Tag Archive for: Groundwater Management Area 14

Last Chance to Fight Subsidence: Comment Now

On Friday, July 23, 2021 – one week from today – the public comment period will close on the proposed Desired Future Conditions (DFCs) for the Lone Star Groundwater Conservation District. DFCs represent goals for preserving a percentage of groundwater for future generations and preventing subsidence. A contentious debate has raged for years between those who profit from the pumping of cheap groundwater and those whose property will be damaged by the subsidence it causes.

Subsidence Caused by Excessive Groundwater Pumping

Subsidence is a sinking of property relative to others around it. Unlimited pumping removes the water under homes and businesses that helps to prop them up. When the water is removed, it can create a bowl in the landscape and contribute to flooding.

The Woodlands has already experienced this, where a “graben” is developing between two fault lines. Graben is a geologic term meaning “a block of the earth’s crust between two faults displaced downward relative to the blocks on either side.” Such displacement can damage streets, bridges, pipelines, driveways, foundations and homes.

Modeling has shown that subsidence could cause more than 3.5 feet of sinking in southern and eastern Montgomery County, growing population centers where groundwater pumping is greatest. Subsidence is already a serious concern in The Woodlands where it has triggered faults.

Predicted subsidence in Montgomery County if Lone Star allows the pumping of 115,000 acre-feet per year.

Conflict Between GMA-14 and Lone Star Groundwater Conservation District

Years ago, Texas established Groundwater Management areas to bind the people of a region together, and ensure that public interests outweigh the self-interest of a few powerful people. GMA-14 covers most of southeast Texas. It includes five groundwater conservation districts, comprising 20 counties.

GMA-14’s Proposed DFCs

GMA-14 has debated its next set of desired future conditions (DFCs) since 2016. At its last meeting, members finally adopted the following statement. 

In each county in GMA 14, no less than 70 percent median available drawdown remaining in 2080 and no more than an average of 1.0 additional foot of subsidence between 2009 and 2080.

GMA-14 Desired Future Conditions 

Click here for the full text surrounding the DFCs. 

Let’s break that down:

  • The numbers represent averages or medians within each county.
  • “70% median available drawdown remaining in 2080” means counties cannot draw down their aquifer(s) more than 30%. Seventy percent must remain at the end of the period – 2080. Each district controls this by monitoring aquifer levels and adjusting annual well permits to meet the goal.
  • “No more than an average of 1.0 additional foot of subsidence between 2009 and 2080” means “county-wide.”

Understand that some areas have already experienced significant subsidence in the last decade. For instance, before moving to more surface water, the Woodlands was sinking about 2 centimeters per year. That’s more than three quarters of an inch per year, 7.8 inches in ten years, or almost 2 feet during the life of a 30 year mortgage.

When The Woodlands began using more surface water in 2016 after completion of a surface water pipeline from Lake Conroe, the rate of subsidence dropped 75%.

Subsidence: a Check against Excessive Drawdown

The subsidence metric (1 foot additional) is a check on drawdown. Aquifers can recharge, but subsidence cannot reverse itself.

The subsidence metric ensures that groundwater pumpers won’t deplete aquifers, then magically claim they will recharge in the last year of the monitoring period. It protects both groundwater levels and homes.

Simon Sequeira, owner of a large for-profit groundwater pumping utility in Montgomery County, has fought the inclusion of a subsidence metric in the DFCs for years. This four-page letter to GMA-14 spells out his reasons why a subsidence metric should NOT be included in DFCs. In it, he first claims that drawdown will become an issue before subsidence becomes evident. He then threatens to sue everyone in sight if a subsidence metric IS included. Duh!

If he really believed subsidence is not a factor, why does he protest it so much? And why won’t he answer that question?

“The lady doth protest too much, methinks,” said Shakespeare in Hamlet – a phrase used in everyday speech to indicate doubt regarding the truth of an overly strong denial. 

The simple fact is this. Subsidence was already happening with pumping rates lower than the DFCs proposed. When MoCo started using more surface water, the subsidence leveled off. But get ready for more if Sue-Happy Simon gets his way.

