FY19-20 Implementation Report

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Urban Management Measures and Outreach in New Braunfels – FY19-20 Implementation Report

MARCH 2021

Prepared for the Dry Comal Creek (1811A) and Comal River (1811) Watershed Partnership by:

Greg Malatek, Mark Enders, and Phillip Quast - City of New Braunfels

Nathan Pence, Lee Gudgell, and Cinde Thomas-Jimenez - Guadalupe-Blanco River Authority

Jim Boenig - Edwards Aquifer Authority

Ashley Evans, PE and Carrie Smith - Arcadis U.S., Inc.

Funding for the development of this Watershed Protection Plan project was provided through a federal Clean Water Act §319 (h) grant to the City of New Braunfels, administered by the Texas Commission on Environmental Quality from the U.S. Environmental Protection Agency.

Dry Comal Creek and Comal River Watershed Protection Plan – FY19-20 Implementation Report

Contents

1. PROJECT SIGNIFICANCE AND BACKGROUND ...... 1

2. STUDY AREA ...... 4 Watershed Boundaries ...... 4 Geography ...... 5 Dry Comal Creek ...... 5 Comal River ...... 6

3. SUMMARY OF BMPS IMPLEMENTED ...... 8 Task 3: BMPs Addressing Overabundant Urban and Non-Native Wildlife ...... 8 Subtask 3.1: Do-Not-Feed Urban Wildlife Campaign in City Limits ...... 8 Subtask 3.2: Voluntary Do-Not-Feed Wildlife Campaign in Rural Neighbourhoods ... 11 Subtask 3.3: Wildlife Management Workshops ...... 13 Subtask 3.4: Oil Coat Non-Native Duck Eggs ...... 14 Status of Task 3 Deliverables ...... 17 Task 4: BMPs Addressing Stormwater Infrastructure ...... 18 Subtask 4.1: OSSF Education and Assistance Program ...... 18 Subtask 4.2: Non-structural Stormwater BMPs Outside the City’s MS4 Jurisdiction . 18 Subtask 4.3: Stormwater Outreach and Education ...... 19 Subtask 4.4: Pet Owner Outreach and Education ...... 21 Subtask 4.5: Pet Waste Stations ...... 25 Subtask 4.6: Analysis of E. coli Structural Stormwater BMPs Beyond the City’s MS427 Subtask 4.7: Reduce Animal Waste in Landa Park Runoff Water ...... 27 Status of Task 4 Deliverables ...... 27 Task 5: Outreach and Education ...... 29 Subtask 5.1: News Campaigns ...... 29 Subtask 5.2: Youth Activities ...... 37 Subtask 5.3: Outreach at Local Events ...... 43 Subtask 5.4: Hire Watershed Education Personnel ...... 45 Subtask 5.5: Develop New Nonpoint Source Pollution Education Activities and Materials ...... 45 Subtask 5.6: Watershed Visualization Tool ...... 46 Subtask 5.7: Hands-On Learning Module ...... 46 Subtask 5.8: Online Educational Games ...... 46 Status of Task 5 Deliverables ...... 46 Task 6: Data Acquisition and Analysis ...... 47 Subtask 6.1: Acquire and Evaluate E. coli Data ...... 47 Subtask 6.2: Wastewater Discharge Water Quality Assessment ...... 51 Status of Task 6 Deliverables ...... 54 Task 7: Storm Event Monitoring...... 56

4. DISCUSSION ...... 56

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Deliverables Not Completed ...... 56 Lessons Learned ...... 56 Recommendations...... 56

5. WATER QUALITY RESULTS ACHIEVED ...... 57

List of Tables Table 1: Goals for 2018 to 2022 Grant Period ...... 2 Table 2: BMPs Addressing Overabundant Urban and Non-Native Wildlife – Summary of Task 3 Deliverables ...... 17 Table 3: BMPs Addressing Stormwater Infrastructure – Summary of Deliverables ...... 27 Table 4: Summary of News Campaign ...... 29 Table 5: Summary of Youth Outreach Events ...... 42 Table 7: Summary of Community Outreach ...... 43 Table 7: Outreach and Education – Summary of Deliverables ...... 46 Table 8: Summary of Discharge Permits in Comal River and Dry Comal Creek Watershed ...... 51 Table 9: Cemex Discharge E. Coli Data Analysis ...... 54 Table 10: Data Acquisition and Analysis – Summary of Deliverables ...... 55

List of Figures Figure 1: Dry Comal Creek and Comal River Watershed (Comprising Three HUC 12 Watersheds) ...... 5 Figure 2: Dry Comal Creek at Seguin St. (Looking Upstream) ...... 6 Figure 3: Comal Springs at Landa Park (Spring Run #1) ...... 7 Figure 4: Comal River at Hinman Island ...... 7 Figure 5: 24”x36” Kiosk-Style Signage ...... 9 Figure 6: 12”x18” Sign – Example ...... 9 Figure 7: Example 6”x6” Placard ...... 10 Figure 8: Example Do-Not-Feed Wildlife Door Hanger Template ...... 10 Figure 9: Map of Do-Not-Feed-Wildlife Signage Installations ...... 11 Figure 10: Voluntary Do-Not-Feed Wildlife Postcard – Side 1 ...... 12 Figure 11: Voluntary Do-Not-Feed Wildlife Postcard – Side 2 ...... 12 Figure 12: Map of Addresses Outside City Limits Reached by Mailer ...... 13 Figure 13: February 13 Wildlife Management Workshop Flyer ...... 14 Figure 14: Non-Native Avian Nest Locations in Landa Park – FY19 ...... 15 Figure 15: Non-Native Avian Nest Locations in Landa Park – FY20 ...... 16 Figure 16: Draft Watershed Signage ...... 19 Figure 17: Educational Stormwater Runoff Postcard – Side 1 ...... 20 Figure 18: Educational Stormwater Runoff Postcard – Side 2 ...... 20

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Figure 19: Educational Pet Waste Disposal Postcard – Side 1 ...... 21 Figure 20: Educational Pet Waste Disposal Postcard – Side 2 ...... 22 Figure 21: Puppy Playland Infographic ...... 23 Figure 22: Installed Puppy Playland Infographic ...... 24 Figure 23: Waste Station Installation Map ...... 26 Figure 24: Pet Waste Bag Dispensers ...... 26 Figure 25: Herald Zeitung Week 1 Publication ...... 31 Figure 26: Herald Zeitung Week 2 Publication ...... 32 Figure 27: Herald Zeitung Week 3 Publication ...... 33 Figure 28: Herald Zeitung Week 4 Publication ...... 34 Figure 29: Herald Zeitung Week 5 Publication ...... 35 Figure 30: Herald Zeitung Week 6 Publication ...... 36 Figure 31: Community Impact Half-Page Insert ...... 37 Figure 32: Elementary School Level Outreach Presentation Example Slide ...... 38 Figure 33: Middle School Level Outreach Presentation Example Slide ...... 38 Figure 34: High School Level Outreach Presentation Example Slide ...... 39 Figure 35: Lab Guidebook Cover Pages ...... 39 Figure 36: WPP Best Practices Activity Worksheet ...... 40 Figure 37: Explanatory BST Infographic ...... 41 Figure 38: All School Levels within Dry Comal Creek and Comal River Watershed ...... 42 Figure 39: Portable Display used at Local Outreach Events ...... 44 Figure 40: City and GBRA staff conducting outreach at ScienceFest ...... 45 Figure 41: 12- and 24-Month E. Coli GeoMeans along the Comal River (CR) from January 2012 through June 2020 ...... 48 Figure 42: 12- and 24-Month E. Coli GeoMeans along the Dry Comal Creek (DCC) from January 2012 through June 2020 ...... 49 Figure 43: E. Coli GeoMeans at the Dry Comal Creek at Walnut Avenue vs. Number of Samples Taken Following Rain Events ...... 50

