the groundwater of the aquifer;

(2)

the protection of the water quality of the surface streams to which the aquifer provides springflow;

(3)

the achievement of water conservation, and the maximization of the beneficial use of groundwater available for withdrawal from the aquifer;

(4)

the protection of aquatic and wildlife habitat, and the protection of species that have been listed as threatened or endangered under applicable federal or state law; and

(5)

the providing for instream uses, bays, and estuaries.

§711.134.Standard Conditions.

Any groundwater withdrawal permit issued by the authority is subject to and the permittee shall comply with the following conditions:

(1)

the construction, operation and maintenance of wells pursuant to subchapter C (relating to Well Construction, Operation and Maintenance) of chapter 713 of this title (relating to Water Quality);

(2)

the abandonment and closure of wells pursuant to subchapter D (relating to Abandoned Wells; Well Closures) of chapter 713 of this title (relating to Water Quality);

(3)

the spacing of wells pursuant to subchapter E (relating to Well Spacing) of chapter 713 of this title (relating to Water Quality);

(4)

the installation, operation and maintenance of well fields pursuant to subchapter F (relating to Well Head Protection) of chapter 713 of this title (relating to Water Quality);

(5)

the recharge of the aquifer pursuant to subchapter J of this chapter (relating to Aquifer Recharge, Storage and Recovery Project);

(6)

taking no action that pollutes or contributes to the pollution of the aquifer;

(7)

the beneficial use and utilization of groundwater withdrawn from the aquifer that is reused pursuant to subchapter I (relating to Reuse Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(8)

not wasting groundwater within or withdrawn from the aquifer pursuant to subchapters E (relating to Permitted Wells) and I of this chapter (relating to Prohibitions);

(9)

the beneficial use and utilization of groundwater withdrawn from the aquifer pursuant to subchapter C (relating to Groundwater Conservation Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(10)

the beneficial use and utilization of groundwater withdrawn from the aquifer pursuant to subchapter D (relating to Demand Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(11)

the interruption of the right to withdraw and beneficially use groundwater from the aquifer pursuant to subchapter E (relating to Drought Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(12)

the interruption of the right to withdraw and beneficially use groundwater from the aquifer pursuant to subchapter F (relating to Critical Period Management Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(13)

the installation, operation and maintenance of meters and alternative measuring methods pursuant to subchapter M of this chapter (relating to Meters; Alternative Measuring Methods; and Reporting);

(14)

the keeping and filing of reports pursuant to subchapter M of this chapter (relating to Meters; Alternative Measuring Methods; and Reporting), and any other applicable law or rule; and

(15)

the use of groundwater withdrawn from the aquifer only for an authorized beneficial use and without waste pursuant to subchapter E (relating to Permitted Wells) and I of this chapter (relating to Prohibitions);

(16)

the retirement or interruption of the right to withdraw and beneficially use groundwater from the aquifer pursuant to subchapter G (relating to Springflow Maintenance Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(17)

proportional adjustment pursuant to subchapter G (relating to Groundwater Available for Permitting, Proportional Adjustment, Equal Percentage Reductions) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(18)

retirement by equal percentage reductions pursuant to subchapter G (relating to Groundwater Available for Permitting, Proportional Adjustment, Equal Percentage Reductions) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(19)

retirement pursuant to subchapter H (relating to Withdrawal Reductions and Regular Permit Retirement Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(20)

the acquisition of additional water supplies pursuant to subchapter J (relating to Alternative Water Supply Rules) of chapter 715 of this title (relating to Comprehensive Water Management Plan Implementation);

(21)

the provision of notice of changes in name and mailing address of the permitting pursuant to §707.105 of chapter 707 of this title (relating to Change of Name, Address or Telephone Number);

(22)

the payment of all registration, application, aquifer management, and retirement fees pursuant to chapter 709 of this title (relating to Fees);

(23)

the cessation of withdrawals under interim authorization status pursuant to subchapter D (relating to Interim Authorization) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(24)

abandonment pursuant to subchapter H (relating to Abandonment and Cancellation) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(25)

cancellation pursuant to subchapter H (relating to Abandonment and Cancellation) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(26)

the restoration of equally proportionally reduced amounts pursuant to subchapter K (relating to Additional Groundwater Supplies) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(27)

the transfer of the permit pursuant to subchapter L (relating to Transfers) of chapter 711 of this title (relating to Groundwater Withdrawal Permits);

(28)

the prohibition on the use of groundwater withdrawn from the aquifer at a place of use outside of the boundaries of the authority pursuant to § 711.220 of this chapter (relating to Place of Use Outside of Authority Boundaries);

(29)

compliance with the terms and conditions of the permit;

(30)

compliance with the act;

(31)

compliance with the rules of the authority; and

(32)

any other condition as may, in the discretion of the board be reasonable and appropriate.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007358

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter G. GROUNDWATER AVAILABLE FOR PERMITTING; PROPORTIONAL ADJUSTMENT; EQUAL PERCENTAGE REDUCTIONS

31 TAC §§711.160, 711.162, 711.164, 711.166, 711.168, 711.170, 711.172, 711.174, 711.176, 711.180

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The new sections are adopted pursuant to the following statutory provisions:

Section 1.01 of the Act contains the findings of the Texas Legislature that the Edwards Aquifer is a distinctive natural resource and that a special regional management district (the Authority) is required for the effective control of the resource to protect terrestrial and aquatic life, domestic and municipal water supplies, existing industries, and the economic development of the state.

Section 1.03(1) defines the "Edwards Aquifer."

Section 1.03(4) of the Act defines "beneficial use" to mean the use of water that is economically necessary for a purpose authorized by law when reasonable intelligence and reasonable diligence are used in applying the water to that purpose. The concept of beneficial use is incorporated into the permitting rules of Chapter 711.

Section 1.03(9) of the Act defines "domestic or livestock use." This concept is incorporated into the exempt well rules found within Chapter 711.