Learn More and Protect Your Property Rights

To learn more about subsidence, check out:

Please consider emailing the Lone Star Groundwater Conservation District before July 23rd. Demand that they adopt the subsidence metric proposed by GMA-14 and a sustainable pumping rate.

Compose your own email to info@lonestargcd.org or just click this link. Don’t forget to replace the placeholders for contact info with your real info and hit send. It only takes a few seconds.

Posted by Bob Rehak on 7/16/2021

1417 Days after Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.

LSGCD Finally Approves Phase II of Subsidence Study, Only One Problem…

At its April 13, 2021 board meeting, the Lone Star Groundwater Conservation District (LSGCD) finally approved Phase 2 of its Subsidence Study. Approval of the study had been on the agenda for months, but kept getting postponed. It was only after Groundwater Management Agency 14 (GMA-14) insisted on a subsidence metric in its Desired Future Conditions (DFCs) last Friday, that LSGCD finally approved the study this Tuesday.

Samantha Reiter, General Manager of LSGCD, has repeatedly stated for months that subsidence is not a limiting factor in Montgomery County, so it shouldn’t be included in DFCs for Montgomery County. She made three motions in the GMA-14 meeting last week that would have let LSGCD avoid a subsidence limitation that she claimed did not apply.

The study – which might or might not support that conclusion – will take 60 weeks to complete. But the Texas Water Development Board deadline for DFCs from all groundwater management areas is January 5, 2022 – in 38 weeks.

The study will cost $122,700 and arrive 22 weeks after the train leaves the station.

For the full details of the study scope of work, costs, and timetable that LSGCD approved last night, click here.

Scope of Work to Focus on MoCo

A thorough reader will also note that while LSGCD has been trumpeting “subsidence is not a limiting factor here,” the scope of work acknowledges that Phase One of the study was basically a literature review of pre-existing studies. Most of those were based in other counties.

The ostensible purpose of the Phase Two study is to develop data specific to Montgomery County and LSGCD (see pages 1/2). So it appears, they may not really obtain data to prove or disprove their claim until long after DFCs must be finalized by statute.

Lone Star Still Hopeful It Can Avoid Subsidence Metric

To her credit, Ms. Reiter admitted later in the board meeting that GMA-14 rejected her three alternative motions to make a subsidence DFC optional. However, during that discussion, she also said she thought part of the pushback came because she circulated her motion(s) for review at 11 p.m. the night before the meeting. That angered some people who said they had been begging for motions to review, even if only in draft form, for months.

Reiter stated last night to her board that she hoped those GMA-14 members would reconsider her motions in October. That would happen after the public comment period on the DFCs adopted last Friday. However, making a major change at that point might trigger a second 90-day public comment period. That’s going to be tight. Only 91 days exist between October 6th (the next GMA-14 meeting) and January 5, the state’s mandatory deadline.

Two Potential Issues with Study Scope

First, LSGCD said it plans to review the DFCs with stakeholders. But many of the people impacted are outside Montgomery County and they aren’t considered “stakeholders.” For instance, models show that at the rate LSGCD wants to pump groundwater, it would cause approximately 3 feet of subsidence in the Kingwood, Humble, Atascocita and Huffman areas but only 1 foot of subsidence at the Lake Houston Dam. That would essentially bring floodwaters two feet closer to upstream homes in Harris County. But we’re not considered LSGCD stakeholders.

Subsidence in Harris County that could be triggered if Lone Star pumps as much water as it voted to.
Lake Houston Dam During Harvey had five times more water going over it than goes over Niagra Falls on an average day. More than 16,000 homes and 3,300 businesses in the Lake Houston Area flooded during Harvey.

Second, the scope of work for the Lone Star subsidence study says, “we will evaluate logs up to 10 miles beyond the Montgomery County boundary to aid in constraining the interpolation of surfaces within LSGC.” Said another way, it appears that they won’t evaluate their impact on Harris County. The purpose of a groundwater management area is to bind all the people of a region together in a common cause. But that doesn’t seem to be happening here.

