Supp Region I Comment submitted 091205

NATIONAL WILDLIFE FEDERATION GULF STATES NATURAL RESOURCE CENTER (512) 476-9805 44 East Avenue, Suite 200 FAX (512) 476-9810 Austin, Texas 78701 www.nwf.org September 12, 2005 Gary Hanlon DETCOG 210 Premier Drive Jasper, TX 75951 Re: Supplemental Comments on Initially Prepared 2006 Regional Water Plan for the East Texas Region Dear Mr. Hanlon and Planning Group Members: This letter briefly supplements, on behalf of the National Wildlife Federation, the written comments previously filed by NWF, Environmental Defense, the Lone Star Chapter of the Sierra Club on the Initially Prepared Regional Water Plan for the East Texas Region (Region I). This letter addresses only one narrow issue: conservation as a water management strategy as it applies to oil refineries. Because Jefferson and Orange Counties are important locations for refining in our state, there is significant potential for water conservation. The Region I Plan should consider any feasible water conservation opportunities refineries can implement. With respect to manufacturing water needs, water conservation -- in the form of water efficiency measures -- is a required water management strategy for those entities using surface water pursuant to a water right in excess of 1000 acre-feet. See 31 TAC § 357.7(a)(7)(A)(i). In addition, the plan must include consideration of additional conservation strategies. (7)(A)(ii). Information included in the Initially Prepared Plan ...