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Acronyms

BMPs Best Management Practices BST Bacteria source tracking cfs Cubic feet per second CFU/100 mL Colony forming units per 100 milliliters City City of New Braunfels CRP Clean Rivers Program CWA Clean Water Act E. coli Escherichia coli ECHO Enforcement and Compliance History Online FY Fiscal Year GBRA Guadalupe-Blanco River Authority Geomeans Geometric means HOAs Homeowner’s Associations HUC Hydrologic Unit Code IH-35 Interstate Highway 35 MGD Million gallons per day mL Milliliters MMOR Making the Most of our Resources MS4 Municipal Separate Storm Sewer System NBU New Braunfels Utilities NPS Nonpoint source OSSFs On-Site Sewage Facilities SOW Scope of Work TCEQ Texas Commission on Environmental Quality TEKS Texas Essential Knowledge and Skills TPDES Texas Pollutant Discharge Elimination System USEPA United States Environmental Protection Agency USGS United States Geological Survey WBD Watershed Boundary Dataset WPP Watershed Protection Plan WTF Wastewater Treatment Facility

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Dry Comal Creek and Comal River Watershed Protection Plan – FY19-20 Implementation Report

1. Project Significance and Background The Dry Comal Creek, Segment 1811A, is a tributary of the Comal River, Segment 1811. The Dry Comal Creek was listed on the 2010 Texas Commission on Environmental Quality (TCEQ) 303(d) list for impairment to its designated contact recreational use, due to elevated Escherichia coli (E. coli) concentrations. As a result of the Dry Comal Creek listing, the City of New Braunfels (City) and Guadalupe-Blanco River Authority (GBRA) began monthly E. coli monitoring at 12 locations along the Dry Comal Creek and Comal River (including the three TCEQ Clean Rivers Program sampling locations) in 2011. These E. coli data indicated that concentrations in both waterbodies were trending upward over time. In 2014, the City applied for, and was awarded, Clean Water Act (CWA) Section 319 grant funds to develop a Watershed Protection Plan (WPP) for Dry Comal Creek and the Comal River. In 2016, both the Dry Comal Creek and Comal River were listed on the TCEQ 303(d) list for bacteria impairment. As part of the WPP development and watershed characterization, E. coli loads were calculated for the three TCEQ Clean Rivers Program (CRP) monitoring locations in the watershed (two on the Comal River and one on the Dry Comal Creek) using nearby United States Geological Survey (USGS) gaged flow data. The evaluation of the historical data collected from the three monitoring sites indicated that, at medium flows, bacteria loads need to be reduced by 34 percent in the Dry Comal Creek (at CRP Site 12570) and 50 percent in the Comal River (at CRP Site 12653) to meet targeted stream standards. In 2013, and again in 2016, the Watershed Partnership (a collaboration between the City, GBRA, the Edwards Aquifer Authority, the Stakeholder Group, and the Technical Advisory Group) collected samples from Dry Comal Creek and the Comal River, and had them analyzed by bacterial source tracking (BST) to provide information on the sources of the bacteria in the water. The results of those BST samples indicated that up to 70 percent of the E. coli bacteria in the water were from wildlife (i.e., nonpoint sources dispersed throughout the watershed). To reduce E. coli concentrations, the WPP outlined best management practices (BMPs) to improve the health of the Dry Comal Creek and Comal River watershed (“the Watershed”), which will be implemented over ten years. Implementation of the WPP for the Dry Comal Creek and Comal River began prior to September 2018, when the City of New Braunfels was awarded $443,853 by the CWA Section 319(h) Nonpoint Source (NPS) Grant Program for the Fiscal Year (FY) of 2018 through Grant No. 582-19-90207. FY2018 319 program grant funding supported the WPP implementation activities described in years two through four of the WPP. In this period, the BMPs described in the WPP target wildlife waste, pet waste, stormwater, and wastewater pollution sources. BMPs were supplemented by a proactive outreach and education program, including a Do-Not-Feed Wildlife Campaign, and continued water quality monitoring by the Watershed Partnership. Two years into the implementation period, the Watershed Partnership evaluated the effectiveness and progress of BMP implementation thus far, as part of an effort to practice “adaptive implementation” (described in the WPP). Based on this evaluation, the Watershed Partnership requested to update the goals and scope of work (SOW) included in the grant funding

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application. A revised grant application was submitted to EPA in August 2020, and the changes to the Watershed Partnership’s implementation measures and goals are reflected herein. In addition to adapting its goals and implementation measures, the Watershed Partnership also extended the grant period by one year to FY22. Goals set for the 2018-2022 grant period are listed in Table 1. Changes submitted to EPA for approval are shown in green.

Table 1: Goals for 2018 to 2022 Grant Period

Goal Project Deliverables Reduce the urban deer and non-native • Design and install at least 30 signs for the Do-Not-Feed avian populations within the city limits Campaign • Distribute educational materials in City limits at least annually • Host 3 in-person or virtual wildlife management workshops and promote 3 wildlife management webinars • Distribute educational materials to rural neighborhoods (at least every two years targeting 400 total households) • Contract with a professional for annual non-native duck egg oil-coating services Reduce the number of failing On-site • Host OSSFs training programs (at least two in person or Sewage Facilities (OSSFs) in the virtual training events) watershed Reduce the amount of E. coli in • Distribute stormwater educational materials (at least 2 stormwater hard copy or electronic distribution events per year) • Install 30 5 signs on storm grates, drains, Watershed boundaries within City limits and/or at creek crossings within the Watershed • Install 2 surveillance cameras and monitor captured footage • Reduce flow of animal waste to Landa Lake by contracting with a professional clean-up service. • Evaluate and develop a plan for structural stormwater BMPs targeting E. coli reduction • Develop and initiate a Storm Event Outfall Sampling Plan Reduce the number of pet owners not • Purchase and install at least 80 40 pet waste stations in picking up pet waste the watershed • Develop and distribute materials promoting the proper disposal of pet waste (at least 2 community locations per year) Monitor E. coli concentrations in • Track and analyze wastewater discharge data submitted wastewater discharges in the to the TCEQ by existing permit holders and track any watershed new wastewater permits, within the watershed (annually) Implement a proactive Outreach and • Produce a short video Education Campaign in the watershed • Release at least 6 news releases and 10 advertisements providing information to residents and in newsletters visitors on E. coli and associated • Host at least 8 in-person or virtual youth activities per BMPs year

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Goal Project Deliverables • Provide education at least 4 in-person or virtual local community events per year • Develop educational materials for the Headwaters Facility • Subcontract with New Braunfels Utilities (NBU) to hire a Part-Time Watershed Educator and develop educational materials • Produce a watershed visualization tool • Develop a virtual hands-on learning module to be distributed to households and classrooms • Develop online educational games *For the Comal River, the baseline (2011-2017) E. coli geomean concentration (CFU/100mL) was 164, and the estimated E. coli load was 6.96x1011 CFU/day. The target E. coli geomean concentration (CFU/100mL) is 113, and the target E. coli load is 3.45x1011 CFU/day. If a linear relationship is assumed between CFU/100mL and the load reduction, then reducing the E. coli load by 1.78x1010 CFU/day will result in a 2 percent load reduction or a goal of 161 CFU/mL.

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Dry Comal Creek and Comal River Watershed Protection Plan – FY19-20 Implementation Report

2. Study Area The Dry Comal Creek watershed encompasses more than 100 square miles. As its name implies, much of the Dry Comal Creek remains dry other than during, and immediately following, large rain events. This is partially because the upper portions of the creek lie within the Edwards Aquifer Recharge Zone where water within the creek channel infiltrates the rock formation comprising the Edwards Aquifer. In the downstream reaches of the Dry Comal Creek, small springs and seeps provide flow to the creek during average weather conditions. The Dry Comal Creek, Segment 1811A, is a tributary of the Comal River, Segment 1811, and has its confluence with the Comal River in the heart of the City. The Comal River is the shortest navigable river in Texas and is located entirely within the City. The Comal River flows approximately two and one- half miles from its source at Comal Springs prior to joining the Guadalupe River. The Comal River provides a significant portion of the baseflow to the Guadalupe River, especially during times of drought. Compared to Dry Comal Creek, the Comal River has a much smaller watershed, but typically exhibits constant flow with an average discharge of approximately 300 cubic feet per second (cfs).