Fortunately, Harris County residents will still have an opportunity to provide input directly to GMA-14 or the Harris-Galveston Subsidence District.

People must stay engaged on this issue. We should not assume it is behind us simply because GMA-14 adopted some proposed DFCs for public comment.

Posted by Bob Rehak on 4/14/2021

1324 Days since Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.

LSGCD Votes to Almost Double Groundwater Pumping, Treat Subsidence as PR problem

The Lone Star Groundwater Conservation District (LSGCD) board voted Wednesday in a special meeting to throw caution and conservation to the wind. In a long-delayed vote, the board unanimously agreed to adopt “Desired Future Conditions” (DFCs) that allow groundwater pumping to increase from approximately 60,000 acre fee per year to 115,000. This was the third of three alternatives they considered and the one that caused up to 3.5 feet of subsidence in southern MoCo. The board also voted unanimously NOT to include a subsidence metric in their DFCs and to hire an Austin PR firm, The Mach 1 Group, to handle the PR fallout.

Still No Action to Initiate MoCo Subsidence Study

For the third meeting in a row, the board also took no action to initiate Phase II of its subsidence study. The LSGCD Phase I report stated that Phase II would assess subsidence and flooding. However, having decided to ignore subsidence, the fate of Phase II remains unclear. (As of this writing, the board has not yet posted its agenda for the regularly scheduled April 13 meeting, nor has it posted the video of the April 7 meeting.) (Update: as of 4/12 at noon, video of the meeting was still not posted.)

Stage Set for Showdown

All of these decisions set the stage for a showdown at the Groundwater Management Area 14 (GMA-14) meeting this Friday at 9 a.m. Approval of LSGCD’s DFCs requires a two-thirds vote. Because GMA-14 has five voting groundwater conservation districts, approval will require at least three others.

GMA-14 will meet tomorrow at 9 a.m. to discuss its options. See meeting details below if you wish to participate.

More Troubling Contradictions Emerge from Meeting

Those who follow this debate have noted many troubling contradictions on the part of LSGCD and yesterday’s meeting was no exception.

The virtual meeting started 14 minutes late due to connectivity issues. The few hardy souls who persisted through the delays and poor audio quality, were treated to lengthy presentations that covered old ground and several contradictory comments from staff and board members.

For instance:

  • LSGCD claimed at the last GMA-14 meeting that it needed another month to hold stakeholder meetings before they could vote on DFCs. But last night’s reports on the stakeholder meetings did not mention subsidence, only the need to improve communications. This set the stage for the motions to ignore subsidence in DFCs and to hire a PR agency. It would be interesting to learn whether stakeholders expressed concerns about subsidence that weren’t reported.
  • QuadVest, which reportedly funded the campaigns of current board members, previously threatened to sue everyone in sight if they didn’t get their way. However, in yesterday’s meeting, they claimed they now had no plans to sue anyone. (Note: Previous to voting on yesterday’s motion, the board discussed litigation in executive session.) Winning through intimidation!
  • The board claimed it could not measure subsidence, although tools to do so are cheap and readily available. And the LSGCD staff was told so in the last GMA-14 meeting.
  • The board also insisted its problems were based on misinformation, but failed to acknowledge one example. Neither did they acknowledge their own role in spreading disinformation.
  • For instance, LSGCD claimed Harris County had no subsidence metric in place, ignoring the facts that the goal of the Harris-Galveston Subsidence District is to eliminate subsidence and that HGSD has extensive regulations in place to get people off of groundwater.
  • The key argument seemed to be that aquifer decline, not subsidence, was the only limiting factor on groundwater pumping. But modeling showed that at the pumping rate they adopted, subsidence would exceed three feet in places.
  • The board also argued that pumping in Harris County affected subsidence in MoCo. While true in certain cases, that ignores the fact that they approved an increase in MoCo pumping while pumping in Harris County is declining.
  • They talked a lot about property rights, but never specified whose. QuadVest believes they have a right to pump water from beneath your house.
Modeled subsidence in MoCo if pumping reaches 115,000 acre feet per year.