Section 1.03(10) of the Act defines "existing user" as a person who has withdrawn and beneficially used underground water from the aquifer on or before June 1, 1993. This concept is incorporated into the Chapter 711 rules, while also accounting for the beneficial use requirement and including the successors in interest of existing users within the definition.

Section 1.03(11) of the Act defines "industrial use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(12) of the Act defines "irrigation use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(13) of the Act defines "livestock." The Chapter 711 rules incorporate this concept when determining whether a well qualifies as "exempt" from permitting requirements.

Section 1.03(14) of the Act defines "municipal use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(21) of the Act defines "waste." This concept is incorporated into the Chapter 711 rules, while also including other practices which are considered wasteful under the Act or under the long-standing water law concept of beneficial use.

Section 1.07 of the Act provides, in part, that the actions taken by the Authority pursuant to the Act may not be construed as depriving or divesting owners of their ownership rights as landowners in underground water, subject to rules adopted by the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer. These rules further those objectives.

Section 1.08(b) makes it clear that the Authority's powers apply only to water within or withdrawn from the Edwards Aquifer, and not to surface water.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rule governing procedures of the board and the authority." This section provides broad rulemaking authority to implement the various substantive and procedures programs set forth in the Act related to the Edwards Aquifer, including the permitting program.

Section 1.11(b) of the Act requires the Authority to "ensure compliance with permitting, metering, and reporting requirements and . . . regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, requires the Authority to adopt and enforce the Chapter 711 rules.

Section 1.11(d)(2) of the Act empowers the Authority to enter into contracts. Pursuant to this section, the Authority may enter into contracts with well owners concerning meters and reimbursement for same under Subchapter M of the Chapter 711 rules.

Section 1.11(d)(8) of the Act provides that the Authority may close abandoned, wasteful or dangerous wells. The Authority's rules relating to the requirement of beneficial use and the prohibition of waste, as well as the closure of abandoned wells derive in part from this statutory authority.

Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 of the Texas Water Code and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) Chapter 32 imposes certain duties upon drillers of water wells and the owners of those wells. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 derive in part from this statutory authority.

Section 1.11(d)(11) of the Act provides that the Authority may require to be furnished with copies of the water well drillers' logs that are required by Chapter 32 of the Texas Water Code.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. This section essentially provides that the Authority is required to comply with the APA for its rulemaking, even though the Authority is a political subdivision and not a state agency that would generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.13 of the Act requires the Authority to allow credit to be given for certified reuse of aquifer water. The Authority will likely adopt rules implementing this section. This concept is acknowledged in Subchapter F.

Section 1.14(a) of the Act provides that authorizations to withdraw aquifer water shall be limited in order to: protect water quality of the aquifer and surface streams to which the aquifer contributes springflow; achieve water conservation; maximize beneficial use of water from the aquifer; protect aquatic and wildlife habitat as well as federally or state-designated threatened or endangered species; and provide for instream uses, bays and estuaries. The Chapter 711 rules are adopted, in large part, pursuant to these statutory mandates.

Section 1.14(b) of the Act imposes, subject to certain limitations, an initial aquifer withdrawal "cap" for permitted withdrawals of 450,000 acre-feet per year, until December 31, 2007. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(c) of the Act imposes, subject to certain limitations, an aquifer withdrawal "cap" for permitted withdrawals of 400,000 acre-feet per year, beginning January 1, 2008. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(d) of the Act provides that either of the caps listed above may be raised by the Authority if, through studies and implementation of certain strategies, the authority, in consultation with state and federal agencies, determines the caps may be raised.

Section 1.14(e) of the Act requires the Authority to prohibit withdrawals from new wells drilled after the effective date of the Act unless the "caps" are raised and then only on an interruptible basis. The Chapter 711 rules incorporate this prohibition.

Section 1.14(f) of the Act entitles the Authority to allow (or not allow) permitted withdrawals on an uninterruptible basis when certain index wells are at or above the following measurements: for the San Antonio pool, when well J-17 is at or above 650 mean sea level (msl); and for the Uvalde Pool, when well J-27 is at or above 865 msl. The section also imposes the duty on the Authority to limit additional withdrawals to ensure that springflows are not affected during critical drought conditions. The Chapter 711 rules incorporate these concepts by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.14(g) of the Act allows the Authority to, by rule, define other pools within the aquifer in accordance with hydrogeologic research, and to establish index wells for any pool to monitor the level of the aquifer to aid the regulation of withdrawals from the pools.

Section 1.14(h) of the Act provides that the Authority generally must ensure, by December 31, 2012, that continuous minimum springflows of Comal and San Marcos Springs are maintained to protect threatened and endangered species to the extent required by federal law. The Chapter 711 rules incorporate this requirement by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.15(a) of the Act directs the Authority "to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by the Act." This section is implemented through the Chapter 711 rules.

Section 1.15(b) of the Act states that "except as provided by §§1.17 and 1.33 of this article, a person may not withdraw water from the aquifer or begin construction of a well or other works designed for the withdrawal of water from the aquifer without obtaining a permit from the authority." This section is implemented through the Chapter 711 rules.

Section 1.15(c) of the Act allows the Authority to issue regular permits, term permits, and emergency permits. This section is implemented through the Chapter 711 rules.

Section 1.15(d) of the Act provides that each permit issued by the Authority must specify the maximum rate and total volume of water that the user may withdraw annually. This section is implemented through the Chapter 711 rules.

Section 1.16(a) of the Act allows an existing user to apply for an initial regular permit by filing a declaration of historical use documenting use of aquifer water during the period from June 1, 1972 through May 31, 1993. The initial regular permits issued pursuant to the Chapter 711 rules will be based upon such.

