Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems


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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems
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Edwards Aquifer Recovery Implementation Program
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HALFF
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This report is an initial study and compilation of existing data and research that illustrates the impacts of water-based recreational activities on protected species and habitats in the Comal and San Marcos Springs ecosystems for the Edwards Aquifer Recovery Implementation Program (EARIP). The EARIP limited the project area to those portions of the Comal and San Marcos Springs that are within the city limits of New Braunfels and San Marcos.This study is a summary of existing data that was made available to Halff Associates by the Edwards Aquifer Recovery Implementation Program, the cities of New Braunfels and San Marcos, Texas Commission on Environmental Quality, U.S. Fish and Wildlife Service and the River Systems Institute of Texas State University. During the course of the study, existing data from various sources was reviewed and evaluated in an effort to identify and locate water-based recreational activities within the limits of the project area. Halff Associates worked to quantify and map the numbers of users, times of use, types of users and the areas they frequent, numbers and locations of endangered species, the locations and limits of their habitats. Halff also conducted review of existing ordinances that pertain to recreation and recreation development on and around the springs. Interviews with various stakeholders were conducted. Water quality data on protected species and their habitats was mapped. A review of existing scientific studies regarding recreational impacts on protected species and economic data from existing studies that was pertinent to the project area was reviewed. The sources of all this data include scientific studies, consultant studies, public agency records and stakeholder interviews.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 1 TABLE OF CONTENTS Executive Summary I. Data Collection .............................................................................................................. 6 II. Existing Ordinances .................................................................................................... 10 III. GIS Database Preparation .......................................................................................... 28 IV. Stakeholder Interviews ............................................................................................. 33 V. W ater Quality Data .................................................................................................... 46 VI. Pertinent Scientifi c Studies ........................................................................................ 57 A. Pertinent Studies .................................................................................................... 56 B. Relevant Studies .................................................................................................... 66 VII. Ec onomic Information .............................................................................................. 70 VIII. R ecreational Impacts & Further S tudy ..................................................................... 75 Bibliography .................................................................................................................. 81 List of Tables 1. New Braunfels Recreation Outfitters 2. San Marcos Recreation Outfitters 3. River Recreation Ordinances 4. Reported Recreation Activity 5. Attributes: Recreation Area 6 . Exhibit Index 7 . New Braunfels Stakeholders Iss u es 8 . San Marcos Stakeholders Issues 9 . TCEQ Clean Rivers Program Monitoring Stations: Comal River 10. TCEQ Clean Rivers Program monitoring Stations: San Marcos Riv er 11. TCEQ Water Quality Sampling Parameters 12. 2008 Texas Water Quality Inventory Stream Segments in Study Areas

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 2 Appendix A: GIS Map Exhibits Exhibit A1 – Tubing Exhibit A2 – Paddle Boats Exhibit A3 – Picnic Areas/RV Campgrounds Exhibit A4 – Swift Water Rescue Training Exhibit A5 – Swimming Exhibit A6 – Tube, Paddle Boat, Kayak, Canoe Rentals Exhibit A7 – Fishing Exhibit A8 – Wading, Lounging, Playing, and Rope Swing Exhibit A 9 – All Uses New Braunfels Potential Wildlife Habitat Maps Exhibit A10 – Comal Springs Dryopid Beetle, Peck’s Cave Amphipod Exhibit A-11 – Comal Springs Riffle Beetle Exhibit A-12 – Fountain Darter San Marcos Recreation Area Maps Exhibit A 13 Tubing Exhibit A-14 – Fishing Exhibit A-15 – Kayaking, Canoeing Exhibit A-16 – Pic nicking Exhibit A-17 – Swimming Exhibit A18 Tube, Kayak, Canoe Rental Locations Exhibit A19 – Dog Park Exhibit A20 – Wading, Lounging Exhibit A-21 – All Uses San Marcos Potential Wildlife Habitat Maps Exhibit A-22 – Fountain Darter Exhibit A23 – San Marcos Gambusia Exhibit A24 – San Marcos Salamander, Texas Blind Salamander, Comal Springs Riffle Beetle Exhibit A25 – Texas Wildrice Appendix B : New Braunfels Stakeholder Interview Responses Appendix C: San Marcos Stakeholder Interview Responses Appendix D: USGS Water Quality Assessment of the Comal Springs Riverine System, NewBraunfels, Texas, 1993 94 Appendix E: Lodging Revenues Appendix F: Response to TWDB Comments

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 3 Acknowledgements Halff Associates, Inc. was retained by Texas Agrilife Exte nsion Service of the Texas A & M University System to prepare a Recreation Study for the Edwards Aquifer Recovery Implementation Program (EARIP) . Throughout the investigation process , Halff Associates Team has benefited a wide range of participants, including staff persons from c ities of New Braunfels and San Marcos , other researchers working with the EARIP faculty and staff from the Geography Department at Texas State University, and stakeholder and public interest groups . Participants listed below have our thanks and gratitude for the assistance they extended for the duration of p roject. City of New Braunfels (CNB) Nathan Pence, CNB River Manager Stacy LairdDicke, CNB Director of Parks Chad Don egan, CNB Golf Course Manager Judy Young, Visitors and Convention Bureau Michael Meek, Chamber of Commerce Suzanne Herblin , Wurstfest / Landa Falls Jason Hunter, WurstFest. / Landa Falls Cecil Eager, Gruene Mansion Inn Darren Hill, Schlitterbahn Water Park s City of San Marcos (CSM) Melani Howard, CSM Watershed Protection Manager Rodney Cobb, CSM Director of Community Services William Ford, CSM, Assistant Director of Community Services Fred Terry, Councillor, CSM, River Task Force Susan Narvais, Mayor CS M Rebecca YbarraRamirez, San Marcos Convention and Visitor Bureau Stephanie Langenkamp, Swim Advocate Duane TeGrotenhuis, T&G Canoe and Kayak Jack Fairchild, San Marcos Lions Club Tube Rentals Glen Hanley, Texas State University Golf Manager Tom Goynes, San Marcos River Retreat Chad Williams, Texas State University River Systems Institute, Texas State University Michael Abbott Meredith Blount Jenna Winters Thomas Hardy