Who Benefits?

QuadVest gets to pump more water, the raw material of its business. QuadVest previously backed efforts to get the LSGCD board elected rather than appointed by local regulated entities. QuadVest then reportedly backed a slate of candidates promising to “Restore Affordable Water.” However, according to MoCo residents who get QuadVest water and have contacted me, water rates have not come down.

Who Loses?

Consequences of subsidence are widespread. Differential subsidence measured over wide areas can alter the gradient of ditches, pipelines, streams, rivers and lakes. For instance, models show that the subsidence associated with pumping 115,000 acre feet per year in Montgomery County would cause 1 foot of subsidence at the Lake Houston Dam but 3 feet in Kingwood and Huffman. That would put tens of thousands of upstream residents 2 feet closer to floodwaters.

Rescue efforts in Kingwood on Valley Manor during Harvey flood in 2017. Almost two miles from West Fork of San Jacinto.
Rescue efforts in Kingwood on Valley Manor during Harvey flood in 2017. 2.1 miles from West Fork of San Jacinto. 110 homes in this subdivision flooded. Imagine if water were 2 feet higher.

Subsidence can also crack roads, foundations, walls, ceilings, and roofs, especially near fault lines which are plentiful in southern MoCo and northern Harris Counties.

Subsidence triggered by groundwater pumping at a Woodlands home near a fault line.

Avoiding Checks and Balances

If subsidence isn’t really a danger as the LSGCD board contends, why not include a subsidence metric in its DFCs? Aquifers can rebound over time, but subsidence is forever. Over-pumping could cause irreversible damage as you see above.

GMA-14 Meeting Details

The GMA-14 meeting is April 9, 2021 at 9 a.m. To make a public comment, sign up here.

Posted by Bob Rehak on April 8, 2021

1318 Days since Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.

Doublespeak Continues to Cloud MoCo Subsidence Debate

Those who watched recent Lone Star Groundwater Conservation District (LSGCD) and Groundwater Management Area 14 (GMA-14) meetings were treated to some jaw-dropping, head-spinning doublespeak on the subject of subsidence. On January 20, 2021, at a GMA-14 meeting, LSGCD rejected any mention of subsidence in their Desired Future Conditions (DFCs). Then on 2/9/2021, three presenters told the Lone Star board that they were still considering subsidence. Then on 2/24/2021, the same three presenters told GMA-14 they still rejected subsidence.

Pardon My Whiplash!

As if that wasn’t enough, during the three-hour 2/24 GMA-14 meeting, they also:

  • Claimed that their groundwater withdrawal plan won’t create subsidence, but insisted on removing subsidence as a measure of their performance.
  • Believe they are entitled to their fair share of subsidence.
  • Insisted they should be measured on nine factors (which included subsidence), but then argued to take subsidence out of the mix.

Their main point? In essence, “We reject subsidence as a measure of our performance.”

Why? Samantha Reiter, LSGWCD General Manager, listed four reasons in a six-page, 3716-word letter which she read to GMA-14. I have summarized her arguments below for readability and to make concise responses possible.

Argument #1: Modeling

Modeling shows that projected water draw-downs won’t create subsidence in excess of one foot on average across Montgomery County, so why worry?

Response: Subsidence models have not yet been validated for the aquifer from which Montgomery County would predominantly pump – the Jasper. Moreover, while aquifers can rebound from overpumping, subsidence cannot. Without a subsidence metric as a check, private water utilities, such as Quadvest, could merrily pump as much water as they wanted for 40 years and claim they would make it up in the last ten. But the subsidence damage at that point would be permanent.

Much of the groundwater in Montgomery County used for human consumption is pumped from the Jasper aquifer which also affects Harris and Galveston Counties. However, models predicting subsidence from the Jasper have not been validated as they have for the Chicot and Evangeline Aquifers. Source Harris-Galveston Subsidence District.

Argument #2: Can’t Control Harris County

LSGCD can’t control Harris County pumping which affects subsidence in MoCo.