Watershed Boundaries Watershed boundaries were determined solely upon science-based hydrologic principles, not favoring any administrative or political boundaries. The Watershed Boundary Dataset (WBD) defines the areal extent of surface water drainage to a point, accounting for all land and surface areas. Watershed boundaries, or “hydrologic units” define a drainage boundary framework and are assigned a “Hydrologic Unit Code (HUC).” The hydrologic unit hierarchy is indicated by the number of digits in the HUC, with HUC 12 being a 12-digit code for local watersheds that capture tributary systems. Three HUC 12-level watersheds make up the Watershed as shown in Figure 1. Note that the officially-designated name for the southeastern HUC 12 watershed (HUC 12 code: 121002020106) is the “Dry Comal River – Guadalupe River”, which includes the Comal River. The segments of the Dry Comal Creek in the northwestern two HUC 12 watersheds (i.e., the “Headwaters West Fork Dry Comal Creek” – [HUC 12 code: 121002020104] and the “West Fork Dry Comal Creek” [HUC 12 code: 121002020105]) are generally intermittent or dry, with flow increasing during storm events.

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Figure 1: Dry Comal Creek and Comal River Watershed (Comprising Three HUC 12 Watersheds)

Figure 1 also highlights the areas within the Watershed draining to the Dry Comal Creek and Comal River. The 71,120-acre Dry Comal Creek drainage basin is much larger than the 11,487-acre Comal River drainage basin. There are an additional 553 acres which drain to the Comal River downstream of the confluence with the Dry Comal Creek. Thus, these three areas cover a total of 83,160 acres.

Geography This WPP covers the watersheds for both the Dry Comal Creek and Comal River. The Watershed spans from southeast of Canyon Lake near Hwy 46, to the City of Garden Ridge and the City. The geography of the Dry Comal Creek and Comal River are further described below.

Dry Comal Creek The main channel of the Dry Comal Creek is located entirely within Comal County; however, a portion of its watershed, or drainage area, extends into Guadalupe County. Dry Comal Creek is an approximately 34-mile long tributary of the Comal River, which lies within the larger

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Guadalupe River Basin. The Dry Comal Creek begins approximately five miles southeast of Canyon Lake in northern Comal County, just north of Hwy 46, and continues toward the south. Just east of the City of Garden Ridge, the Dry Comal Creek turns abruptly to the northeast and continues parallel to Interstate Highway 35 (IH-35) in a northeast direction toward the City. The Dry Comal Creek joins the Comal River near Seguin St. within the City. A photo of the Dry Comal Creek at Seguin St. is provided in Figure 2.

The Dry Comal Creek watershed encompasses more than 100 square miles. As its name implies, much of the Dry Comal Creek remains dry other than during, and immediately following, large rain events. This is due in part because the upper portions of the creek lie within the Edwards Aquifer Recharge Zone. The Recharge Zone has highly faulted and fractured Edwards limestone outcrops at the land surface, allowing significant volumes of water to flow into the Aquifer during rain events. In fact, about 75 percent to 80 percent of Edwards Aquifer recharge occurs where streams and rivers cross the permeable formation and water goes underground. In the downstream reaches of the Dry Comal Creek, small springs and seeps provide flow to the creek during average weather conditions.

Figure 2: Dry Comal Creek at Seguin St. (Looking Upstream)

Comal River

The Comal River (Segment 1811) originates as groundwater from the Edwards Aquifer, and percolates through numerous spring openings located along the Balcones Escarpment in and near Landa Park (see one of these springs in Figure 3), which is located within the City limits. The Comal River is the shortest navigable river in Texas and is located entirely within the City. The Comal River flows approximately two and one-half miles from its source at Comal Springs prior to joining the Guadalupe River.

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Figure 3: Comal Springs at Landa Park (Spring Run #1)

Figure 4 shows a small portion of the Comal River at Hinman Island. The Comal River provides a significant portion of the baseflow to the Guadalupe River, especially during times of drought. The Comal River typically exhibits constant flow with an average discharge of approximately 300 cfs. In recorded history, the only time the Comal Springs have ever gone dry was for a period of about six months during the 1950’s drought-of-record.

Figure 4: Comal River at Hinman Island

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3. Summary of BMPs Implemented (All Task reports and Final Approved Quarterly Progress Report)

Before the Watershed Partnership received TCEQ funding and began the current grant activities, the following activities were completed: • Hosted public wildlife management workshops – Two public outreach workshops related to urban wildlife management were held in New Braunfels City Hall prior to the introduction of the Do-Not-Feed Wildlife ordinance. These workshops, held in February and April 2018, described the issues posed by overly abundant urban wildlife and potential solutions, including the passage of a Do-Not-Feed Wildlife ordinance. • Sought public opinion on potential strategies – A survey was distributed to City residents through social media and in-person at the wildlife management workshops. A majority of the over 200 respondents were in favor of a feeding ordinance and wildlife management initiatives. • Passed a Do-Not-Feed Wildlife ordinance – In September 2018, City Council voted in favor of the passage of Ordinance No. 2018-58, which restricts the feeding of wildlife within City limits. Beginning about halfway through FY20 of the implementation period (March 2020), social distancing guidelines were instituted to reduce the spread of the COVID-19 pandemic. The social distancing rules put in place limit large community events and gatherings, school classes, and other potential outreach events. As a result, the implementation of various BMPs planned for FY21 has been delayed by the Watershed Partnership. In response, the Watershed Partnership, as part of the August 2020 SOW revision request, proposed moving activities to a virtual platform. Additionally, the Watershed Partnership proposed reallocating funding to support another round of egg oil-coating events in FY 21.

Task 3: BMPs Addressing Overabundant Urban and Non-Native Wildlife The objective of Task 3 is to reduce the E. coli loading from overabundant urban deer and non- native avian populations by reducing the population density of deer in urban areas through management programs and by reducing the population of non-native ducks and geese in Landa Park to the extent practical. The following subsections fulfil the Task 3 Task Report (Subtask 3.1) deliverable once updated at the end of the grant period.

Subtask 3.1: Do-Not-Feed Urban Wildlife Campaign in City Limits In FY19, in order to inform residents and tourists about the feeding ordinance passed by New Braunfels City Council, the Watershed Partnership installed multiple signs in Landa Park. In addition, the Watershed Partnership provided signage to tubing outfitters. Signs were developed in three different sizes: one 24”x36” kiosk-style sign, four versions of a 12”x18” sign

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(two in English and two translated to Spanish), and many designs of 6”x6” placards. Examples of signage designs are shown in Figures 5 through 7. In total, 242 signs of varying sizes were installed (200 6”x6” placards, forty 12”x18” signs, and two 3’x5’ kiosk-style signs). In additional to signage, the Watershed Partnership created promotional material, such as door hangers (Figure 8) and stickers. A map of Do-Not-Feed-Wildlife installation sites is shown in Figure 9. Over 1,000 door hangers have been created and provided to New Braunfels Parks Department rangers and Animal Control Services. In FY20, in-person community events were suspended to reduce the spread of COVID-19. The Watershed Partnership is working to move events and material distribution opportunities to a virtual platform. Although there have not been in-person events, 520 door hangers (pictured in Figure 8) have been handed out to residents.

Figure 5: 24”x36” Kiosk-Style Signage Figure 6: 12”x18” Sign – Example

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Figure 7: Example 6”x6” Placard

Figure 8: Example Do-Not-Feed Wildlife Door Hanger Template

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Figure 9: Map of Do-Not-Feed-Wildlife Signage Installations

Subtask 3.2: Voluntary Do-Not-Feed Wildlife Campaign in Rural Neighbourhoods Because the Do-Not-Feed Wildlife Ordinance is only enforceable within New Braunfels City limits, the Watershed Partnership developed a separate outreach campaign to reach areas within the watershed outside of the City limits. In FY19, outreach materials were developed (Figure 10 and Figure 11) communicating the impact of overabundant urban deer without referring specifically to the ordinance. The mailout was sent to 5,266 active addresses, and a map of the addresses reached in the mailout is shown in Figure 11. There were no deliverables planned for Subtask 3.2 during FY20 of implementation.

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Figure 10: Voluntary Do-Not-Feed Wildlife Postcard – Side 1

Figure 11: Voluntary Do-Not-Feed Wildlife Postcard – Side 2

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Figure 12: Map of Addresses Outside City Limits Reached by Mailer

Subtask 3.3: Wildlife Management Workshops In FY19, the City hosted a wildlife management workshop on February 13th, 2019 at New Braunfels City Hall. The workshop reached 33 attendees. A media release was shared on February 4th, 2019 to promote the event. Promotional flyers were also released for the event (Figure 13). In FY20, in-person workshops were suspended to reduce the spread of COVID-19. However, the Watershed Partnership is working to move workshops to a virtual platform and moving forward with plans to advertise at least three online webinars hosted by a third party.