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 4 EXECUTIVE SUMMARY This report is an initial study and compilation of existing data and research that illustrates the impacts of water based recreation al activities on protected species and habitats in the Comal and San Marcos Springs ecosystems for the Edwards Aquifer Recovery Implementation Program (EARIP). The EARIP limited the project area to those portions of the Comal and San Marcos Springs that are within the city limits of New Braunfels and San Marcos . This study is a summary of existing data that was made available to Half f Associates by the Edwards Aquifer Recovery Implementation Program , the cities of New Braunfels and San Marcos , Texas Commission on Environmental Quality, U.S. Fish and Wildlife Service and the River Systems Institute of Texas State University . During the course of the study, existing d ata from various sources was reviewed and evaluated in an effort to identify and locate water based recreational activities within the limits of the project area . Halff Associates worked to quantify and map the number s of users, times of use, types of users and the areas t hey frequent, numbers and locations of endangered species, the locations and limits of their habitats. Halff also conducted review of existing ordinances that pertain to recreation and recreation development on and around the springs. I nterviews with various stakeholders were conducted. W ater quality data on protected species and their habitats was mapped. A review of existing scientific studies regarding recreational im pacts on protected species and economic data from existing studies that was pertinent to the project area was reviewed . The sources of all this data includ e scientific studies, consultant studies, p ublic agency records and stakeholder interviews. Existing ordinances from the cities of New Braunfels and San Marcos that relate to wa t er based recreation al activities and development within the limits of the project were reviewed . T his section of the rep ort summarizes what those specific ordinances are. Of particular note is the restricted (recreation) use by respective city ordinance on the upper reaches of both the Comal Springs (Mill Run Channel and upstream) and San Marcos Springs (Spring Lake) systems. Also i ncluded in this summary are ordinances that pertain to development or potential recreation development adjacent the rivers. Geographical Information Systems software was utilized to map locations of water based recreational activities , locations o f water quality sampling stations and locations of listed species. While waters of the Comal and San Marcos springs systems are considered S tate property, access to and from the banks is restricted by land use/ownership ; t his information is also provided in the mapping data . Interviews with stakeholders included members of city staff, chambers of commerce, recreation and tourist based business owners/managers, representatives of user groups and members of city council. A questionnaire prepared by Halff Ass ociates , with the assistance of the EARIP was provided to stakeholders in advance of the interviews , to give interviewees the opportunity to e laborate on the questions and requested data.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 5 Scientific studies relative to the impacts of recreational activities on endangered species and their habitats were sought but few were foun d. Documents and studies included in the re views were habitat conservation plans, information pertaining to flood control and raw data from an ongoing doctoral study. There were also studies that were cited and referred to by some of the data providers, but several of these were not accessible for review. Economic information pertaining to recreational activities within each of the cities is very limited . There is no published data for San Marcos , although Halff provides extrapolated figures based on survey data provided by the Texas State University doctoral candidate and the information provided by the one and only tube vendor in this city for one particular year. T wo studies for the New Braunfels area on tourism and hospitality were made available , and i nformation on river based recreational activities was extrapolated from data included in both of the studies as there is no specific data on recreation in either study . The recreat ional impacts on these river systems are cultural, social, economic, and most importantl y, physical. The rivers are iconic elements within each of the two cities . With a large portion of the river banks fronting public parks, they are the center of community events and prime socializing spaces . As populations increase in C entral Texas, so does the popularity of recreating in these rivers and as such, there were reports of physical degradation of adjacent parks and banks, but qua nt itative data to identify t he extent of the degradation is minimal at best . The physical impact of litter and erosion is evident in the public parks and there are no real controls for capacity other than parking restrictions. Conclusion Further study is needed in the pursuit of spe cific and quantitative correlation s between recreational use s and listed species. Most of the important information in this docu ment is anecdotal and perceived, and some of the factual information is peripheral and could definitely be used to support more specific research. In summary, the information that Halff has explored within the body of this report provides a good starting point from which further study could be pursued.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 6 I. DATA COLLECTION Sources of information for this report were derived f rom a list of activities and facilities provided by the EARIP, the cities of N ew Braunfels and San Marcos, their chambers of commerce , stakeholder s referred to by the EARIP , the Texas Commission on Environmen tal Quality, Texas Department of Parks and Wildlife , United State s Fish and Wildlife Services and sources of lit erature provided by the River Systems Institute and the EARIP. Information regarding types of recreation vendors, activities, types of users, ti mes of use , numbers of users, regulations of use, economic information, water quality, and species locations were sought and GIS mapping was developed to illustrate locations of various attribu tes . The GIS mapping wi ll al so provide a base from which furth er study can be documented. The information provided within this document is known to be limited as some information sources that were referred to are not available . A. New Braunfels Recreation activities on the Comal River include: swimming, wading, lounging/picnicking, snorkeling, scuba diving, tubing, fishing, paddle boating, swift water rescue , and rope/tree jumping (though it is not lawful) . The most common activities are tubing, swimming, wading and lounging, and fishing. Paddle boating and fishing are the only activities permitted in Landa Lake, closer to the springs although there is very small area in Landa Park that permits wading and there is a spring fed public swimming pool that is dammed off from the Comal River and dates to the 1930’s within L anda Park. Most activity in the water is concentrated at the stretch from Landa Falls / Wurstfest grounds downstream to the Union Avenue exit commonly known as the last public exit. Upstream of Landa Lake is Texas Water Recreation District No. 1, which is a legislated are a designated for restricted use by adjacent property owners. W ood en docks and stacked canoes were observed along this water front . Members from the Halff team gathered information and data about recreational activities and events from city staff, member s of the convention and visitors bureau/chamber of commerce, recreational outfitters and various users of the springs . Tubing is the predominant recreational activity in the river. The City has an agreement with the tubing outfitters that limits the number of tubers on the river at any one time. There are significant number of tubers that do not rent tubes however, but choose instead to provide their own tube to enjoy the river. The costs of tub e rentals rang e between $10 $15 p er person, and the rental fee typically includes a shuttle ride from the tube outfitter to the river drop off and

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 7 pick up points. $1.25 of each tube rental is a river management fee that goes direct ly to the City of New Braunfels. The following list of waterbased recreational outfitters illustrates the variety of recreational activities available along the Comal River. Tube rental outfitters located along the banks of Guadalupe River were excluded from the list even though they are located within the city limits. It is also note worthy to advise that year 2010 was a bit of an anomaly because of the severe flooding experienced in early June; as a result, many outfitters were not access i ble for participation.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 8 Other activities that occur in the Comal River but do not generally require rental equipment or professional guidance include w ading, s wimming / snorkeling, f ishing, swift water rescue training, r ope/tree jumping, and l ounging / picnicking. In addition, there are numerous locations where river users can purchase tubes, and ad hoc tube outfitters are present along the river intermittently during the summer months. B. San Marcos Information gathered from interviews with stakeholders revealed that r ecreation activities on the San Marcos River include swimming, wading, lounging/picnicking, boat touring, snorkeling, scuba diving, tubing, fishing, rope swinging/jumping, boatin g (kayak and canoe), white water kayak training , dog playing . The most common activities are tubing, swimming, wading and lounging/picnicking. Spring Lake, where the springs originate, i s restricted to research use and guided boat tours either by kayak or glass bottom boat. Cost for glass bottom boat tours range between $6 $9; kayak tours are by appointment and are available through an the Aquarena Nature Center , operated by Texas State University. Scuba diving on this lake is permitted research purposes only. The prime areas of activity along the San Marcos River are between Sewell Park and Rio Vista Falls Park falls. Most of this stretch is adjacent public park property and access to the water is only limited by vegetation on the banks. As the demand for river activity grows, there is compelling physical evidence of trampled vegetation , bank damage and bank erosion caused by visitors to the River in their efforts to access the water. Information gathered regarding recreational activities and the events that surround them is from city staff, members of the convention and visitors bureau/chamber of co mmerce, recreational outfitters, various users , and researchers . The follow ing list of waterbased recreational outfitters illustrates the variety of recreational activities available along the San Marcos River.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 9 Other activities that occur in the San Marcos River but do not generally require rental equipment or professional guidance include w ading, swimming / snorkeling , f ishing, swift water rescue training, r ope/tree jumping , l ounging / p icnicking , scuba diving and d og pla y.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 10 II. EXISTING ORDINANCES Existing ordinances were collected from the cities of New Braunfels and San Marcos with the assistance of planning staff from each city. The majority of the ordinances in place in each city deal with development restrictions along the rivers, while there are a few ordinances that address particular behaviors or activities that typically occur. New Braunfels has a higher number of ordinances pertaining to recreation activities on the river than San Marcos does. A. City of Ne w Braunfels Land use and zoning districts alongside the Comal River with in the city of New Braunfels identifies areas of open space, commercial/resort land use districts, as well as low density residential. Each of these land uses and zones permit recreat ion activity of varying degrees. Ordinances related to development of recreation facilities within the floodplain as well as ordinances that relate directly to activities on the water are summarized in the following text. Most notable and o f specific relevance to riverbased activities (not specific to Comal) are the following o rdinances :