Section 1.16(b) of the Act, in conjunction with Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996)(holding that declarations must be filed within six months after the effective date of the Act, i.e., December 30, 1996) provides that an existing user's declaration of historical use (permit application) must be file on or before December 30, 1996, and the applicant must timely pay all application fees required by the Authority. It further requires irrigation applicants to submit, as part of their applications, documentation regarding the number of acres irrigated during the historical period.

Section 1.16(c) of the Act provides that an owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under § 1.33 of the Act is not required to file a declaration of historical use.

Section 1.16(d) of the Act requires the Board to grant an initial regular permit to an existing user who: (1) files a declaration and pays fees as required by this section; and (2) establishes by convincing evidence beneficial use of underground water from the aquifer. This requirement is incorporated into the Chapter 711 rules.

Section 1.16(e) of the Act explains the quantity of water to be permitted under an initial regular permit. Pursuant to this section, if enough water is available, each existing user shall be permitted for an amount equal to the user's maximum beneficial use during the historical period. If there is not enough water available, then this section requires the Authority to "proportionately adjust" permit amounts downward in order to meet the withdrawals "caps" discussed above. However, this section also creates certain "permit minimums" for existing irrigation users and for those existing users who have operated a well for three or more years during the historical period. This section also requires the Authority to extrapolate water use on an annual basis for those existing users who do not have a full year's use during the historical period. These concepts are incorporated into Chapter 711, primarily in Subchapter G.

Section 1.16(f) requires the Authority to equitably treat persons whose historic use was affected by participation in a federal program, such as agricultural subsidy programs. This concept is incorporated in the Chapter 711 rules.

Section 1.16(g) of the Act provides that initial regular permits do not have a term and remain in effect until abandoned, cancelled or retired. These concepts are incorporated in the Chapter 711 rules.

Section 1.16(h) of the Act requires the Authority to notify each permit holder of the limitations to which the permit is subject. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter F.

Section 1.17(a) of the Act provides that a person who, on the effective date of this article, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the Authority, if: "(1) the well is in compliance with all statutes and rules relating to well construction, approval, location, spacing, and operation; and (2) by March 1, 1994, the person files a declaration of historical use on a form as required by the authority."

Section 1.18 of the Act allows the Authority, in certain circumstances, to issue additional regular permits. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.19 of the Act allows the Authority to issue term permits and places certain limitations and conditions on the right to withdraw water under such a permit. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.20 of the Act allows the Authority to issue emergency permits under certain circumstances and subject to certain conditions. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.21 of the Act sets out a process by which the Authority is to implement a plan for reducing the withdrawal "cap" from 450,000 to 400,000 acre-feet per year by January 1, 2008. The plan must be enforceable and include various water conservation, reuse, retirement, and other management measures. If, on or after January 1, 2008, total permitted withdrawals still exceed the 400,000 acre-feet cap, then the Authority must implement "equal percentage reductions" of all permits in order to reach the cap. This concept is implemented in Chapter 711, primarily in Subchapter G.

Section 1.22 of the Act provides that the Authority may acquire permitted aquifer rights to be used for: holding in trust for sale or transfer to other users; holding in trust as a means of managing aquifer demand; holding for resale or retirement as a means of achieving pumping reductions required by the Act; or retiring the rights. These concepts are implemented in part in Chapter 711.

Section 1.23(a) of the Act provides that the Authority may require certain permittees to submit and implement water conservation plans and water reuse plans. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.25 of the Act requires the Authority to develop and implement a comprehensive water management plan and, in conjunction with the SCTWAC and other water districts, to develop and implement a plan for providing alternative water supplies, with oversight by state agencies and the Edwards Aquifer Legislative Oversight Committee. The alternative supplies plan shall consider alternative technologies, financing issues, costs and benefits, and environmental issues. These concepts are implemented, in part, in Chapter 711, primarily through Subchapter F.

Section 1.26 of the Act requires the Authority to prepare and coordinate implementation of a critical period management plan which meets certain, enumerated criteria. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.29 of the Act authorizes the imposition of various types of fees on various types of permits. The Chapter 711 rules acknowledge this fee provision, primarily in Subchapter E.

Section 1.31 of the Act provides that nonexempt well owners must install and maintain meters or alternative measuring devices to measure the flow rate and cumulative amount of water withdrawn from each well. These concepts are implemented in the Chapter 711 rules.

Section 1.32 of the Act requires permittees to submit annual water use reports to the Authority. This section is acknowledged in Subchapter F.

Section 1.33 of the Act provides the criteria for exempt wells -- i.e., wells that produce no more than 25,000 gallons of water per day for domestic and livestock use and that are not within or serving a subdivision requiring platting. The section explains that such wells are exempt from metering requirements. However, such wells must be registered with the Authority. These concepts are implemented in Chapter 711.

Section 1.34 of the Act imposes certain limitations upon the ways in which aquifer water and/or water rights may be transferred (alienated). First, aquifer water must be used within the Authority's boundaries. Second, the section allows the Authority to establish rules by which a person may install water conservation equipment and sell the water conserved. Third, the section further provides that a holder of a permit for irrigation use may not transfer more than 50 percent of the irrigation rights initially permitted and that the user's remaining irrigation water rights must be used in accordance with the original permit and must pass with transfer of the irrigated land. These concepts are implemented, in part, in Chapter 711.

Section 1.35 of the Act prohibits: withdrawing aquifer water except as authorized by a permit; violating permit terms or conditions; wasting aquifer water; polluting or contributing to the pollution of the aquifer; or violating the Act or an Authority rule. These concepts are implemented in Chapter 711.

Section 1.36 of the Act empowers the Authority to enter orders enforcing the terms and conditions of permits, orders, or rules, and to draft rules suspending permits for failure to pay required fees or violations of permits, orders or rules. These concepts are implemented, in part, in Chapter 711.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This rulemaking is in furtherance of this legislative mandate.

Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711derive in part from this statutory authority and implement this chapter and the supporting rules.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.101(a) empowers the Authority to make and enforce rules to provide for conserving, preserving, protecting, and recharging of the groundwater in order to, among other things, prevent waste and carry out the duties provided elsewhere in Chapter 36. This requirement is implemented, in large part, through Chapter 711.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.111 requires the Authority to require aquifer users to keep and maintain reports of drilling, equipping, and completing water wells and the production and uses of groundwater. Chapter 711 implements these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. The section further specifies the permitted format and contents of permit applications, and lays out criteria for the district to consider when ruling on a permit application. The section also provides that permits may be issued subject to the district's rules and other restrictions. The Chapter 711 rules incorporate these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.1131 specifies what may be included as elements of a permit issued by a district.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.115 provides that no person may drill a well, alter the size of a well or well pump, or operate a well without first obtaining a permit from the Authority.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that drilling a well without a required permit or operating a well at a higher rate of production than the rate approved for the well is declared to be illegal, wasteful per se, and a nuisance. This concept is incorporated into Chapter 711, primarily in the definition of waste found in § 711.1.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.211(a) endows districts such as the Authority with the "functions, powers, authority, rights, and duties that will permit accomplishment of the purposes for which it was created or the purposes authorized by the constitution, this code, or any other law." This broad delegation of powers is incorporated into the Chapter 711 rules.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.221 empowers representatives of the Authority to enter land and perform tests and other inspections. This authority is incorporated into Chapter 711, primarily in § 711.416.

16 TAC, Chapter 76. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation (TDLR).) The TDLR's rules implementing Chapter 32 are found at 16 TAC, Chapter 76. These rules impose numerous duties upon well drillers and well owners related to well construction, operation, and plugging. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 implement, in part, the rules found in 16 TAC, Chapter 76.

§711.166.Groundwater Available for Permitting for Term Permits.

(a)

The amount of groundwater authorized to be withdrawn from the aquifer pursuant to term permits is not subject to the maximum total permitted withdrawals provided for in §711.164(a) and (b) of this chapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits).

(b)

The amount of groundwater from the aquifer that the board may permit to be withdrawn pursuant to term permits shall not exceed the number of acre-feet for each calendar year established by the board in its order issued under § 711.102 of this chapter (relating to Term Permits) authorizing the filing of applications for term permits when the following index wells are measuring at the following groundwater levels:

(1)

for wells within the San Antonio pool, and well J-17 is greater than 665 feet above mean sea level; or

(2)

for wells within the Uvalde pool, well J-27 is greater than 865 feet above mean sea level.

§711.168.Groundwater Available for Permitting for Emergency Permits.

(a)

The amount of groundwater authorized to be withdrawn from the aquifer pursuant to emergency permits is not subject to the maximum total permitted withdrawals provided for in §711.164(a) and (b) of this chapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits).

(b)

Irrespective of the groundwater levels of wells J-17 or J-27, the amount of groundwater from the aquifer that the board may permit to be withdrawn pursuant to emergency permits shall not exceed the amount necessary to prevent the loss of life or to prevent severe, imminent threats to the public health or safety for each calendar year.

§711.172.Proportional Adjustment of Initial Regular Permits.

(a)

Applicability. This section applies only to initial regular permits.

(b)

Definitions. The following words and terms, when used in this subchapter, shall have the following meanings, unless the context clearly indicates otherwise:

(1)

Historical average minimum-an amount, as determined by the authority, for an applicant who operated a well in three or more years during the historical period, equal to the average amount of groundwater withdrawn annually during the historical period and put to beneficial use, calculated as follows:

Figure: 31 TAC §711.172(b)(1)

(2)

Irrigator minimum-an amount, as determined by the authority, for an applicant for irrigation use, equal to two acre-feet times each acre of land the applicant, or his contract user, prior user, or former existing user actually irrigated in any one calendar year during the historical period if:

(A)

the applicant, or his contract user, prior user or former existing user owned, leased, or otherwise had a legal right to irrigate the land during the historical period; and

(B)

the applicant, or his prior user or former existing user owned the well from which the land was irrigated.

(3)

Maximum historical use (MHU)-The amount of groundwater from the aquifer as determined by the authority that, unless proportionally adjusted, an applicant for an initial regular permit is authorized to withdraw equal to the greater of the following, as may be applicable:

(A)

an applicant's irrigator minimum;

(B)

for an applicant who has beneficial use without waste during the historical period for a full calendar year, the applicant's actual maximum beneficial use of groundwater from the aquifer without waste during any one full calendar year of the historical period; or

(C)

for an applicant who has beneficial use without waste during the historical period, but, due to the applicant's activities not having been commenced and in operation for a full calendar year, the applicant does not have beneficial use for a full calendar year, the applicant's extrapolated maximum beneficial use calculated as follows: the amount of groundwater that would normally have been placed to beneficial use without waste by the applicant for a full calendar year during the historical period for the applied for purpose had the applicant's activities been commenced and in operation for a full calendar year during the historical period.

(4)

Operate a well-The withdrawal of groundwater from a well for a beneficial use.

(5)

Step-up amount (SUA) - The difference between an applicant's irrigator or historical average minimum, if any, and the applicant's PA-1 amount as determined in subsection (g)(5) of this section. Where an irrigator applicant qualifies for both an irrigator minimum and an historical average minimum, the SUA shall be equal to the difference between whichever of the applicant's minimums is greater and the applicant's PA-1 amount.

(c)

Purpose of Proportional Adjustment. The purpose of proportional adjustment is to adjust the aggregate maximum historical use of all initial regular permits to attain the amount of groundwater available for permitting in § 711.164(a) of this subchapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits).

(d)

Proportionality. An adjustment is proportional when the adjustment of the maximum historical use of an initial regular permit maintains a constant ratio in relation to the adjustment of the maximum historical use of all other permits.

(e)

Duty to Proportionally Adjust. If the total aggregate maximum historical use of all initial regular permits exceeds the amount of groundwater available for permitting in § 711.164(a) of this chapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits), the board shall, pursuant to this section, proportionally adjust the maximum historical use of each permit.