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Figure 13: February 13 Wildlife Management Workshop Flyer

Subtask 3.4: Oil Coat Non-Native Duck Eggs The City contracted with Arcadis on November 12, 2018 to perform egg oil coating events annually in Landa Park to reduce the population of non-native ducks and geese. Oil coating non-native duck and goose eggs prevents the non-native ducks and geese from hatching, thereby reducing the number of non-native avian wildlife in Landa Park. In FY19, oil coating events were planned for early spring, when non-native duck and goose populations were likely to begin nesting. Only nests confirmed to belong to non-native avian wildlife were sprayed during egg oil-coating events. One hundred percent food grade corn oil

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Dry Comal Creek and Comal River Watershed Protection Plan – FY19-20 Implementation Report was sprayed onto the eggs using a mister. In Spring 2019, Arcadis performed three egg oil coating events in Landa Park over the course of two months. The locations of potential and confirmed non-native avian nests are shown in Figure 15 and the number of eggs coated per event are summarized below.

• March 5, 2019: 11 eggs coated total • March 20, 2019: 29 eggs coated total • April 18, 2019: 34 eggs coated total

Figure 14: Non-Native Avian Nest Locations in Landa Park – FY19

In FY20, oil coating events were planned to occur from late winter to late spring, when non- native duck and goose populations had been observed nesting the previous year. Only nests confirmed to belong to non-native avian wildlife were sprayed during egg oil-coating events. One hundred percent food grade corn oil was sprayed onto the eggs using a mister. In Spring 2020, Arcadis performed six egg oil coating events in Landa Park over the course of five months (i.e., the number of events were doubled to capture the full hatching season). The locations of potential and confirmed non-native avian nests are shown in Figure 15 and the number of eggs coated per event is summarized below.

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• January 1, 2020: 0 eggs coated • February 7, 2020: 2 eggs coated • March 2, 2020: 7 eggs coated • March 25,2020: 7 eggs coated • April 15, 2020: 3 eggs coated • May 16, 2020: 5 eggs coated The August 2020 SOW revision request included additional funding to continue egg coating in the Spring of 2021.

Figure 15: Non-Native Avian Nest Locations in Landa Park – FY20

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Status of Task 3 Deliverables Table 2 includes a comprehensive list of the detailed documentation submitted to TCEQ for each task and the status of each deliverable.

Table 2: BMPs Addressing Overabundant Urban and Non-Native Wildlife – Summary of Task 3 Deliverables

Documentation Provided to Deliverable Status TCEQ Draft and Final design for COMPLETE. Signs approved by Draft signage for: permanent signage for Do-Not- TCEQ as 1/10/19. • 24”x36” kiosk-style size Feed Wildlife Urban Campaign • 12”x18” poster style (4 versions, English and Spanish) • 6”x6” placards for trash cans and picnic tables Documentation of the COMPLETE. • Map of sign installations installation of at least thirty (30) • Photo documentation of signs, including a map of installed signs installation sites Documentation of educational COMPLETE for FY19 and FY20. • Number of door hangers materials distributed within City IN PROGRESS for FY21. distributed limits, at least annually • Number of outreach events reached (Section 5.3) Document educational COMPLETE. Submitted to • Postcard-sized handouts for materials distributed in rural TCEQ and approved for FY19. outside City limits neighborhoods, at least every FY21 IN PROGRESS • Map displaying addresses two years reached by the postcard Documentation of in-person IN PROGRESS. One workshop • Workshop materials have workshops including notices, has been held. The following two been provided to TCEQ. agendas, meeting materials will be held in subsequent years. and attendance lists, minimum of three (3) Documentation of NOT STARTED No items to-date. advertisements for online workshops, minimum of 3

Subcontract with a professional COMPLETE • Contract with Arcadis. for egg oil-coating services

Documentation of egg oiling COMPLETE for FY19. • Report provided to TCEQ for events, including number of COMPLETE for FY20. Spring 2019 and Spring 2020. eggs oiled per event Event to be repeated in Spring 21 PENDING APPROVAL. Submit draft and final BMPs IN PROGRESS No items to-date. Section 3.1 of Addressing Overabundant this Task Report is the second Urban and Non-Native Wildlife draft of this report. Task Report

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Task 4: BMPs Addressing Stormwater Infrastructure The objective of Task 4 is to reduce the E. coli loading from failing on-site sewage facilities (OSSFs), urban and stormwater runoff, and pet waste by providing education and assistance to OSSF owners, implementing additional stormwater management practices outside of the City’s Municipal Separate Storm Sewer System (MS4) permits, and reducing the amount of pet waste not picked up by pet owners. For FY21, a SOW change request was submitted to TCEQ, requesting to add Subtasks 4.6 and 4.7, described below. The SOW also requested that the Watershed Partnership discontinue the planned stormwater dumping monitoring program (see Subtask 4.2 for more information). The following subsections will fulfil the Task 4 Task Report deliverable (now Subtask 4.8) once updated at the end of the grant period.

Subtask 4.1: OSSF Education and Assistance Program Comal County hosts annual OSSF training in November and May. The City has coordinated with Comal County to publicize and participate in future OSSF training events related to the proper operation and maintenance of septic systems, including how to identify a failing system and guidance on how to repair or replace a system. The most recent training event was November 13, 2019. In-person workshops were suspended to reduce the spread of COVID-19. As a result, Comal County has posted seven online classes related to OSSF maintenance on their website. The Watershed Partnership has plans to advertise these OSSF maintenance classes on their website.

Subtask 4.2: Non-structural Stormwater BMPs Outside the City’s MS4 Jurisdiction The City is also implementing non-structural stormwater control measures outside of the City’s existing MS4 program. In FY19, the City began discussing potential locations for stormwater signage with Comal County. In addition, the City began exploring equipment options and potential locations for surveillance cameras. After further evaluation, the Watershed Partnership determined, in FY20, that the use of a surveillance camera to monitor potential dumping locations within the Watershed was impractical due to the lack of appropriate technology. Thus, the SOW revision submitted in August 2020 proposed redirecting this funding. The Watershed Partnership is in the process of determining potential locations for signs within the watershed that read “No Dumping” and “Entering the Dry Comal Creek [and/or] Comal River Watershed”. The Watershed Partnership decided not to pursue the installation of “Do Not Dump” signs at creek crossings outside to City limits, due to a limited number of appropriate locations. Grant language was updated to include signage locations within City limits as well. The Watershed Partnership plans to erect “No Dumping” signs at locations within City limits where roadways cross the Dry Comal Creek. In addition, the Watershed Partnership also plans to erect “Entering the Dry Comal Creek [and/or] Comal River Watershed” at locations along

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Watershed boundaries within City limits (Figure 16). The Watershed Partnership is awaiting the approval of the revised scope to move forward with this signage.

Figure 16: Draft Watershed Signage

Subtask 4.3: Stormwater Outreach and Education The Watershed Partnership plans to continue distribution of the 6”x9” postcard on stormwater quality and proper stormwater management (Figure 17 and Figure 18) developed in FY19. In FY19, these postcards were delivered to 5,266 addresses within the Watershed area outside of City limits. In FY20, in-person community events were suspended to reduce the spread of COVID-19. The Watershed Partnership is working to move events and material distribution opportunities to a virtual platform.

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Figure 17: Educational Stormwater Runoff Postcard – Side 1

Figure 18: Educational Stormwater Runoff Postcard – Side 2

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Subtask 4.4: Pet Owner Outreach and Education The Watershed Partnership is implementing a pet waste public outreach program that targets both within City limits and residential developments in unincorporated areas of the Watershed. In FY19, an educational pet waste postcard was developed to distribute at community outreach events and is pictured in Figure 19 and Figure 20. This postcard was made available to community members at the outreach and education events described in Section 5.3. Following the expansion of an existing dog park at Landa Street and Loop 337, in FY20, New Braunfels Puppy Playland, the Watershed Partnership installed a kiosk-style infographic, displaying the location of the park within the Watershed and educating park visitors about the importance of picking up pet waste (Figure 21 and Figure 22). Additionally, in-person community events were suspended to reduce the spread of COVID-19. The Watershed Partnership is working to move events to a virtual platform while continuing to provide materials at multiple locations within the Watershed. The Watershed Partnership has also distributed 200 postcards to community locations where the display brochures are located (i.e., ASPCA, Landa Park, the City of New Braunfels Library).