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 11 The following ordinances are focused on the control of recreational activities and providers within the city of New Braunfels. (NB) Section 23 50(f) – Entering rivers by jumping or dangerous acts It is a violation of this code to enter any river, lake stream or waterway by jumping, diving or doing any other dangerous act on or off any publicly owned bridge, street, highway, appurtenance, publicly owned land or public right of way unless for reason of rescuing someone from drowning. It is also a violation to jump dive or perform any dangerous acts on or off of trees, platforms, high banks, dams or other walkways to enter streams, rivers or waterways. (NB) Sec. 50 57. Prohibited accumulations; litter; weeds; graffiti; duty of property owner, occupant. (Code 1961, 8 34; Ord. No. 98 22, II, 8 1098; Ord. No. 2006 22, 1, 313 06) Owners and supervisors of real property occupied or not are not lawfully permit to allow filth, carrion, weeds, rubbish, junk, trash, waste products, brush and refuse, graffiti of any kind to remain on the property. Deposit of any such matter into or along any drain, gutter, alley, sidewalk, street or right of way, vacant lot (private or public) Weeds and Unsightly vegetation greater than 12 inches height within 150 feet of any right of way, alley or utility easement, building or structure is not permitted and Owners of real property shall maintain or remove such. Graffiti is not permitted on real property and shall be removed within 15 days of notice from health official. (NB) Section 58 33 Same – Duties and responsibilities (of the floodplain admi nistrator) ( Code 1961 ) To review permit applications to determine whether proposed building sites including mobile homes will be safe from flooding To review permits for proposed development to assure all necessary permits have been obtained from federal, state or local government agencies. To notify the state water commission and adjacent communities prior to any alteration or relocation of a watercourse and submit copies of such to FEMA Assure the flood carrying capacity within the altered or relocated po rtion of any watercourse is maintained To interpret the exact location of the boundaries of the flood plain in areas of special flood hazards where interpretation is needed When regulatory floodway has not been designated, the administrator must require no new construction, substantial improvements, or other development be permitted unless it can be demonstrated that the cumulative effect of the

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 12 proposed development when combined with all other existing and anticipated development will not increase the water surface elevation of the base flood more than one foot at any point within the community (NB) Section 58 34 Permit procedures ( Code 1961, ss 5 31, Ord. No. 9829, ss I) Dev Permits must describe extent of alteration or relocation of any watercourse or natural drainage as result of development (NB) Section 58 36 Provision for flood hazard reduction In areas of special flood hazard, structures must be adequately anchored to prevent flotation, collapse or lateral movement Construction methods and practi ces must minimize flood damage and of materials resistant to flood damage Water supply systems as well as sanitary sewage systems shall be designed to minimize or eliminate infiltration of floodwaters Recreation vehicle parks must develop a plan for evacuating residents All recreation vehicles must not be permitted to have uninflated tires or any condition that would impede, delay or hinder immediate evacuation With respect to floodways, encroachments are prohibited: including fill, excavation , ew construction, substantial improvements unless certification by a profession engineer or architect is provided to demonstrate encroachments do not increase in flood levels (NB) Sec tion 741. Park rangers and river project manag er authorized to issue citations. (Ord. No. 2004 24, I, 412 04) For the violation of any of the city ordinances under Chapter 86 "Parks and Recreation", Chapter 126 "Traffic and Vehicles", Chapter 6 "Animals" and section 82 9 and section 82 10 of Chapter 82 "Offenses and Miscellaneous Provisions." (Ord. No. 2003 34, I, 512 03; Ord. No. 2006 53, I, 6 26 06) (NB) Sec tion 8210. Noise prohibitions, public rights of way and public property, exceptions; penalty. It is unlawful to operate any radio, tape recorder, cassette player, CD player, DVD player or MP3 player or any other sound reproducing device any louder than audibility at 50 feet or more while located on public proper ty, exceptions are for athletic and city authorized events