(f)

Proportional Adjustment Orders. The board shall implement and effectuate proportional adjustment by order of the board. Proportional adjustment orders may be provisional for a fixed period of time, or may be final.

(g)

Proportional Adjustment Procedure. Proportional adjustment of initial regular permits, if required, shall be performed as follows:

(1)

For each applicant who is to be issued an initial regular permit, the board shall determine and assign a maximum historical use.

(2)

For each applicant for irrigation use who is to be issued an initial regular permit, the board shall determine and assign an irrigator minimum, if any.

(3)

For each applicant who operated a well for three or more years during the historical period and who is to be issued an initial regular permit, the board shall determine and assign a historical average minimum, if any.

(4)

Phase-1Proportional Adjustment Factor. If the total of all maximum historical uses of all applicants for initial regular permits to whom the board will issue an initial regular permit exceeds 450,000 acre feet per annum, then the board shall calculate a Phase-1 proportional adjustment factor ("PA-1 Factor") as follows:

Figure: 31 TAC §711.172(g)(4)

(5)

Phase-1 Proportionally Adjusted Amount. The board shall then calculate a proportionally adjusted amount ("PA-1 amount") for each applicant to be issued an initial regular permit as follows:

Figure: 31 TAC §711.172(g)(5)

(6)

Step-up Amount. For each applicant assigned an historical average or irrigator minimum and whose PA-1 amount is less than the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two), the board shall determine and assign a step-up amount. An applicant whose PA-1 amount is equal to or greater than its irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) shall not receive a step-up amount.

(7)

Phase- 2 Proportional Adjustment Factor. If the total of all PA-1 amounts plus all step-up amounts remaining after the Board has issued agreed orders pursuant to § 711.180 of this chapter (relating to Voluntary Waiver of Applications for Initial Regular Permits) exceeds 450,000 acre feet per annum, then the board shall calculate a Phase-2 proportional adjustment factor ("PA- 2 Factor") as follows:

Figure: 31 TAC §711.172(g)(7)

(8)

Phase-2 Proportionally Adjusted Amount. The board shall then calculate a Phase-2 proportionally adjusted amount ("PA-2 amount") for each applicant issued an initial regular permit as follows:

(A)

For each applicant eligible to receive a step-up amount:

Figure: 31 TAC §711.172(g)(8)(A)

(B)

For each applicant not eligible to receive a step-up amount:

Figure: 31 TAC §711.172(g)(8)(B)

(9)

The board shall issue an initial regular permit to each eligible applicant establishing a groundwater withdrawal amount authorized to be withdrawn as provided in §711.176(b) and (c) of this chapter (relating to Groundwater Withdrawals Amount for Initial Regular Permits; Compensation for Phase-2 Proportional Amounts).

(h)

If the board issues a proportional adjustment order, then the board shall account for all groundwater proportionally adjusted from each initial regular permit. If additional groundwater becomes available for permitting pursuant to § 1.14(d) of the act and subchapter K of this chapter (relating to Additional Groundwater Supplies), then the proportionally adjusted amounts shall be restored through the inverse application of subsection (g) of this section in accordance with § 711.304(3) of this chapter (relating to Allocation of Additional Groundwater Supplies).

§711.176.Groundwater Withdrawal Amounts for Initial Regular Permits; Compensation for Phase-2 Proportional Amounts.

(a)

If the aggregate maximum historical use of all applicants to be issued initial regular permits does not exceed the amount of groundwater available for permitting in §711.164(a) of this chapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits), then an applicant shall receive an initial regular permit authorizing the withdrawal of groundwater from the aquifer in the amount of the maximum historical use.

(b)

If the aggregate maximum historical use of all applicants to be issued initial regular permits exceeds the amount of groundwater available for permitting in §711.164(a) of this chapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits), then an applicant shall receive an initial regular permit authorizing the withdrawal of groundwater from the aquifer in the following amounts:

(1)

if the applicant does not qualify for an irrigator or historical average minimum, and no PA-2 amount is calculated pursuant to §711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), then in an amount equal to the applicant's PA-1 amount as calculated in §711.172(g)(4) and(5);

(2)

if the applicant does not qualify for an irrigator or historical average minimum, and a PA-2 amount is calculated pursuant to § 711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), then in an amount equal to the applicant's PA-2 amount;

(3)

if the applicant qualifies for an irrigator or historical average minimum, no PA-2 amount is calculated pursuant to §711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), and the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) is less than the applicant's PA-1 amount as calculated in §711.172(g)(4) and (5), then in an amount equal to the applicant's PA-1 amount;

(4)

if the applicant qualifies for an irrigator or historical average minimum, no PA-2 amount is calculated pursuant to §711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), and the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) is greater than the applicant's PA-1 amount as calculated in §711.172(g)(4) and (5), then in an amount equal to the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two);

(5)

if the applicant qualifies for an irrigator or historical average minimum, a PA-2 amount is calculated pursuant to §711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), and the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) is less than the applicant's PA-2 amount, then in an amount equal to the applicant's PA-2 amount; or

(6)

if the applicant qualifies for an irrigator or historical average minimum, a PA-2 amount is calculated pursuant to §711.172(g)(7) and (8) of this chapter (relating to Proportional Adjustment of Initial Regular Permits), and the applicant's irrigator or historical average minimum (or where an irrigator applicant qualifies for both minimums, the greater of the two) is greater than the applicant's PA-2 amount, then in an amount equal to the applicant's PA-2 amount. In such a case, the difference between the applicant's PA-2 amount and the applicable minimum may not be withdrawn by the applicant, but instead, the authority shall provide to the applicant compensation for this amount at the fair market value as that term is defined in §11.0275, Texas Water Code (relating to Fair Market Value).