Response: True, but MoCo has already shown that surface water can dramatically reduce subsidence, even where subsidence is worst – in the heavily populated, southern part of the county. Moreover, SJRA’s surface water treatment plant has space to quadruple its capacity. While MoCo is arguing to increase its reliance on groundwater, Harris County is desperately trying to reduce its.

When The Woodlands began using more surface water in 2016 after completion of a surface water pipeline, the rate of subsidence dropped 75%.

See more below under “More on Argument #2.”

Argument #3: Unfairness

It’s unfair to limit subsidence in MoCo to an amount less than Harris County experienced.

Response: Is LSGCD really arguing to make the same mistakes Harris County did? Is it really worth damaging peoples’ foundations, walls, doors, cabinets, ceilings, roofs and driveways to make a philosophical point about fairness?

These front steps in The Woodlands dropped almost 10 inches due to subsidence before conversion to more surface water. Photo courtesy of Mark Meinwrath.

Argument #4: Measurable Goals

Goals must be measurable and LSGCD does not have enough monitoring sites or equipment to measure subsidence throughout Montgomery County.

Mike Turco, head of the Harris-Galveston Subsidence District answered this in the GMA-14 meeting. You can monitor subsidence with GPS, LIDAR and other readily available technologies for much less than the cost of a network of extensometers.

To see Ms. Reiter’s full text, click here. Her subsidence discussion starts on page 4.

More On Argument #2

Of the four arguments posed above, #2 seems strongest. Excessive pumping in either Harris or Montgomery County can produce subsidence across the county line. So how do you determine who’s causing how much in each location?

This is a question for scientists to answer. However, it seems to me that if one county is reducing its reliance on groundwater and the other is increasing its, any increase in the rate of subsidence should be easy to trace.

And this is precisely the scenario we face. Harris is reducing its dependence on groundwater; Montgomery is arguing to increase its.

In Harris County, the City of Houston is investing heavily to move people off groundwater. The $351 million Luce Bayou Interbasin Transfer Project will bring more water to Lake Houston. And the new $1.4 billion Northeast Water Purification Plant will supply that water to Houston as well as surrounding municipalities, counties and utility districts. Montgomery County already has a lake that’s 3-4X larger and a water treatment plant that can supply its growing population with enough water to reduce subsidence to a negligible rate. With the Montgomery County investment already made, why risk subsidence?

Expansion of Houston’s Northeast Water Purification Plant will quadruple its capacity. It will soon provide 320 million gallons of treated water capacity per day, more than three times the entire water demand in Montgomery County. Looking NE toward Lake Houston in background.

We Need Fewer Filibusters, Less Doublespeak, More Debate

I wish the LSGCD would engage in debates, not filibusters. By its own admission, LSGCD has tried to come up with a statement of Desired Future Conditions since 2016. That’s five years! How long does it take to study a problem and write a sentence!

In my opinion, verbose, rambling, repetitive 3-hour meetings filled with doublespeak have been designed to cloud tradeoffs, not find the best balance. It shouldn’t take smart people three hours to articulate a problem. And until we can get at what the real problem is, we will never find a real solution.

Posted by Bob Rehak on 3/5/2021

1284 Days since Hurricane Harvey

The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.

Groundwater Management Area 14 to Hold Joint Planning Committee Meeting on January 20

Mark your calendar and sign up now. Groundwater Management Area 14 (GMA 14) will meet by webinar Wednesday, January 20th at 10 AM to continue the process of developing a set of desired future conditions for area aquifers. The standards will eventually determine groundwater availability and affect other issues such as subsidence.

GMA 14 includes the 15 colored counties above. Each color represents a different Conservation District. Montgomery County (dark blue) has the Lonestar Groundwater Conservation District.

GMA 14 engages in a joint planning process and includes representatives from Bluebonnet, Brazoria County, Lone Star, Lower Trinity, and Southeast Texas groundwater conservation districts, plus two subsidence districts. GMA 14 spans 20 counties. It is one of 16 groundwater management areas in the state of Texas. 