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 13 (NB) Sec tion 8212. Volume drinking devices prohibited (Ord. No. 2006 54, I, 626 06) (a) Definitions. For the purpose of this section, the following definitions shall apply: Volume drinking devices means an object used, intended for use or designed for use in artificially increasing the speed with which, and/or amount of, alcohol is ingested into the human body by carrying the liquid from a higher location into the mouth by force of gravity or mechanical means, including but not limited to funnels, tubes and hoses. The term includes a beer bong. It is an offense to use or possess with intent of use in a public place (NB) Sec tion 82 13. Amplified sound devices prohibitions on the Comal and It is unlawful to operate or permit to be operated any amplified sound device or equipment between the hours of 10pm 8am. Violations may result in fines ranging Guadalupe Rivers. from $100 $500. (NB) Section 86 1 – Overnight camping prohibited; hours parks closed; penalty No tents for camping and no overnight camping is permitted within parks. No overnight parking of vehicles, portable buildings, camping units of any type are permitted. No person, vehicle or equipment or activity is permitted between the hours of 12am and 6 am with exception of grant by the city. (NB) Section 86 4 – Additional rule and regulations for control of parks and recreation ares and facilities ( Code 1961, ss 14A 6; Ord. No. 2003 51, ss I(2.) ) With the exception of city and city authorized equipment, it is unlawful to launch any type of boat, canoe, water vehicle or flotation device from the banks of Land Park Lake. It is unlawful to deposit /throw/drop/place loose paper, cans, bottles, sacks, boxes, cloths, waste materials, rubbish alongside any body of water within city limits. It is unlawful to drive any motor vehicle on any trail/footpath/footbridge spanning a creek or stream with the exceptio n of golf carts or maintenance vehicles It is unlawful to remove, destroy or damage any vegetation within parks and recreation areas. It is unlawful to wade or swim in any water body within the Landa Park Golf Course to retrieve golf balls or for any other purpose.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 14 (NB) Section 86 6 Swimming or wading prohibited in Landa park Lake; exception ( Code 1961, ss 14A -5) It is an offense to enter, wade, swim or engage in any aquatic activity in any area of Landa Park Lake with exception of area posted ‘wading area’; exception is law enforcement and public safety agencies operating water craft (NB) Sec tion 86 7. Operation of vehicles in parks (Code 1961, 14A 7; Ord. No. 987, I, 2 -998; Ord. No. 01 18, I, 3 12 01; Ord. No. 0163, I, 12 10 01; Ord. No. 2003 51, I(3.), 81103; Ord. No. 2004 25, I, 4 12 04; Ord. No. 2008 41, 1, 6 -908) Landa Park: operation of motor vehicles on designated portions of Landa Park Drive prohibited by law: 7am 8pm, Saturdays, Sundays a nd legal holidays from Easter weekend through Labor Day Hinman Island: operation of motor vehicle s of any kind prohibited by lawn on that portion of Hinman Island Drive from its west side intersection with Liberty Avenue in a westerly direction to its ea st side intersection with Elizabeth Avenue 7am – 8pm Saturdays, Sundays and legal holidays from Easter weekend through Labor Day when the barricades on Hinman Island Drive are closed.. Parking fees in Prince Solms Park East. There shall be a parking fee applicable 9am 6pm Saturdays, Sundays and holidays from Easter weekend through Memorial Day weekend and on weekdays and weekends from Memorial Day weekend through Labor Day, unless exempt by city manager. Fees are designated for the restoration and improve ment of Prince Solms Park East No through commercial truck traffic except Light trucks including any truck with a manufacturer's rated carrying capacity not to exceed 2,000 pounds and including those trucks commonly known as pickup trucks, panel delivery trucks, vans and carryall trucks shall be excluded from the provisions of this section. Recreational vehicles and passenger buses shall be excluded from the provisions o f this subsection. Any truck which has a destination point, for commercial purposes, within Landa Park or Hinman Island Park shall be permitted to proceed by the shortest route through such parks to its destination, and shall exit by the same route. Maximum weight limits for bridges in Landa Park: (1) Bridge on Landa Park Drive at the Comal River and Landa Railroad Train Depot, TxDOT location number 15 046 8403 15 004, shall have a maximum safe load limit of 12,500 pounds, axle or tandem; (2) B ridge in Landa Park at the main spring flow from Panther Canyon area nearest the wading p ool, TxDOT location number 15 046 8403 15 003, shall have a maximum safe load limit of 24,000 pounds tandem; (3) Arched bridge on Landa Park Drive at the Comal River Springs closest to California Street, TxDOT location number 15 046 840315002, shall hav e a maximum safe load limit of 24,000 pounds tandem.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 15 (NB) Section 86 8 Glass containers prohibited in park areas and on rivers, lakes and streams ( Ordinance No. 2005 62) It is a misdemeanor offense to be carrying, using and/or disposing of glass beverage containers in all city parks adjacent rivers, lakes and streams Cross reference — Waterways, ch. 142. (NB) Section 86 10. Prohibition of alcoholic beverages in city parks and city owned property (Ord. No. 2007 12, 1, 2 12 07; Ord. No. 2008 11, 1, 1 28 08) ( a)It shall be unlawful for anyone to consume liquor or any alcoholic beverage, or possess an open container of intoxicating liquor or alcoholic beverage within the boundaries of the following public parks or city owned property within the city limits: (1) Prince Solms Park; (2)Hinman Island Park; (3)Cypress Bend Park; (4)The City owned tuber exit on the Comal River that borders Lincoln Street and Union Avenue. (5)River Acres Park; (6)H.E.B. Soccer Park; (7)Jesse Garcia Park; (8)Ernest Eikel Field; (9)Haymarket Park; (10)Torrey Park; (11)Kraft Park; (12)Northridge Park; (13)Dry Comal Trails; (14)Solms Park; and (15)Fredericksburg Sports Complex. (b)It shall be unlawful for anyone to consume intoxicating liquor or any alcoholic beverage, or possess an open con tainer of intoxicating liquor or alcoholic beverage in all designated parking areas or within 25 feet, either side of any roadway, within the boundaries of the following public parks or city owned property within the city limits: (1)Landa Park; (2)Camp Co mal. City permitted functions are exempt. Fine $500 (NB) Section 8611. N oise restrictions in city parks (Code 1961, 14A 10.1; Ord. No. 2006 53, II , 6 26 06) Unlawful between the hours of 10:00 p.m. and 8:00 a.m.: (1) Operating of any radio receiving set, tape player, cassette tape player, compact disc player, DVD player, MP3 player, musical instrument, television, phonograph, drum or other machine or device for the production or reproduction of sound. (2)Operating or permitting to be operated any loudspeaker or sound amplifying equipment. It shall be unlawful and considered a misdemeanor offense for any person to play musical instruments or provide live music any time within the boundaries of all city parks within the city limit. City park events exempt.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 16 Violations may result in fines $100 $500 (NB) Section 86 13 – Prohibition of use of fo am, polypropylene, expanded polypropylene and polystyrene in certain public waters ( Ord. No. 9436, ss I ) It is unlawful to use, carry, possess or dispose of any of above referenced on or in the public waters of the portions of Guadalupe River, Lake Dunla p and Comal River with exception of Foam for boat flotation devices when enclosed within the structural framework of the boat or are fully encapsulated by a water based acrylic coating Foam minnow buckets which meet or exceed a 2 lb density Foam dock supp orts fully encapsulated in a water based latex coating (NB) Section 86 14 – Coolers that are allowed on rivers, lakes and streams Cooler size is limited to maximum 16 quarts, must be able to be securely fastened as to prevent contents from falling out cannot be Styrofoam. Only one cooler per person is permitted on Guadalupe and Comal Rivers. No containers constructed of Styrofoam or glass are permitted on or in the public waters of Guadalupe and Comal Rivers. It is unlawful to dispose of any container into the waters or banks of the Guadalupe or Comal River unless it is an authorized and placed trash receptacle. No open containers with capacity of 5 oz or less permitted on Guadalupe, Comal Rivers and Lake Dunlap. (NB) Section 86 15 – Use of life jackets o n rivers Young children and individuals who cannot swim or are poor swimmers are recommended to wear life jackets on the Comal River. Outfitters shall provide information to customers concerning recommendations and requirements for life jackets (NB) Secti on 86 14 – Coolers that are allowed on rivers, lakes and streams Coolers: not to exceed 16 quarts, must be secured by zipper, Velcro snap, mechanical latch or bungee cord to prevent contents from falling out cannot be Styrofoam Only one cooler per person is permitted on Guadalupe and Comal Rivers No containers constructed of Styrofoam or glass are permitted on or in the public waters of Guadalupe and Comal Rivers It is unlawful to dispose of any container into the waters or banks of the Guadalupe or Comal river unless it is an authorized and placed trash receptacle No open containers with capacity of 5 oz or less permitted on Guadalupe, Comal Rivers and Lake Dunlap