Figure 19: Educational Pet Waste Disposal Postcard – Side 1

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Figure 20: Educational Pet Waste Disposal Postcard – Side 2

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Figure 21: Puppy Playland Infographic

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Figure 22: Installed Puppy Playland Infographic

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Subtask 4.5: Pet Waste Stations The Watershed Partnership identified individual areas for pet waste stations, including but not limited to public areas, apartment complexes, and new developments. In FY 19 and 20, the Watershed Partnership met involved parties, reached out to the City’s Parks Department, homeowner’s associations (HOAs) and apartment complexes throughout the City, and ultimately, did not find a need for all 80 of the planned pet waste stations. Subsequently, as part of the SOW revision submitted, the Watershed Partnership requested that the goal for this task be reduced to the installation of 40, rather than 80, pet waste stations. Twenty-four pet waste stations were provided to non-municipal institutions and ten were provided to City parks. Additionally, the Watershed Partnership has installed three additional pet waste stations in the expanded New Braunfels Puppy Playland. The Watershed Partnership has documented the pet waste station locations as they are installed (Figure 23). The remaining pet waste stations will be distributed annually on an as-needed basis. In addition, the City has procured 1,000 pet waste bag dispensers (Figure 24). These will be passed out at community events in the future and provided to ASPCA to hand out as well.

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Figure 23: Waste Station Installation Map

Figure 24: Pet Waste Bag Dispensers

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Subtask 4.6: Analysis of E. coli Structural Stormwater BMPs Beyond the City’s MS4 Subtask 4.6 was added as part of the August 2020 SOW revision request. Progress will begin following approval.

Subtask 4.7: Reduce Animal Waste in Landa Park Runoff Water Subtask 4.7 was added as part of the August 2020 SOW revision request. Progress will begin following approval.

Status of Task 4 Deliverables Table 3 includes a comprehensive list of the detailed documentation submitted to TCEQ for each task and the status of each deliverable.

Table 3: BMPs Addressing Stormwater Infrastructure – Summary of Deliverables

Deliverable Status Documentation Provided to TCEQ Documentation of OSSF IN PROGRESS No items to date. workshops, including notices, agendas, meeting materials, and attendance lists, minimum of 2 Documentation of installation of PENDING No items to date. signs on storm grates, drains, APPROVAL Watershed boundaries, within the Watershed, and at creek crossings, including a map of installation sites, minimum of 30 5 Documentation of installation of IN PROGRESS Funding for this deliverable was surveillance equipment, proposed to be reallocated. including a map of installation sites Documentation of either virtual IN PROGRESS • 6”x9” postcard detailing BMPs or hard copy stormwater 5,266 postcards related to stormwater runoff has educational materials distributed mailed in FY19. been approved by TCEQ. at community events, minimum Postponed due to of two per year COVID in FY20. Documentation of pet waste IN PROGRESS • 6”x9” postcard detailing BMPs educational materials distributed Available at all related pet waste disposal has at community events, minimum outreach events and been approved by TCEQ. of two per year Landa Park information kiosk. Postponed due to COVID in FY20. Documentation of pet waste IN PROGRESS • Map of installation sites station installations, including a 34 distributed within map of installation sites, watershed in FY19 minimum of 8040 and 3 in FY20.

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Deliverable Status Documentation Provided to TCEQ Analysis of E.coli Structural PENDING No items to date. Stormwater BMPs Beyond the APPROVAL City’s MS4 Report

Subcontract with the clean-up PENDING No items to date. service APPROVAL

Submit draft and final BMPs IN PROGRESS No items to-date. Section 3.2 of this Addressing Stormwater and Task Report is the second draft of Infrastructure Task Report this report.

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Task 5: Outreach and Education The objective of Task 5 is to provide information on the current sources of E. coli in the watershed and strategies for reducing E. coli pollution. Educational programs will encourage the community to change behaviors where necessary (e.g., not feeding urban wildlife). In addition to the subtasks listed below, the City continues to provides updates to stakeholders through distribution of this report and an annual infographic, email correspondence, and in- person or virtual meetings. The following subsections will fulfil the Task 5 Task Report deliverable (Subtask 5.5) once updated at the end of the grant period.

Subtask 5.1: News Campaigns In FY19, the Watershed Partnership began coordinating with local media to disseminate information about the BMPs. A summary of media published either on local channels, in local newspapers, or through press release is shown in Table 4. The Watershed Partnership also began seeking a firm to create a video campaign for the WPP.

Table 4: Summary of News Campaign

Date Media Type Description Newspaper 12/14/18 Herald-Zeitung published an article on the wildlife feeding ordinance. (Article/Ad 1) Newsletter Fall 18 MMOR article on “Help Keep our Wildlife Wild!”. (Article/Ad 2) Television 1/2/19 KENS5 aired a story detailing the implementation of the WPP. (News Release 1) Newspaper The Herald-Zeitung listed the wildlife feeding ordinance as one of its 1/2/19 (Article/Ad 3) top ten stories of 2018. A news release was issued by the City, advertising that there would Newspaper 2/4/19 be an urban wildlife management workshop held on the following (Article/Ad 4) week (2/13/19). Newspaper The Herald-Zeitung published an article advertising that the City was 2/8/19 (Article/Ad 5) holding an urban wildlife management workshop. The Herald-Zeitung published an article titled Leave it Wild, detailing Newspaper 2/16/19 the education efforts conducted by the City staff regarding the new (News Release 2) wildlife feeding ordinance. Newspaper The Community Impact newsletter published an article that discussed 2/18/19 (Article/Ad 7) the WPP efforts. Newspaper MMOR article on “Prohibiting the feeding of wildlife to protect our Spring 19 (Article/Ad 8) rivers and lakes.” 12/18/19 Newspaper MMOR article on “Alternatives to Feeding Wildlife.” Winter 2020 (Article/Ad 10) 6/15/2020 Newsletter MMOR article on “Don’t drop it!.” Summer 2020 (Article/Ad 11) The Herald Zeitung published a quarter page educational graphic, Newspaper 7/10/20 created by the Watershed Partnership. The first instalment described (News Release 3) a watershed (Figure 25).

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Date Media Type Description Newspaper The Herald Zeitung published a quarter page informational graphic, 7/11/20 (News Release 4) created by the Watershed Partnership. The second instalment detailed the importance of a healthy watershed (Figure 26). Newspaper The Herald Zeitung published a quarter page informational graphic, 7/17/20 (News Release 5) created by the Watershed Partnership. The third instalment detailed reasons why feeding wildlife can be harmful (Figure 27). Newspaper The Herald Zeitung published a quarter page informational graphic, 7/18/20 (News Release 6) created by the Watershed Partnership. The fourth instalment detailed healthy foods for wildlife to eat (Figure 28). Newspaper The Herald Zeitung published a quarter page informational graphic, 7/31/20 (News Release 7) created by the Watershed Partnership. The fifth instalment detailed the importance of picking up pet waste (Figure 29). Newspaper The Herald Zeitung published a quarter page informational graphic, (News Release 8) created by the Watershed Partnership. The sixth instalment detailed 8/1/20 actions Watershed residents could take to ensure the health of their community (Figure 30). The Community Impact newspaper published an informational half- Newspaper page insert, created by the Watershed Partnership, detailing the 8/20 (News Release 9) importance of the WPP and the actions taken by the Watershed Partnership to date (see Figure 31). Digital Ad The Watershed Partnership designed two sizes of digital ads which 7/20 – 8/20 (Article/Ad 12) have been displayed on the Herald Zeitung’s website. Digital Ad The Watershed Partnership designed two sizes of digital ads which 7/20 – 8/20 (Article/Ad 13) have been displayed on the Community Impact’s website. The biannual New Braunfels Parks and Recreation “Fun Things in Fall & Winter Newspaper Life” newsletter published a half-page insert detailing the importance 2020 (News Release 10) of the WPP and the actions taken by the Watershed Partnership to date (see Figure 31).