High Stakes

Groundwater availability is a growing concern in the management area due to subsidence, water table reduction, wells running dry, the triggering of geologic faults, impacts to infrastructure, foundation issues, and providing a sustainable basis for future growth.

The last available subsidence maps, for instance, showed the north Harris and south Montgomery County area sinking 2 feet relative to the Lake Houston Dam.

Pumping 115,000 acre feet per year would cause up to 3.25 feet of subsidence in southern MoCo. That’s far more than the 1-foot in the Desired Future Conditions definedby GMA14.
The same amount of pumping would cause up 3 feet of subsidence in parts of Kingwood and Huffmanand a foot or more in much of the rest of Harris County.

Because aquifers travel under several counties, what happens in northern Montgomery County can impact southern Harris and Galveston counties, especially where people live closer to sea level.

How Much is Safe to Pump?

In determining groundwater availability targets, this month’s meeting will focus on:

  • Socioeconomic Impacts Reasonably Expected to Occur
  • Feasibility of Achieving the Desired Future Conditions
  • Other Relevant Information (including fault movement). 

In all, GMA 14 considers nine factors in the join planning process: 

  • Aquifer Uses and Conditions
  • Water Supply Needs and Management Strategies
  • Hydrological Conditions
  • Environmental Impacts
  • Impact on Subsidence
  • Socioeconomic Impacts
  • Private Property Rights
  • Feasibility of Achieving the desired future conditions
  • Other Relevant Information





January 20, 2021 at 10:00 AM

Via GoToWebinar.com


The Groundwater Management Area 14 Meeting will begin at 10:00 A.M.
Click the following link to register for Groundwater Management Area 14 – January 20, 2021 Meeting: https://attendee.gotowebinar.com/register/5586548623672514573
Once the registration is completed, an email will be sent with information on logging into the meeting and/or phone numbers and access codes to dial into the meeting should you wish to attend by telephone. Please choose one method or the other to join to avoid audio feedback.

Note: Participation via video conference is not required. If you wish to address the Board, during the public comment period, please fill out and submit the online speaker registration form.

You may also register as a speaker at the beginning of the meeting. Registration as a speaker will require providing:

  1. first and last name;
  2. email address
  3. phone number.

Any person participating in the meeting must be recognized and identified by the Chairman each time they speak.

Go To Webinar Information


GMA 14 Speaker Registration Form



The agenda includes:

  1. Call to order;
  2. Confirmation of receipt of posted notices;
  3. Welcome and Introductions;
  4. Public comment;
  5. Discussion and possible action to approve minutes of November 18, 2020 GMA 14 Joint Planning Meeting;
  6. Update from Texas Water Development Board and discussion of any related items of interest to GMA 14;
Meeting will be convened as a meeting of the GMA 14 Joint Planning Interlocal Agreement Participants.
  1. Presentation and discussion by Districts or Interlocal Agreement Participants of recent activities of interest to or impacting the GMA 14 planning group;
  2. Discuss and consider current Desired Future Conditions as they relate to recent static water level measurements within GMA 14 Member Districts;
  3. Presentation, discussion and consideration of “socioeconomic impacts reasonably expected to occur” (as required by Texas Water Code 36.108 (d)(6));
  4. Presentation, discussion and consideration of “the feasibility of achieving the desired future conditions” (as required by Texas Water Code 36.108 (d)(8));
  5. Presentation, discussion and consideration of “any other information relevant to the specific Desired Future Condition” including but not limited to fault movement related to groundwater pumping (as required by Texas Water Code 36.108 (d)(9));
  6. Discussion and possible action regarding the DFCs and the path forward for GMA 14 to accomplish statutory mandates for Round 3 Joint Planning;
  7. GMA 14 Interlocal Agreement financial report;
GMA 14 Interlocal Agreement Participants meeting will be adjourned, and the meeting of the GMA 14 District Representatives will reconvene.
  1. Discussion and possible action regarding next meeting date, location, and agenda items;
  2. Meeting Adjourned.

GMA 14 – January 20, 2021 Agenda

Posted by Bob Rehak on 1/14/2020

1234 Days since Hurricane Harvey