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 17 (NB) Section 86 16 – Rivers, flotation devices, Ord. No. 2007 20, ss II It is unlawful to float the Guadalupe or Comal Rivers except by canoe, kayak, boat or raft (including inflatable vessels), not exceeding 18’ length. Sat, Sun and holidays: Persons floating on such vessels are not permitted to exit ‘last tubers’ exit adjacent to Garden St. and Union Ave. between May 1 and October 1. Rafts (non inflatable structures used to transport 2 or more) are not permitted on the Comal River. On the Comal River, inflatable devices are limited to 2 person capacity and cannot be greater than 5’ diameter (or have any length of the vessel greater than 5’). (NB) Section 86 100 Requirements for rental of water oriented recreational equipment ( Ord. No. 0122. ss II ) There shall be a written record of (name, DOB, address) all those renting wateroriented equipm ent (NB) Section 86 101 – Wristband; public exits, City Tube Chute, Prince Solms Park, Hinman Island Park. ( Ord. No. 0122, ssII ) All persons on these city premises in possession of water oriented rented equipment or using the public exits on the Comal or Guadalupe rivers between Apr 1 and Oct 1 shall wear a city approved wristband (NB) Sec tion 86 117. Public river exits (Ord. No. 0132, II, 5 14 01; Ord. No. 2008 29, III, 4 14 08) Each water oriented recreation equipment rental customer is required to remit $1.25 river management fee to the city for us of any public river exit unless this fee has already been included as a shuttle passenger fee; this river management fee is valid only for the date that it is coll ected. (NB) Section 86 118 – Water recreation shuttles (Ord. No. 0132, III, 5 14 01; Ord. No. 2008 29, IV, 414 08) Water recreation shuttle permit holders collect and remit to the city $1.25 river management fee for each shuttle passenger transported to the city, unless the fee has already been collected as part of the water oriented recreation equipment rental; this fee is valid only for the date it is collected.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 18 (NB) Section 86 119 – Fee payment; reports (Ord. No. 0132, IV, 5 14 01; Ord. No. 2008 29, V, 4 14 08) River management fees are required to be recorded and reported to the city monthly between April 1st and November 1st of each year. Reports are to include, numerical counts for each day, total counts for the month and a calculation of fees based on $1.25 per person. This revenue is directly allocated to the city management of the river. (NB) Section 86 120 – Penalty River management fees are required to be submitted to the city within 15 days of the following calendar month; the penalty for failure to comply is a suspension of the water recreation shuttle permit and use of the public river exits. (NB) Sec. 126 334. Trailers, time limit (Code 1961, 23 140) Trailers or semitrailers may not be parked or left standing on a public street for one continuous period of more than 30 minutes without authority from the chief of police (NB) Sec. 126 346. Stopping, standing or parking prohibited in specified places (Code 1961, 23 127; Ord. No. 93 15, 1, 2, 4 12 93; Ord. No. 949, I, 2 28 94; Ord. No. 9415, I, 4 2594; Ord. No. 94 34, I, 8 2294; Ord. No. 9622, I, 4 -896; Ord. No. 97 40, I, 11 24 97; Ord. No. 98 19, I, 7 27 98; Ord. No. 9828, I, 10 26 98; Ord. No. 99 10, I, 222 99; Ord. No. 9927, I, 4 26 99; Ord. No. 9940, 6 2899; Ord. No. 9945, I, 7 12 99; Ord. No. 9968, I, 1025 99; Ord. No. 00 09, I, 228 00; Ord. No. 2000 44, I, 11 13 00; Ord. No 2000 54, I, 11 13 00; Ord. No. 0125, I, 4 -901; Ord. No . 200139, I, 8 13 01; Ord. No. 2001 62, I, 12 10 01; Ord. No. 200213, 1, 4 -802; Ord. No. 2002 47, I, 12 -902; Ord. No. 2003 37, I, 5 27 03; Ord. No. 2003 69, I, 10 13 03; Ord. No. 2004 18, I, 3 -804; Ord. No. 200436, I, 5 10 04; Ord. No . 200441, I, 6 14 04; Ord. No. 2005 51, I, 613 05; Ord. No. 2005 83, I, 112805; Ord. No. 2005 84, I, 11 28 05; Ord. No. 2006 04, I, 1 23 06; Ord. No. 2006 19, I, 2 27 06; Ord. No. 200627, I, 4 10 06; Ord. No. 2006 39, I, 5 -806; Ord. No. 2007 40, I, 5 29 07; Ord. No. 2008 14, I, 12808; Ord. No. 2008 25, I, 3 24 08; Ord. No. 200872, I, 11 10 08; Ord. No. 2008 75, I, 12-808; Ord. No. 2009 06, I, 2 -909; Ord. No. 2009 42, I, 727 09) Pedestrians shall not stand nor stop in vehicular areas that will put them in conflict with other traffic . There is no parking permitted on many of the streets and intersections near and surrounding public access points to the river: streets surrounding Landa Park, Hinman Island, Prince Solm s Park and the public tuber exits at Garden Street and Union Avenue. Some locations are restrictive only from 8am to 8pm and from May 1st to September 15th. Other locations are restrictive between 7am and 8pm weekends and holidays from Easter weekend throu gh to Labor Day weekend.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 19 (NB) Sec tion 126 368. Fifteen minute parking on Lincoln Street (Code 1961, 23 136.1; Ord. No. 2000 46, I, 11 27 00; Ord. No. 0125, III, 4 -901; Ord. No. 2001 39, II, 8 1301; Ord. No. 2003 32, I, 512 03; Ord. No. 2004 39, I, 6 1404; Ord. No. 2006 92, I, 9 25 06; Ord. No. 2009 05, I, 2-909; Ord. No. 2009 42, I, 727 09) No parking is permitted on the southeast curb of Lincoln Street at Union Ave. for a distance of 710 feet west. No parking for more than 15 minutes is permitted on the north side of Lincoln from 600 feet west of Union for a distance of 100 feet between 8am and 8pm weekends and holidays from Memorial Day through Labor Day On certain parts of Liebsher Drive, parking is restricted to water recreation shuttle vehicles (by permit) from 7am – 8pm April 1st to October 31st; these areas are loading zones for such permitted vehicles and are restricted to 15 minutes. A 15 minutes loading zone is designated for water rec reation shuttles on parts of Lincoln Street near Union Avenue, and on Union Avenue near Lincoln Street. There is no parking on Common Street near Liberty Avenue other than for water recreation shuttles for the purposes of loading and unloading. Same for Liberty Avenue near the near W. South Street. (NB) Part II Chapter 138 – Vehicles for Hire Article VI – Water Recreation Shuttle Services Commercial shuttle operators used for water recreation require an annual permit from the c ity. The number of seats permitted for the Comal River is limited to 1,205 annually, whereas it is unlimited for the Guadalupe River. By Ordinance, shuttle entry and exit points for the Comal River are restricted to city property: Shuttle Zone at Prince So lms Park Garden Street and Union Avenue tubing exits (NB) Section 138 2 – Annual permit required (Ord. No. 0110, I, 2 12 01) An operating permit from the city authorizing transport of passengers for compensation from a point within the city is requir ed. (NB) Section 138 3 – Transferability of operating permit (Ord. No. 01 10, I, 212 01) Operating permits are not transferrable unless approved in writing by the city manager or his designee. Transfers may be made to different operators after all ordinance requirements are met and a fee of $75 collected by the city secretary for administering permit records .

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 20 (NB) Sec tion 138 4. A pplication for operat ing permit (Ord. No. 0110, I, 2 12 01) Applications for a taxicab permit are filed with the city secretary and must be filed before December of each calendar year with the following information: owner(s), address, telephone, make, hp, vehicle identific ation number, seating capacity, license number of every vehicle to be used for service, evidence of insurance, names, addresses, dates of birth and DL#’s of each driver operating vehicles for the company, schedule of rates, statement that no felony convict ions or other offense involving moral turpitude exist which adversely affects the applicant's ability to provide safe and reliable passenger transportation , history of any revocation or suspension of like permits. A fee of $75 plus $10 for each vehicle is collected. (NB) Sec tion 138 5. Issuance of pe rmit (Ord. No. 0110, I, 2 12 01) Upon written proof of insurance and determination all documents for application are met, a permit is issued for period of January 1 to December 31 (NB) Section 138 167 permit ( Code 1961, ss 25 71; Ord. No. 0117, ss I, Ord. No. 2005 12, ss I, Ord. No. 2005 30, ss1, Ord. No. 2008 35, ss II ) Guadalupe and Comal River permits are required for operating water recreation vehicles Limited shuttle zones for Guadalupe River Guadalupe River Shuttle seats are annually unlimited Limit of 1,205 Shuttle seats permitted annually for Comal River (NB) Section 138 170 – shuttle entry/ exit points ( Code 1961, ss 25 74; Ord. No. 0122, ss IX; Ord. No. 01 32, ss VI; Ord. No. 2005 12, ss I; Ord. No. 2005 30, ss I; Ord. No. 2008 29, ss VII ) Comal River entry and exit points on city property : Shuttle zone at Prince Solms Park Union Street tub ing exit Guadalupe River exit point on city property: Public river exit at Cypress Bend Park (NB) Part II Chapter 142 – Waterways (NB) Section 142 2 – powers of city concerning water bodies; responsibilities of property owners ( Code 1961, ss4 4, Ord. No. 0124,ss I ) the city shall have the power to alter or improve any water body within its limits; no owner of property fronting any river within city limits shall alter any