In FY20, the Watershed Partnership contracted with Iniosante (October 11th, 2019), a local video production firm, to create a video campaign planned for release on social media, the Watershed website, informational displays and in local theaters in 2020. A kick-off meeting was held October 24th, 2019. The Watershed Partnership extended an open casting call to stakeholders and City and Comal County employees with an excellent response; however, the impacts of COVID-19 caused many of the volunteers to rescind their response. Additional funding was allocated to the project to cover the costs of hiring acting talent to fill the roles previously filled by volunteers. Iniosante has secured filming locations, including the fishing pier at Landa Park. Iniosante conducted filming June 26th - 28th. The City has signed an agreement to run the video before the screening films in two local movie theaters for 10 weeks in FY21. These theaters are located in New Braunfels and Schertz along the I-35 corridor. The Watershed Partnership also published educational materials in two local publications, the Herald-Zietung and the Community Impact newspapers. The graphics educated the community on the watershed and the WPP and encouraged residents and visitors of the watershed to participate in BMP implementation.

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Figure 25: Herald Zeitung Week 1 Publication

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Figure 26: Herald Zeitung Week 2 Publication

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Figure 27: Herald Zeitung Week 3 Publication

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Figure 28: Herald Zeitung Week 4 Publication

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Figure 29: Herald Zeitung Week 5 Publication

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Figure 30: Herald Zeitung Week 6 Publication

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Figure 31: Community Impact Half-Page Insert

Subtask 5.2: Youth Activities In FY19, the Watershed Partnership developed three presentations for youth at levels suitable for elementary school-age, middle school-age, and high school-age students. Pictured in Figure 32, Figure 33, and Figure 34 are the presentation slides educating students at an elementary, middle, and high school level, respectively, about how to improve watershed health. In addition, the Watershed Partnership created the following educational materials for distribution at youth and community events: • Lab guidebook, detailing E. coli sampling (Figure 35) • WPP Best Practices activities worksheet (Figure 36) • An explanatory BST infographic (Figure 37) • Four maps displaying school locations within the Watershed (Figure 38) Table 5 summarizes the presentations that the City has given to local students. In FY20, in-person classroom learning events were suspended to reduce the spread of COVID- 19. The Watershed Partnership is working to move learning opportunities to a virtual platform.

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Figure 32: Elementary School Level Outreach Presentation Example Slide

Figure 33: Middle School Level Outreach Presentation Example Slide

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Figure 34: High School Level Outreach Presentation Example Slide

Figure 35: Lab Guidebook Cover Pages

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Figure 36: WPP Best Practices Activity Worksheet

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Figure 37: Explanatory BST Infographic

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Figure 38: All School Levels within Dry Comal Creek and Comal River Watershed

Table 5: Summary of Youth Outreach Events

Date School Topics Discussed Number of Attendees WPP implementation, New Braunfels Middle E. coli pollution and 4/15/19 440 School sources, no-feed ordinance, pet waste WPP implementation, Garden Ridge E. coli pollution and 4/24/19 120 Elementary School sources, no-feed ordinance, pet waste WPP implementation, E. coli pollution and 5/15/19 Canyon High School 133 sources, no-feed ordinance, pet waste WPP implementation, 6/17/19, 6/24/19, Comal ISD Summer E. coli pollution and 240 7/22/19 Camp students sources, no-feed ordinance, pet waste

6/24/19 Oak Creek Elementary WPP implementation, 60 E. coli pollution and

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Date School Topics Discussed Number of Attendees sources, no-feed ordinance, pet waste Presentation for teachers focused on promoting water 8/6/19 Canyon High School quality and watershed 8 protection curriculum into the Comal ISD science classes Presentation for teachers focused on promoting water 8/7/19 Seguin Learning Center quality and watershed 21 protection curriculum into the Comal ISD science classes

Subtask 5.3: Outreach at Local Events The Watershed Partnership has coordinated participation in local events. In FY19, youth outreach materials, as well as a portable standing display (see Figure 39 and Figure 40), were developed for use at these events to educate community members about the WPP efforts. Although in-person community events were suspended in FY20 to reduce the spread of COVID- 19, the Watershed Partnership participated in several community events prior to shutdowns (Table 6). The Watershed Partnership also procured a more durable outdoor version of the portable standing display. Additionally, the Watershed Partnership is working to move events to a virtual platform.

Table 6: Summary of Community Outreach

Approximate Number Date Event Description of Activity of Attendees

The City hosted a booth in the morning Dos Rios River of the annual Dos Rios River Watershed 9/21/19 245 Watershed Cleanup Cleanup, where City staff and volunteers educated attendees about the ongoing WPP implementation efforts. The City presented an overview of the Rotary Club 10/2/19 WPP and implementation 100 Presentation measurements to the New Braunfels Rotary Club. The City, with GBRA, hosted a booth at ScienceFest. Families attending the 10/6/19 ScienceFest annual science fair had the opportunity 800 to learn about ongoing WPP implementation efforts.

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Approximate Number Date Event Description of Activity of Attendees

The City hosted a booth at the City Community Arbor Arbor Day event held in Landa Park. 10/19/19 150 Day City staff discussed the ongoing WPP implementation efforts with Arbor Day attendees. The City hosted a booth at the Central Central Texas Texas Stormwater Conference, where 1/15/20 Stormwater City staff and volunteers educated 202 Conference attendees about the ongoing WPP implementation efforts. Watershed The City hosted a stakeholder meeting 1/23/20 Partnership where the outreach video script and 19 Stakeholder Meeting concept were reviewed by stakeholders.

Figure 39: Portable Display used at Local Outreach Events

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Figure 40: City and GBRA staff conducting outreach at ScienceFest

Subtask 5.4: Hire Watershed Education Personnel The Watershed Partnership in collaboration with NBU hired a part-time watershed educator, who began work on June 8, 2020. The educator will be employed for approximately 750 hours throughout the grant period to provide nonpoint source pollution and urban wildlife management education programs to residents, community groups, and students.

Subtask 5.5: Develop New Nonpoint Source Pollution Education Activities and Materials In FY19, the Watershed Partnership developed the educational materials described in Subtask 5.2. In addition, the City held a meeting with GBRA and the Comal and New Braunfels ISD science coordinators. During this meeting, the Watershed Partnership coordinated presentations to teachers during summer education programs. During presentations to the Comal ISD 7th Grade Teachers (held on October 8th, 2019) and at Comal ISD University (held on July 31,2018), the Watershed Partnership has facilitated discussion about including WPP education in lesson plans, while teachers still comply with the Texas Essential Knowledge and Skills (TEKS) and prepare for standardized testing. In FY20, the Watershed Partnership continued to coordinate with local teachers and with NBU Headwaters staff. The Watershed Partnership also met with NBU Headwaters staff to discuss short-term and long-term goals and tasks for the watershed educator (Subtask 5.4), who has developed multiple interactive lesson plans.

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Subtask 5.6: Watershed Visualization Tool Subtask 5.6 was added to the revised grant SOW request in August 2020. Progress will begin following approval.

Subtask 5.7: Hands-On Learning Module Subtask 5.7 was added to the revised grant SOW request in August 2020. Progress will begin following approval.

Subtask 5.8: Online Educational Games Subtask 5.8 was added to the revised grant scope in August 2020. Progress will begin following approval.

Status of Task 5 Deliverables Table 7 includes a comprehensive list of the detailed documentation submitted to TCEQ for each task and the status of each deliverable.

Table 7: Outreach and Education – Summary of Deliverables

Deliverable Status Documentation Provided to TCEQ Documentation of news releases, COMPLETE • 10 news releases completed minimum of 6 Documentation of advertisements or COMPLETE • 13 articles/ads completed; all approved articles in newsletters, minimum of 10 by TCEQ prior to publication Video to air on public access and/or IN PROGRESS. • Draft script and storyboard video displays Video complete • Final video and airing in • Movie theatre contract local theatres Documentation of youth activities, IN PROGRESS; • Documentation listing the school visited, including event details, materials, and 9 classroom number of attendees, date, and topics number in attendance, minimum of presentations covered have been submitted to TCEQ. eight per year • Draft and final versions of the presentations given in the classrooms have been approved by TCEQ. Documentation of community events, IN PROGRESS; • Documentation listing the community including event details, materials, and 6 events event attended, number of attendees, number in attendance, minimum of completed date, and topics covered have been four per year submitted to TCEQ. Draft and final portable display COMPLETE • Portable display has been approved by TCEQ. Subcontract with a project partner to COMPLETE. • Subcontract hire a part-time watershed educator Draft and final educational materials PLANNING IN • Lesson plans for the Headwaters Facility PROGRESS Watershed visualization tool PENDING No items to date. APPROVAL Draft and final hands-on learning PENDING No items to date. module and workbook APPROVAL

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Deliverable Status Documentation Provided to TCEQ Draft and final online educational PENDING No items to date. games APPROVAL Submit draft and final Education and IN PROGRESS No items to-date. Section 3.3 of this Task Outreach Task Report Report is the second draft of this report.