(c)

Initial regular permits issued by the board pursuant to this section may be issued with a provisional groundwater withdrawal amount until the total amount of groundwater permitted for withdrawal in initial regular permits is finally determined following an opportunity for contested case hearings on all initial regular permit applications, as provided in §711.172(f) of this chapter (relating to Proportional Adjustment of Initial Regular Permits). The authority may periodically issue Proportional Adjustment Orders in order to assure that the amount of groundwater permitted for withdrawal in initial regular permits does not exceed the amount available for permitted withdrawals under §711.164 of this chapter (relating to Groundwater Available for Permitted Withdrawals for Initial and Additional Regular Permits).

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007359

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204


Subchapter I. GENERAL PROHIBITIONS

31 TAC §§711.220, 711.222, 711.224, 711.226, 711.228, 711.230, 711.232, 711.234

VI. CONCISE RESTATEMENT OF THE STATUTORY PROVISIONS UNDER WHICH THE RULES ARE ADOPTED.

The new sections are adopted pursuant to the following statutory provisions:

Section 1.01 of the Act contains the findings of the Texas Legislature that the Edwards Aquifer is a distinctive natural resource and that a special regional management district (the Authority) is required for the effective control of the resource to protect terrestrial and aquatic life, domestic and municipal water supplies, existing industries, and the economic development of the state.

Section 1.03(1) defines the "Edwards Aquifer."

Section 1.03(4) of the Act defines "beneficial use" to mean the use of water that is economically necessary for a purpose authorized by law when reasonable intelligence and reasonable diligence are used in applying the water to that purpose. The concept of beneficial use is incorporated into the permitting rules of Chapter 711.

Section 1.03(9) of the Act defines "domestic or livestock use." This concept is incorporated into the exempt well rules found within Chapter 711.

Section 1.03(10) of the Act defines "existing user" as a person who has withdrawn and beneficially used underground water from the aquifer on or before June 1, 1993. This concept is incorporated into the Chapter 711 rules, while also accounting for the beneficial use requirement and including the successors in interest of existing users within the definition.

Section 1.03(11) of the Act defines "industrial use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(12) of the Act defines "irrigation use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(13) of the Act defines "livestock." The Chapter 711 rules incorporate this concept when determining whether a well qualifies as "exempt" from permitting requirements.

Section 1.03(14) of the Act defines "municipal use." The Chapter 711 rules incorporate this concept within the types of uses for which aquifer water may be withdrawn.

Section 1.03(21) of the Act defines "waste." This concept is incorporated into the Chapter 711 rules, while also including other practices which are considered wasteful under the Act or under the long-standing water law concept of beneficial use.

Section 1.07 of the Act provides, in part, that the actions taken by the Authority pursuant to the Act may not be construed as depriving or divesting owners of their ownership rights as landowners in underground water, subject to rules adopted by the Authority.

Section 1.08(a) of the Act provides that the Authority "has all of the powers, rights, and privileges necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer." This section provides the Authority with broad and general powers to take actions as necessary to manage, conserve, preserve, and protect the aquifer and to increase the recharge of, and prevent the waste or pollution of water in, the aquifer. These rules further those objectives.

Section 1.08(b) makes it clear that the Authority's powers apply only to water within or withdrawn from the Edwards Aquifer, and not to surface water.

Section 1.11(a) of the Act provides that the Board of Directors ("Board") of the Authority "shall adopt rules necessary to carry out the authority's powers and duties under (Article 1 of the Act), including rule governing procedures of the board and the authority." This section provides broad rulemaking authority to implement the various substantive and procedures programs set forth in the Act related to the Edwards Aquifer, including the permitting program.

Section 1.11(b) of the Act requires the Authority to "ensure compliance with permitting, metering, and reporting requirements and . . . regulate permits." This section, in conjunction with § 1.11(a) and (h) of the Act, and § 2001.004(1) of the APA, requires the Authority to adopt and enforce the Chapter 711 rules.

Section 1.11(d)(2) of the Act empowers the Authority to enter into contracts. Pursuant to this section, the Authority may enter into contracts with well owners concerning meters and reimbursement for same under Subchapter M of the Chapter 711 rules.

Section 1.11(d)(8) of the Act provides that the Authority may close abandoned, wasteful or dangerous wells. The Authority's rules relating to the requirement of beneficial use and the prohibition of waste, as well as the closure of abandoned wells derive in part from this statutory authority.

Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 of the Texas Water Code and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) Chapter 32 imposes certain duties upon drillers of water wells and the owners of those wells. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 derive in part from this statutory authority.

Section 1.11(d)(11) of the Act provides that the Authority may require to be furnished with copies of the water well drillers' logs that are required by Chapter 32 of the Texas Water Code.

Section 1.11(h) of the Act provides, among other things, that the Authority is "subject to" the APA. This section essentially provides that the Authority is required to comply with the APA for its rulemaking, even though the Authority is a political subdivision and not a state agency that would generally be subject to APA requirements. Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures."

Section 1.13 of the Act requires the Authority to allow credit to be given for certified reuse of aquifer water. The Authority will likely adopt rules implementing this section. This concept is acknowledged in Subchapter F.

Section 1.14(a) of the Act provides that authorizations to withdraw aquifer water shall be limited in order to: protect water quality of the aquifer and surface streams to which the aquifer contributes springflow; achieve water conservation; maximize beneficial use of water from the aquifer; protect aquatic and wildlife habitat as well as federally or state-designated threatened or endangered species; and provide for instream uses, bays and estuaries. The Chapter 711 rules are adopted, in large part, pursuant to these statutory mandates.

Section 1.14(b) of the Act imposes, subject to certain limitations, an initial aquifer withdrawal "cap" for permitted withdrawals of 450,000 acre-feet per year, until December 31, 2007. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(c) of the Act imposes, subject to certain limitations, an aquifer withdrawal "cap" for permitted withdrawals of 400,000 acre-feet per year, beginning January 1, 2008. The Chapter 711 rules implement this cap, explain to which permits it applies, how it can be raised, and other procedural details.