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 21 body of water without first obtaining and permit and without the approval of the ci ty engineer. (NB) Section 142 3 – Comal River; Guadalupe River ( Code 1961, ss4 2,4 2.1(a),(b)) Rafts, boats or floats are not permitted beyond speed limit of 5 mph on any portion of the Comal River and on the Guadalupe River: between Textile Mill Dam and where the G River meets the city limits (excludes law enforcement and public safety agencies) Horsepower of motor; exception On Comal River: no motors rated in excess of 10 hp This does not apply to any existing franchise, concession, lease or license to operate any boat, float or raft on the Comal. (NB) Section 142 4 – Methods of fishing ( Code 1961,ss4 -3) Fishing is lawful only by pole & line, casting rod and reel, artificial bait, trotline or set line; seines may be permitted in accordance with state laws or parks and wildlife commission regulations (NB) Section 142 5Control of aquatic activities on Mill Race (Comal Channel) ( Code 1961,ss 4 -5) It is an offense to enter or engage in any aquatic activity between Landa Park Lake and the confluence with the Comal River (dry Comal Crk) It is unlawful to launch in water vessel or flotation device on any portion of the same This does not apply to law enforcement and public safety agencies (NB) Section 144 5.12 Bowling alleys, dance halls, shooting galleries, s hooting ranges, skating rinks, commercial or public tuber entrance or take out facilities, and similar commercial recreation buildings or activities ( Ord. No. 2006 99, ss 1 (exh. A) ) No commercial or public tuber entrance or take out facility shall be deve loped without a special use permit

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 22 B. City of San Marcos Recreation activity on the San Marcos River predominantly occurs along city owned parkland, however, there is also privately owned property where recreation is permitted within their zoning so long as development of recreation within the floodplain is in accordance with the municipal code. These development ordinances , and those that relate directly to activities on and in the water aim to protect the water ways (biological diversity, natural and traditional character) and water quality are reported. All these related ordinances found for the City of San Marcos are reported . Ordinances that pertain specifically to recreation activities include: ordinances pertaining to parks adjacent the San Marcos River: curfew, hunting, fishing, camping, disruptive conduct, restriction of motorized v ehicles on trails, possession of alcohol, horseback riding restrictions Ordinances that pertain specifically to activities of the river include: prohibition of glass Release of any organisms into the waters Washing of bodies, pets and personal items are prohibited Restriction of activities in Spring Lake Prohibition of speargun use Jumping into the river from bridges is prohibited Restrictions regarding operation of river shuttles: including parking allowances and franchise application detailing routes, stops, seating capacity, parking allowanc es, documentation of revenue (SM) Chapter 58 Public Facilities, Parks and Recreation Article 3 Water Activities (SM) Section 58.029 Night curfew in city parks 11pm – 6am (SM) Section 58.030 Disruptive conduct It is unlawful to remove, destroy, deface, tamper with or disturb any artifact, or cultural feature to take, remove, disturb any rock, soil, gem mineral except by permit. It is unlawful to mutilate, injure, destroy, pick, cut or remove and any plant life except by permit

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 23 (SM) Section 58.032 Motor vehicles It is unlawful to drive a motor vehicle in a city park area that is not an improved roadway or park in area not designate for such No motors on trails or bike paths Abandoning, storing or leaving a vehicle, boat, trailer or other personal property beyond park facility hours if not permitted (SM) Section 58. 033 Possession of alcoholic beverages in certain parks It is unlawful to possess any alcoholic beverage within 500’ of a softball or baseball field, within a children’s park, within a fenced area surrounding a city swimming pool (SM) Section 58.034 Glass beverage containers are prohibited In any city park In or on the waters of the San Marcos River (SM) Section 58.037 Hunting, fishing and camping in city parks It is unlawful to hunt, harm, harass, disturb trap, confine, catch, possess or remove wildlife from or in city parks To release any fish, bait fish, plant or other aquatic organism into the waters of a city park Fish, grapple or catch and release in an area where fishing is prohibited by sign No fires unless designated otherwise No wood gathering No camping unless otherwise designated No washing of bodies, clothing, pets or other personal belongings in drinking fountains, pools, sprinklers, reservoirs, lake, river or any other water body in a park No depositing wastewater, sewage or effluent from sin ks, toilets or other plu mb ing fixtures onto grounds or waters of a city park (SM) Section 58.040 animals No riding, driving, leading or saddling of horses without a permit in a city park unless designated a horseback riding trail (SM) Section 58.067 Usin g public waters of Spring Lake Restrict uses to: Sightseeing, excursion boats, archaeological and scientific projects

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 24 (SM) Section 58.068 Possessing of or shooting spearguns in San Marcos River It is unlawful to possess or shoot a speargun while in or up on the San Marcos River (SM) Section 58.069 Activities on bridges crossing San Marcos River It is unlawful to jump or dive into San Marcos River from any bridge crossing the river (SM) Section 58.072 Bridge construction over river; prohibited entry ; warning signs During periods of construction over the San Marcos River, city manager may prohibit entry of persons within or along the San Marcos River into the areas, unless contracted to work in the area (SM) Chapter 90 Article 5 River Shuttles Division 1. Generally (SM) Section 90.3903 Restrictions to operation Written approval of routes and stops, dates and times from city manager (‘s office) (SM) Section 90.310 Franchise required and application Application to include seating capacity, maps detailing routes, dates of operation, parking allowances for customers, statement of gross revenues generated from river related activities for the previous year, a comprehensive description of type and nature of business (SM) Section 90.313 Fees Annual franchise fee valid May 1 – Apr 30 (SM) Chapter 5 – Environment al Regulations (SM) Section 5.1.1.2 Erosion Control Standards Preserve natural drainage patterns whenever possible Limit loss of pervious character of soil Utilize open surface drainage through grass lined swales Located stormwater runoff to avoid sinkholes, fractures, faults Channelizing stormwater permitted by Engineering Director Dissipate point discharges in sheet flow Minimize erosion impacts of runoff an d control contaminants with sediment contr ol devices

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 25 Vegetate detention ponds Provide internal rock berm baffles in ponds Trap floating matter in ponds Provide maintenance access to ponds (SM) Section 5.1.1.3 Runoff Attenuation Utilize strategies for energy dissipation, sediment and pollutant traps Detention required to maintain runoff rates at pre development levels (SM) Section 5.1.1.4 Wastewater collection and Disposal Not permitted in water quality corridors: septic tanks, holding tanks, evapotranspiration units, cesspools or other sewage dis posal systems (SM) Section 5.1.1.5 Impervious Cover Limitations A p ercentage is permitted and varies with grade/slope of hillside (SM) Section 5.1.1.6 Street and Drainage Improvements Must be designed to 25 year frequency rainfall Drainage improvement costs at sole responsibility of property owner Drainage improvements serving multiple developments shall be dedicated to the public (in an easement that contains all storm water flows to the limits of the 100 year floo d plain; drainage improvements serving st reets or other public property may dedicated in a public street ROW rather than a drainage easement); Easements must be 25’5” in width for open drainage systems or 15’ width for enclosed Maintenance of drainage easement corresponds with ownership (SM) Se ction 5.1.1.7 BMP Improvements Maintenance Criteria Holder of an approved watershed protection plan is required to maintain any required permanent BMP’s after construction; submit an annual maintenance report to Engineering Director (SM) Section 5.1.1.8 C ontinuing Responsibilities Passes on with any transfer of property (SM) Div.2 Stream and River Corridor Water Quality Standards (SM) Section 5.1.2.1 Purpose, Applicability and Exceptions To protect water quality and prevent flood damage, applies to SMRC and Edwards Aquifer recharge zone, exception is a drainage basin of less than 120 acres upstream from development