Task 6: Data Acquisition and Analysis The objective of Task 6 is to acquire, compile, and evaluate data collected by project partners. The data will be used to track progress toward the E. coli reduction goals identified in the Dry Comal Creek and Comal River WPP. The following subsections will fulfil the Task 6 Task Report deliverable (Subtask 6.3) once updated at the end of the grant period.

Subtask 6.1: Acquire and Evaluate E. coli Data The Dry Comal Creek and Comal River WPP has a 10-year goal for reducing E. coli concentrations in the waterbodies. Reduction in pollution loads and associated E. coli concentrations in the Dry Comal Creek and Comal River is anticipated to occur gradually. Additionally, there are many variables outside the Watershed Partnership’s control that impact E. coli concentrations (e.g., land use changes, effectiveness of BMPs, source population changes, weather, etc.). Because of these factors, the first reduction benchmark will be evaluated in FY21. However, updated graphs shown on the following pages provide an assessment of changes in E. coli concentrations over time. Locations monitored are plotted on a map in the WPP. E. coli GeoMeans in the Comal River (Figure 41) have been declining over the past six months but are still within the range of historical concentrations observed. The decrease observed in 2016 to 2017 was attributed to the higher streamflows. However, the recent fluctuation in GeoMeans may be at least partially due to samples collected within 48 hours of receiving more than 0.2 inches of rain; as the portion of samples taken after more than 0.2 inches of rainfall in the 12-month GeoMeans declined, so did the 12-month GeoMean. Twelve-Month E. coli GeoMeans in the Dry Comal Creek (Figure 42) have been relatively stable or slightly increasing, with the exception of the Dry Comal Creek at Walnut Avenue and Seguin St. sampling locations. The E. coli concentration at the Dry Comal Creek at Walnut Avenue and Seguin St. sampling locations (furthest downstream) has decreased significantly. Only one of the most recent 12 sampling events shown has had an E. coli concentration above the detection limit (i.e., > 2400 or 4800 CFU/mL). These events continue to generally be correlated with the portion of samples collected following rain events (i.e., > 0.2 inches of rain in the previous 48 hours). Figure 43 compares the number of samples taken following rain events with the 12- Month GeoMean of E. coli concentrations at the Dry Comal Creek at Walnut Avenue sampling location.

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CR @ Pecan Island CR @ Landa Haus CR @ Landa Park Area 16 CR @ Hinman Island CR @ River Run CR @ Mill Pond 600 CR @ Garden St. CR @ Last Tuber's Exit USGS Daily Flow from Comal River at Hinman Island (cfs)

E. coli coli E. 500

400

300

200 Month GeoMean GeoMean of Month

- 100 Concentrations (CFU/100 (CFU/100 mL) Concentrations 12 andComal River (CR) Flow (cfs) 0 600Jan-12 Jan-13 CR Jan-14@ Pecan Island Jan-15 Jan-16 Jan-17 Jan-18CR @ Landa HausJan-19 Jan-20 Jan-21 CR @ Landa Park Area 16 CR @ Hinman Island CR @ River Run CR @ Mill Pond 500 CR @ Garden St. CR @ Last Tuber's Exit USGS Daily Flow from Comal River at Hinman Island (cfs) E. coli coli E. 400

300

200 Month GeoMean of GeoMean Month -

24 (CFU/100 mL) Concentrations 100 andComal River (CR) Flow(cfs)

0 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21

Figure 41: 12- and 24-Month E. Coli GeoMeans along the Comal River (CR) from January 2012 through January 2021

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DCC @ Knights of Columbus DCC @ Walnut Ave. DCC @ Loop 337 DCC @ Altgelt Ln. DCC @ Solmes Rd. DCC @ Krueger Canyon 1000 GBRA Flow from Dry Comal Creek at Knights of Columbus (cfs): 1000.0 E. coli coli E. 800 100.0

600 10.0

400 1.0 Month GeoMean GeoMean of Month

- 200 0.1 Concentrations (CFU/100 (CFU/100 mL) Concentrations 12 Dry Comal Creek (DCC) Fow (cfs) Fow (DCC) Creek Comal Dry

0 DCC @ Knights of Columbus DCC @ Walnut Ave. 0.0 1000Jan-12 DCCJan-13 @ Loop 337 Jan-14 Jan-15 Jan-16 Jan-17DCC @ AltgeltJan-18 Ln. Jan-19 Jan-20 Jan-21 1000.0 DCC @ Solmes Rd. DCC @ Krueger Canyon GBRA Flow from Dry Comal Creek at Knights of Columbus (cfs): 800 100.0 E. coli coli E.

600 10.0

400 1.0 Month GeoMean of GeoMean Month - 24 Concentrations (CFU/100 (CFU/100 mL) Concentrations 200 0.1 Dry Comal Creek (DCC) Flow (CFS) Flow(DCC) Creek Comal Dry

0 0.0 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 Jan-17 Jan-18 Jan-19 Jan-20 Jan-21

Figure 42: 12- and 24-Month E. Coli GeoMeans along the Dry Comal Creek (DCC) from January 2012 through January 2021

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DCC at Seguin Street DCC at Walnut Ave. Sampling Events with >0.2-in Precipitation Within 48 Hours of Sampling

800 8 700 7 E. coli coli E. 600 6

500 5 in Precipitation - 400 4 300 3 200 2 Month GeoMean of GeoMean Month

- 100 1 12 Concentrations (CFU/100 (CFU/100 mL) Concentrations 0 0 Within 48 Hours of Sampling 48 Hours Within Sampling Events with >0.2 Events Sampling E. coli Sample Date

Figure 43: E. Coli GeoMeans at the Dry Comal Creek at Walnut Avenue vs. Number of Samples Taken Following Rain Events

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Subtask 6.2: Wastewater Discharge Water Quality Assessment The Watershed Partnership is also tracking E. coli data submitted to the TCEQ on wastewater discharges (i.e., Texas Pollutant Discharge Elimination System [TPDES] permits) within the Watershed. The Watershed Partnership performed a search in TCEQ Central Registry and EPA Enforcement and Compliance History Online (ECHO) databases for current wastewater discharge and related permits in the Watershed. Description of the wastewater-related permits are summarized in Table 8.

Table 8: Summary of Discharge Permits in Comal River and Dry Comal Creek Watershed

Permittee Description of Discharge Description of Monitoring DISCHARGE PERMITS • When discharge occurs, monitoring is required in the form of grab samples collected from outfall number 001, where outflow from the stormwater settling pond flows to the Cemex Dry Comal Creek. Construction • Monitoring must be conducted daily Materials South, • From the Balcones Cement Plant, and must be reported to the TCEQ LLC which manufactures Portland and monthly for parameters including masonry cement flow, chemical oxygen demand, total (TPDES permit • Discharges to a settling pond through dissolved solids, total suspended WQ2179000; a controlled weir and into a 24-inch solids, turbidity, E. coli, and pH. TX0077534 was concrete pipe, and subsequently to renewed 3/12/20 • Discharge limits include a daily the Dry Comal Creek through maximum E. coli concentration of 03/12/25) 399 CFU/100 mL • Stormwater discharges are monitored according to provisions outlined in the facility’s Stormwater Pollution Prevention Plan, which is a requirement of the facility’s TPDES permit.