Section 1.14(d) of the Act provides that either of the caps listed above may be raised by the Authority if, through studies and implementation of certain strategies, the authority, in consultation with state and federal agencies, determines the caps may be raised.

Section 1.14(e) of the Act requires the Authority to prohibit withdrawals from new wells drilled after the effective date of the Act unless the "caps" are raised and then only on an interruptible basis. The Chapter 711 rules incorporate this prohibition.

Section 1.14(f) of the Act entitles the Authority to allow (or not allow) permitted withdrawals on an uninterruptible basis when certain index wells are at or above the following measurements: for the San Antonio pool, when well J-17 is at or above 650 mean sea level (msl); and for the Uvalde Pool, when well J-27 is at or above 865 msl. The section also imposes the duty on the Authority to limit additional withdrawals to ensure that springflows are not affected during critical drought conditions. The Chapter 711 rules incorporate these concepts by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.14(g) of the Act allows the Authority to, by rule, define other pools within the aquifer in accordance with hydrogeologic research, and to establish index wells for any pool to monitor the level of the aquifer to aid the regulation of withdrawals from the pools.

Section 1.14(h) of the Act provides that the Authority generally must ensure, by December 31, 2012, that continuous minimum springflows of Comal and San Marcos Springs are maintained to protect threatened and endangered species to the extent required by federal law. The Chapter 711 rules incorporate this requirement by making withdrawals subject to various conditions keyed on drought conditions and critical period management rules.

Section 1.15(a) of the Act directs the Authority "to manage withdrawals from the aquifer and manage all withdrawal points from the aquifer as provided by the Act." This section is implemented through the Chapter 711 rules.

Section 1.15(b) of the Act states that "except as provided by §§1.17 and 1.33 of this article, a person may not withdraw water from the aquifer or begin construction of a well or other works designed for the withdrawal of water from the aquifer without obtaining a permit from the authority." This section is implemented through the Chapter 711 rules.

Section 1.15(c) of the Act allows the Authority to issue regular permits, term permits, and emergency permits. This section is implemented through the Chapter 711 rules.

Section 1.15(d) of the Act provides that each permit issued by the Authority must specify the maximum rate and total volume of water that the user may withdraw annually. This section is implemented through the Chapter 711 rules.

Section 1.16(a) of the Act allows an existing user to apply for an initial regular permit by filing a declaration of historical use documenting use of aquifer water during the period from June 1, 1972 through May 31, 1993. The initial regular permits issued pursuant to the Chapter 711 rules will be based upon such.

Section 1.16(b) of the Act, in conjunction with Barshop v. Medina County Underground Water Conservation District, 925 S.W. 2d 618, 630 (Tex. 1996)(holding that declarations must be filed within six months after the effective date of the Act, i.e., December 30, 1996) provides that an existing user's declaration of historical use (permit application) must be file on or before December 30, 1996, and the applicant must timely pay all application fees required by the Authority. It further requires irrigation applicants to submit, as part of their applications, documentation regarding the number of acres irrigated during the historical period.

Section 1.16(c) of the Act provides that an owner of a well from which the water will be used exclusively for domestic use or watering livestock and that is exempt under § 1.33 of the Act is not required to file a declaration of historical use.

Section 1.16(d) of the Act requires the Board to grant an initial regular permit to an existing user who: (1) files a declaration and pays fees as required by this section; and (2) establishes by convincing evidence beneficial use of underground water from the aquifer. This requirement is incorporated into the Chapter 711 rules.

Section 1.16(e) of the Act explains the quantity of water to be permitted under an initial regular permit. Pursuant to this section, if enough water is available, each existing user shall be permitted for an amount equal to the user's maximum beneficial use during the historical period. If there is not enough water available, then this section requires the Authority to "proportionately adjust" permit amounts downward in order to meet the withdrawals "caps" discussed above. However, this section also creates certain "permit minimums" for existing irrigation users and for those existing users who have operated a well for three or more years during the historical period. This section also requires the Authority to extrapolate water use on an annual basis for those existing users who do not have a full year's use during the historical period. These concepts are incorporated into Chapter 711, primarily in Subchapter G.

Section 1.16(f) requires the Authority to equitably treat persons whose historic use was affected by participation in a federal program, such as agricultural subsidy programs. This concept is incorporated in the Chapter 711 rules.

Section 1.16(g) of the Act provides that initial regular permits do not have a term and remain in effect until abandoned, cancelled or retired. These concepts are incorporated in the Chapter 711 rules.

Section 1.16(h) of the Act requires the Authority to notify each permit holder of the limitations to which the permit is subject. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter F.

Section 1.17(a) of the Act provides that a person who, on the effective date of this article, owns a producing well that withdraws water from the aquifer may continue to withdraw and beneficially use water without waste until final action on permits by the Authority, if: "(1) the well is in compliance with all statutes and rules relating to well construction, approval, location, spacing, and operation; and (2) by March 1, 1994, the person files a declaration of historical use on a form as required by the authority."

Section 1.18 of the Act allows the Authority, in certain circumstances, to issue additional regular permits. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.19 of the Act allows the Authority to issue term permits and places certain limitations and conditions on the right to withdraw water under such a permit. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.20 of the Act allows the Authority to issue emergency permits under certain circumstances and subject to certain conditions. This concept is incorporated into the Chapter 711 rules, primarily in Subchapter E.

Section 1.21 of the Act sets out a process by which the Authority is to implement a plan for reducing the withdrawal "cap" from 450,000 to 400,000 acre-feet per year by January 1, 2008. The plan must be enforceable and include various water conservation, reuse, retirement, and other management measures. If, on or after January 1, 2008, total permitted withdrawals still exceed the 400,000 acre-feet cap, then the Authority must implement "equal percentage reductions" of all permits in order to reach the cap. This concept is implemented in Chapter 711, primarily in Subchapter G.