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 26 (SM) Section 5.1.2.2 Water Quality Zones FEMA mapped waterway & for each stream, river or waterway in SMRC and Edwards Aquifer Recharge zone : 50’ extending out from each side of CL of minor waterway, 100’ extending out on each side of the CL of intermediate waterway or 100 yr flooplain resulting from full developed conditions in the watershed Required when a plat is required for development ( SM) Section 5.1.2.3 Buffer zones = 100’ width measured from the outer boundary of the water quality zone, buffer and WQZ not to exceed width of 100 yr floodplain (SM) Section 5.1.2.4 Impervious Cover Limitations Not permitted in a water quality zone Permi tted within a buffer zone, dependent on gradients Exceptions permitted where access (vehicular) across waterway is limited (SM) Section 5.1.2.5 Clustering and Development Transfers Clustering of residential density and impervious cover allowed in accordan ce with Table 5.1.16.1, when approved under a cluster development plan (SM) Section 5.1.2.6 Performance Standards in Water Quality and Buffer Zones Shall be stabilized with 70% vegetation/ground cover; areas disturbed shall be restored Sheet flow point di scharges No fertilizers nor pesticides permitted within water quality zones Limitations on excavation and fill (see Article 4, Div. 2 Chapt 5) (SM) Art 3: Development Related to the San Marcos River Corridor Div. 1: General Provisions (SM) Section 5.3.1.1 (a)(6) corridor is facing potential for intense development (10) city Mgr has directed staff to conduct a study of characteristics of the corridor, adverse impact of development activities and how to mitigate (b) (1) prevent stripping of native vegetat ion (2) prevent soil erosion and sedimentation (3) prevent increase in stormwater runoff (4) prevent or reduce pollution concentrations (5) protect biological integrity of SMR habitat (6) preserve natural and traditional character of the land and wate rway

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 27 Map of areas located at City Clerk’s Office (d) (1) additional requirements of this article shall not apply to SF detached residence on a properly platted subdivision lot that has been properly platted before the effective date of the ordinance (SM) Div.2 Development Standards (SM) Section 5.3.2.1 Ecological Preservation Restoration of disturbed areas containing native plants shall be approved by Engineering Director. Stabilization of eroding creek banks is permitted to protect threatened property, as approved by federal and state agencies and the Engineering Director. Excavating or filling permitted as necessary for structural engineering for a building or structure. (SM) Section 5.3.2.2 Water Quality Standards Impervious cover not permitted except for trails for walking, running and non motorized biking or for access to another public road (within distance limitations of other crossings) Disposal of contaminants must be approved by Engineering Director and in accordance with the Contaminant Removal Guidelines of the City Input and release from water quality basins shall utilize grass lined swales and /or overland dispersion measures. (SM) Section 5.3.2.3 Overland Flow and Natural Drainage Lim i t to prevent erosion and attenuate impact of contaminant s transported by flow Open surface drainage via grass lined swales preferred (leave in undeveloped or natural state for runoff to occur); use of streets as central drainage network is prohibited Storm Sewers Enclosed and impervious channels by permission o f Engineering Director (SM) Section 5.3.2.4 Velocity Attenuation and Surface Drainage Channels Channelization of San Marcos and Blanco Rivers and any tributary of the SMR within the SMRC is prohibited (SM) Section 5.3.2.5 Creation of Impervious Cover P ermitted outside water quality zone, % varies with various slopes

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 28 III. GIS DATABASE PREPARATION Section 1. Data Collection Recreation use data provided during stakeholder interviews , as described in Section IV, was collected and mapped for the San Marcos River in San Marcos, Texas and the Comal River in New Braunfels, Texas. The San Marcos River study area extends from Spring Lake downstream to the San Marcos City Limit. The Comal River Study area extends from Landa Park to the confluence with the Gu adalupe River. The following data sets were obtained for use in delineation of recreation uses on the Comal River and the San Marcos River. Halff coordinated with the Capital Area Council of Governments (CAPCOG), the City of San Marcos, the City of New Braunfels, Texas Water Development Board (TWDB), Texas Commission o n Environmental Quality (TCEQ), and the United States Geological Survey (USGS) to gather available data . The following is a summary of data obtained for the purpose of executing this study effort. CAPCOG Aerial Imagery, 0.5 meter resolution, February 2008 National Hydrography Dataset (NHD) Streams and water bodies, USGS San Marcos City Parks, City of San Marcos TNRIS Stratmap (TWDB) Parks, Roads, and City Limits TCEQ Clean Rivers Water Q uality Stations The Comal County Regional Habitat Conservation Plan Environmental Impact Statement (Draft) was also referenced to delineate areas of potential wildlife habitat of protected species within the study area. In addition to the basemap data collected as described above, Halff Associates conducted two days of stakeholder meetings to collect recreation use information as discussed in Section I, IV, V, and VI. Recreational activities identified in these meetin gs are listed in Table 4.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 29 A limited amount of t emporal use data was provided during stakeholder interviews, as described in Section IV. The temporal use data that was collected was presented in terms of intensity , not n umerical value s. Based upon the d ata gathered during stakeh older interviews, temporal use dat a was grouped into four c ategories of intensity : high, mediu m, low, and unknown to best describe the intensity of use occurring at the recreation area. Based on the limited data available at this time, no temporal patterns of use intensity were indentified. However, the GIS geo database attribute table wa s prepared such that any future d ata may be added to the database and analyzed. Entrance and exit locations were also identified and de lineat ed from interviews and surveys. Locations shown are those described by stakeholders during interviews and do not necessarily repres ent all points of access. Critical habitat areas for the species, as discussed in Section VI, have also been de lineat ed . Tubing, kayak, canoe, and paddleboat vendors were identified from interviews, surveys, and internet data search es . Prepar ation of the data is discussed in Section 2. Section 2. GIS Database Preparation Recreation al areas were delineated using ArcGIS version 9.3.1. A file geodatabase feature class was set up with the attribute fields listed in Table 5. Metadata for the Recreation_Area feature is summarized below: File Geodatabase: EARIP_Recreation.gdb Feature Datas et: EARIP_Recreation Feature : Recreation_Area