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Permittee Description of Discharge Description of Monitoring • Self-monitoring is required for parameters including flow, Meyer Ranch carbonaceous biochemical oxygen • Municipal Utility Treat and discharge of wastes from demand (5-day), total suspended District WWTP, the Meyer Ranch Wastewater solids, ammonia nitrogen, total as of 2/8/19 Treatment Facility (WTF) phosphorus, total nitrogen, and E. coli. (formerly • Permit includes interim discharge Randolph Todd requirements for the expansion to • A grab sample of all parameters Company LLC) 0.15 million gallons per day (MGD) other than flow and E. coli must be collected once per week. Flow must (TPDES permit and expanded 0.39 MGD facility be recorded continuously, and a WQ15314001A; • Discharge location is in the grab sample for E. coli must be TX0135976 was uppermost reaches of Dry Comal collected five times per week. renewed 5/8/20 Creek where it is likely to infiltrate • Discharge limits include a daily through 5/8/25) under normal conditions average E. coli concentration of 126 CFU/100 mL and a maximum E. coli concentration of 399 CFU/100mL. OTHER WASTEWATER PERMITS • SJWTX, Inc. No discharge of pollutants to the Dry • Annual grab samples at two Comal Creek or Comal River (TPDES permit different soil monitoring points on- • Treated domestic sewage effluent WQ15320001 site discharge is limited to 0.035 MGD in was renewed Phase I, 0.070 MGD in Phase II, and • Monitoring is required for 3/3/20 through 0.130 MGD in Phase III (disposed via parameters including flow, 3/3/2030) surface irrigation) carbonaceous biochemical oxygen demand (5-day), total suspended • Treatment of private domestic solids, ammonia nitrogen, total wastewater from the facility, Vintage Facility Owner: phosphorous, pH, and E. coli SouthStar at Oaks at the Vineyard, a 40-acre Vintage Oaks, subdivision • Monitoring data are maintained on LLC • Wastewater storage in a synthetically site (no requirement for Discharge lined pond on-site Monitoring Reports) Northcliffe Wastewater • No discharge of pollutants to the Dry • No E. coli monitoring Treatment Comal Creek or Comal River • Monthly grab samples for flow, Facility • Dispose of treated domestic biochemical oxygen demand (5- (Permit No. wastewater effluent at a daily average day), total suspended solids, WQ11751001 flow rate not to exceed 0.30 MGD via chlorine residual and pH surface irrigation at the Northcliffe expired 2/1/20) • Country Club golf course in the City of Five times per week instantaneous Owner/Operator: Schertz flow recording and grab samples GBRA for chlorine residual

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Permittee Description of Discharge Description of Monitoring Comal High School No. 4 Wastewater • Treatment No E. coli monitoring • No discharge of pollutants to the Dry Facility • Comal Creek or Comal River Monthly grab samples for biochemical oxygen demand (5- • Dispose of treated domestic day), total suspended solids, and (Permit No. wastewater effluent at a daily average pH WQ00124533002 flow not to exceed 0.02 MGD via through 1/2/24) surface irrigation of a 7.5-acre public • Five times per week instantaneous grass land flow recording and grab samples

• Wastewater storage in a 2.75 acre- for chlorine residual Facility Owner: feet pond onsite • Continuous monitoring required for Comal flow Independent School District

Table 9 presents the E. coli concentrations present in the Cemex facility’s permitted wastewater discharge over time, as well as the volume of the permitted wastewater discharges. E. coli data are only available in Discharge Monitoring Reports submitted to TCEQ for the Cemex facility (TPDES Permit # 02179-000) at this time. Note that while the Watershed Partnership may also track new wastewater treatment, land application or sludge holding tank permits in the Watershed (as summarized in the previous table), data analysis is limited to wastewater discharges that are required to report E. coli data. Although no DMR data were available for download on the Meyer Ranch discharge, the average daily E. coli permit limit does correspond with the State’s recreational limit for E. coli. Additionally, under normal conditions, this flow is anticipated to infiltrate prior to reaching the downstream segments of Dry Comal Creek. Overall, data show that the discharge from the Cemex plant is not contributing significant amounts of E. coli to the Dry Comal Creek and generally makes up a small fraction of the total streamflow, except for rare occasions where the Dry Comal Creek flow is ≤ 0.1 MGD. In fact, based on E. coli sampling in the Dry Comal Creek, E. coli concentrations are consistently decreasing between the sample points before and after the Cemex outfall (DCC at Krueger Canyon and DCC at Loop 337, respectively), except under very low flow conditions. Of the four incidents when the E. coli concentration increased downstream in the Dry Comal Creek, only one corresponded with a high volume of discharge from the Cemex Plant. Further, recent FY 20 measurements of E. coli were all below detection limits. Thus, no changes are recommended at this time for the wastewater BMPs.

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Table 9: Cemex Discharge E. Coli Data Analysis

Dry Comal E. coli at E. coli in the Cemex Creek (DCC) % DCC @ E. coli at DCC % Change in Cemex Plant Discharge Date Total Stream- Krueger @ Loop 337 E. coli Discharge Flow Streamflow flow Canyon (CFU/100mL) Concentration (CFU/100mL) (MGD) (MGD) (CFU/100mL) Dec-17 0 0.0004 23.1 0% 3500 47 -99% Jan-18 - 0.0111 0.16 7% 34 17 -50% Feb-18 - 0.0135 0.25 5% 200 200 0% Mar-18 42 0.0129 3.98 0% 240 100 -58% Apr-18 - 0.0008 0.21 0% 140 150 7% May-18 - 0.0002 0.02 1% 97 580 498% Jun-18 17 0.0042 0.01 65% 10 72 620% Jul-18 - 0.0036 0.01 28% 59 58 -2% Aug-18 1 0.0111 0.00 100% 260 60 -77% Sep-18 - 0.0042 0.00 100% 15 1 -93% Oct-18 - 0.0134 3.04 0% 330 200 -39% Nov-18 0 0.0071 1.21 1% 100 190 90% Dec-18 - 0.0223 0.76 3% 59 33 -44% Jan-19 - 0.0071 2.29 0% 2400 2000 -17% Feb-19 0 0.0018 1.69 0% 230 86 -63% Mar-19 - 0.0021 5.22 0% 160 140 -13% Apr-19 - 0.0021 0.67 0% 320 190 -41% May-19 0 0.0042 0.17 2% 20 170 750% Jun-19 - 0.0111 0.15 7% 82 20 -76% Jul-19 - 0.0071 0.01 55% 170 150 -12% Aug-19 0 0.004184 0.00 - 210 83 -60% Sep-19 - 0.007136 0.00 - 40 1100 2650% Oct-19 - 0.001088 0.00 - 27 81 200% Nov-19 0 0.000831 0.02 4.2% 180 340 89% Dec-19 - 0.00048 0.03 1.6% 690 17 -98% Jan-20 - 0.000183 0.06 0.3% 78 54 -31% Feb-20 0 0.001387 0.78 0.2% 3500 770 -78% Mar-20 - 0.004184 0.13 3.2% 85 52 -39% Apr-20 - 0.000183 3.43 0.0% 1200 920 -23% May-20 0 0.000183 0.27 0.1% 55 40 -27% Jun-20 - 0.00048 1.30 0.0% 290 690 138%

Status of Task 6 Deliverables Table 10 includes a comprehensive list of the detailed documentation submitted to TCEQ for each task and the status of each deliverable.

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Table 10: Data Acquisition and Analysis – Summary of Deliverables

Deliverable Status Documentation Provided to TCEQ Graphs or tables of updated IN PROGRESS • Updated E. coli data data, annually (Submitted • Updated water quality data 8/28/19 for • Updated list of wastewater discharges within Watershed FY19; Updated • Memorandum summarizing updates to water quality herein for FY20 Submit Draft and Final Acquired IN PROGRESS No items to-date. Section 6 of this Task Report is the second Data Analysis Report draft of this report.

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Task 7: Storm Event Monitoring As part of the August 2020 SOW revision request, the Watershed Partnership requested reallocation of funding to collect, compile, and evaluate stormwater quality data. Monitoring water quality at outfalls near locations where E. coli increases have been observed will inform evaluation and selection of locations for future stormwater BMPs (refer to Subtask 4.6). Progress will begin following approval.

4. Discussion This section will be completed as part of the final deliverable in 2022.

Deliverables Not Completed

Lessons Learned

Recommendations

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5. Water Quality Results Achieved This section will be completed as part of the final deliverable in 2022.

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