Section 1.22 of the Act provides that the Authority may acquire permitted aquifer rights to be used for: holding in trust for sale or transfer to other users; holding in trust as a means of managing aquifer demand; holding for resale or retirement as a means of achieving pumping reductions required by the Act; or retiring the rights. These concepts are implemented in part in Chapter 711.

Section 1.23(a) of the Act provides that the Authority may require certain permittees to submit and implement water conservation plans and water reuse plans. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.25 of the Act requires the Authority to develop and implement a comprehensive water management plan and, in conjunction with the SCTWAC and other water districts, to develop and implement a plan for providing alternative water supplies, with oversight by state agencies and the Edwards Aquifer Legislative Oversight Committee. The alternative supplies plan shall consider alternative technologies, financing issues, costs and benefits, and environmental issues. These concepts are implemented, in part, in Chapter 711, primarily through Subchapter F.

Section 1.26 of the Act requires the Authority to prepare and coordinate implementation of a critical period management plan which meets certain, enumerated criteria. These concepts are implemented in part in Chapter 711, primarily through Subchapter F.

Section 1.29 of the Act authorizes the imposition of various types of fees on various types of permits. The Chapter 711 rules acknowledge this fee provision, primarily in Subchapter E.

Section 1.31 of the Act provides that nonexempt well owners must install and maintain meters or alternative measuring devices to measure the flow rate and cumulative amount of water withdrawn from each well. These concepts are implemented in the Chapter 711 rules.

Section 1.32 of the Act requires permittees to submit annual water use reports to the Authority. This section is acknowledged in Subchapter F.

Section 1.33 of the Act provides the criteria for exempt wells -- i.e., wells that produce no more than 25,000 gallons of water per day for domestic and livestock use and that are not within or serving a subdivision requiring platting. The section explains that such wells are exempt from metering requirements. However, such wells must be registered with the Authority. These concepts are implemented in Chapter 711.

Section 1.34 of the Act imposes certain limitations upon the ways in which aquifer water and/or water rights may be transferred (alienated). First, aquifer water must be used within the Authority's boundaries. Second, the section allows the Authority to establish rules by which a person may install water conservation equipment and sell the water conserved. Third, the section further provides that a holder of a permit for irrigation use may not transfer more than 50 percent of the irrigation rights initially permitted and that the user's remaining irrigation water rights must be used in accordance with the original permit and must pass with transfer of the irrigated land. These concepts are implemented, in part, in Chapter 711.

Section 1.35 of the Act prohibits: withdrawing aquifer water except as authorized by a permit; violating permit terms or conditions; wasting aquifer water; polluting or contributing to the pollution of the aquifer; or violating the Act or an Authority rule. These concepts are implemented in Chapter 711.

Section 1.36 of the Act empowers the Authority to enter orders enforcing the terms and conditions of permits, orders, or rules, and to draft rules suspending permits for failure to pay required fees or violations of permits, orders or rules. These concepts are implemented, in part, in Chapter 711.

Section 2001.004(1) of the APA requires agencies subject to the APA to "adopt rules of practice stating the nature and requirements of all available formal and informal procedures." This rulemaking is in furtherance of this legislative mandate.

Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation.) The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711derive in part from this statutory authority and implement this chapter and the supporting rules.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.101(a) empowers the Authority to make and enforce rules to provide for conserving, preserving, protecting, and recharging of the groundwater in order to, among other things, prevent waste and carry out the duties provided elsewhere in Chapter 36. This requirement is implemented, in large part, through Chapter 711.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.111 requires the Authority to require aquifer users to keep and maintain reports of drilling, equipping, and completing water wells and the production and uses of groundwater. Chapter 711 implements these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.113 empowers districts such as the Authority to require permits for drilling, equipping, or completing wells or for altering the size of wells or well pumps. The section further specifies the permitted format and contents of permit applications, and lays out criteria for the district to consider when ruling on a permit application. The section also provides that permits may be issued subject to the district's rules and other restrictions. The Chapter 711 rules incorporate these requirements.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.1131 specifies what may be included as elements of a permit issued by a district.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.115 provides that no person may drill a well, alter the size of a well or well pump, or operate a well without first obtaining a permit from the Authority.

Chapter 36 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 36.119(a) decrees that drilling a well without a required permit or operating a well at a higher rate of production than the rate approved for the well is declared to be illegal, wasteful per se, and a nuisance. This concept is incorporated into Chapter 711, primarily in the definition of waste found in § 711.1.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.211(a) endows districts such as the Authority with the "functions, powers, authority, rights, and duties that will permit accomplishment of the purposes for which it was created or the purposes authorized by the constitution, this code, or any other law." This broad delegation of powers is incorporated into the Chapter 711 rules.

Chapter 49 of the Texas Water Code generally applies to groundwater districts such as the Authority. Section 49.221 empowers representatives of the Authority to enter land and perform tests and other inspections. This authority is incorporated into Chapter 711, primarily in § 711.416.

16 TAC, Chapter 76. Section 1.11(d)(10) of the Act provides that the Authority may enforce Chapter 32 and TNRCC rules adopted thereunder. Chapter 32 of the Texas Water Code imposes certain duties upon drillers of water wells and the owners of those wells. (Chapter 32 is now administered not by the TNRCC, but by the Texas Department of Licensing and Regulation (TDLR).) The TDLR's rules implementing Chapter 32 are found at 16 TAC, Chapter 76. These rules impose numerous duties upon well drillers and well owners related to well construction, operation, and plugging. The Authority's rules relating to well construction, well abandonment and cancellation contained within Chapter 711 implement, in part, the rules found in 16 TAC, Chapter 76.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on October 18, 2000.

TRD-200007361

Gregory M. Ellis

General Manager

Edwards Aquifer Authority

Effective date: November 7, 2000

Proposal publication date: August 11, 2000

For further information, please call: (210) 222-2204