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 30 -+ Coordinate System: NAD 1983 State Plane Texas South Central 420 4 Projection: Lambert Conformal Conical Geographic Coordinate System: GCS North American 1983 Horizontal Datum: North American 1983 The recreation areas were delineated for each type of use reported. The reported recreation areas can be queried and symbolized by activity. Areas reported as specific entry and exit areas are identified in the ENTRY_EXIT field. Additional fields were also inc luded to identify the intensity of use and if the area is for public or private use. These attributes can be updated if information becomes available. Section 3. Associated Exhibits The attached exhibits illustrate recreation areas and areas of potential wildlife habitat of protected species. Table 6 summarizes the se exhibits. They are grouped by city and further arranged by type of area. Table 6 Exhibit Index Exhibit # Title Description New Braunfels Recreation Areas NB.1 Tubing Identifies areas where tubing occurs in the Comal River. NB.2 Paddle Boats Identifies areas where paddle boats are used in the Comal River. NB.3 Picnic Areas, RV Campground Id entifies areas along the banks of the Comal River where picnic areas and RV Campgrounds occur. NB.4 Swift Water Rescue Training Identifies t he area where swift water rescue training occurs in the Comal River. NB.5 Swimming Identifies areas in the Comal River where swimming occurs.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 31 Table 6 continued NB.6 Tube, Paddle Boat, Kayak, Canoe Rentals Illustrates the locations of rentals categoriz ed by tube rental and paddle boat, kayak, and canoe rentals near the Comal River in the City of New Braunfels. NB.7 Fishing Identifies areas of fishing along the banks and in the Comal River NB.8 Wading, Lounging, Playing, Rope Swing Identifies areas where wading occur in the Comal River and the locations of lounging, playing, and rope swing use occur along the banks. NB.9 All Uses Summarizes all of the identified recreation uses along and i n the Comal River, all entry/exit areas, and the storm water quality stations. New Braunfels Potential Wildlife Habitat Areas NB.10 Comal Springs Dryopid Beetle, Peck's Cave Amphipod Illustrates areas of potential wildlife habitat. NB.11 Comal Springs R iffle Beetle Illustrates areas of potential wildlife habitat. NB.12 Fountain Darter Illustrates areas of potential wildlife habitat. San Marcos Recreation Areas Exhibit # Title Description SM.1 Dog Parks Tubing Identifies areas where tubing occurs in the San Marcos River. SM.2 Fishing Identifies areas of fishing along the banks and in the San Marcos River. SM.3 Kayaking, Canoeing Identifies areas where kayaking and canoeing occur in the San Marcos River. SM.4 Picnic Area Identifies areas along the banks of t he San Marcos River where picnicking occurs.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 32 Table 6 continued SM.5 Swimming Identifies areas in the San Marcos River where swimming occurs. SM.6 Tube, Kayak, Canoe Rental Locations Illustrates the locations of rentals categorized by tube rental and kayak and canoe rental s near the San Marcos River in the City of San Marcos. SM.7 Tubing Dog Parks Illustrates three locations where dogs are allowed. SM.8 Wading, Lounging Identifies areas where wading occur in th e San Marcos River and the location of lounging along the banks. SM.9 All Uses Summarizes all of the identified recreation uses along and in the San Marcos River, all entry/exit areas, and the storm water quality stations. San Marcos Potential Wildlife H abitat Areas SM.10 Fountain Darter Illustrates areas of potential wildlife habitat. SM.11 San Marcos Gambusia Illustrates areas of potential wildlife habitat. SM.12 San Marcos Salamander, Texas Blind Salamander, Comal Springs Riffle Beetle Illustrates areas of potential wildlife habitat. SM.13 Texas Wild rice Illustrates areas of potential wildlife habitat.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 33 IV. STAKEHOLDER INTERVIEWS Stakeholder interviews were conducted June 29th and 30th 2010. The lists of interviewees were provided by EAR IP representatives and city staff in both cities. A questionnaire was provided to all individuals in advance of the interviews. Stakeholders from San Marcos and New Braunfels were comprised of city representatives, river committee members, active river us ers and commercial operators. T wenty two (22) stakeholders from San Marcos were sent questionnaires and invited to be interviewed . E leven responded, and t en (10 ) attended the interview a nd answered the questionnaire . O ne(1) submitt ed the questionnaire but did not attend the interview . Thirteen (13) stakeholders from New Braunfels were invited to be inter viewed and sent a questionnaire . N ine (9) responde d and seven (7) attended the interview and answered the questionnaire . T wo (2) submitted the questionnaire but did not attend the interview. Interviews were conducted by two members of the Halff team and interviewees were scheduled individually or as part of group of not more than three ( 3 ) at 30 minute intervals . Questionnaires and maps were made availa ble at the interviews and participants were given the op tion to respond to the questionnaire during the interview or provide them via email following our dates. The list of questions not only aimed to obtain information directly regarding recreation activity but also peripherally and indirectly to identify potential impacts recreation activities have on the cities , be they economic, operational or physical. N ot all individuals provided an answer to every question and answers provided may be based on the perce ptioins of the stakeholder and not necessarily factual data. (See Appendices B and C for specific responses) Responses c ommon to both cities include : P eak use occurs between Memorial Day weekend and Labor Day During this period, weekends and holiday long weekends have the highest use numbers occur between 11am and 4 pm T he most highly used areas of these springs are along city owned par ks that run adjacent the rivers. D uring high use periods , parking is an issue for both these cities and the current rate of use of these rivers is having a degrading e ffect on the se surrounding parks L itter is a constant maintenance issue

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 34 D espite the crowds an d trash, these rivers are highly valued for the economic opportunities, and social as well as health benefits they provide to their respective communities. A. New Braunfels Stakeholders from New Braunfels hold their rivers in high regard f or the quality of life they provide and as an economic resource. Based on a 2009 economic study commissioned by the City of New Braunfels , tourism contributed $469.7 million in revenue for the area. There is no definitive study or tracking methodology in place to determine how many people use the river as a recreational resource as it is an open s ource of recreation without fee. While one respondent perceived between 3000 5000 people per typical weekend during the peak season used the river, another thought there might be three times this many . Prime activities are tubing and picnicking in the peak season. Hinman Island and the Tube Chute at Prince Solms Park seem to draw the most crowds as they are consid ered both launch and exit points, but also the surrounding parks offer plenty of free space for picnickers. Although there is a perception that the parks are overcrowded and the amount of users are negatively impacting the condition of the parks, the re is also the feeling that there is a reasonable amount of control on number of (tube) users on the river, as it is monitored by the river manager and commercial (tube) outfitters , who have learned to work together to prevent congestion on the river. The river manager has the authority to prohibit use of the river if he feels there is such numbers to cause safety concerns. The use of water recreation shuttles is common in New Braunfels. Stakeholders estim ated that 50 70% of all tubers use this service . S huttl es provide service to satellite parking lots as well as tuber pick up and drop off points along the river. In the off season, the river is used for swift water rescue training by fire departments from all over Central Texas and beyond. New Braunfels has ordinances in place to minimize the amount of trash, reduce potential for misconduct on the river as well as protect the users of the river, but some offer that though these are admirable, people find a way around every rule and that ther e is inadequate enforcement to enforce the rules that exist. The issue of alcohol consumption is an ongoing contentious issue. Alcohol is not permitted to be consumed in public parks, however, once in the water,

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 35 standing or floating, consumption cannot be regulated as the river is within the S tate’s jurisdiction. The consumption of alcohol is often enjoyed with recreation on the river; however, many stakeholders commented that they felt it also contributed to altercations and unfavorable public beha vior. Although not ranked by priority, t he following table illustrates number of respondents who identified specific issues.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 36 New Braunfels Stakeholder Interview Responses June 30, 2010 1. Wha t are the peak times of recreation use: days, seasons, months, holidays, hours? Memorial Day – Labor Day Weekends / Long weekends, more Saturday than Sunday Afternoon hours (11am 4pm) a) How many people are using the river at these times? Comal: 3 , 000 -5, 000 (per typ. Peak season weekend) Uknown because there is no entry fee Estimate: 187,000/yr on both rivers over approx. 110 days = approx 1700 people/day b) What areas of the river see the highest amount of use? @ Tube Chute Hinman Island to Last Tubers Exit (@ Union) 2. Should there be restrictions on times of use or hours of use? Yes, to daylight hours only, as safety factor 3. Does use have any correlation with water flow or river levels? No, Comal springs brings constant flow Perception of flooding events around central Texas reduces #’s 4. Can recreational activities on the river continue at current levels of activity? Mixed response, see below a) Why or why not? Yes because recreational outfitters are active about controlling their rate of users Yes, because habitats are surviving and thriving No because parks where people access are free and are over capacity now 5. If arriving at the river by vehicle, where do people park (private lots, owned by recreation outfitters or other private lots? Street? Public pa rk?). City: Public parks, public owned lots, streets Private businesses (satellite lots) a) Do the majority of recreational users use commercial shuttle buses and are those desirable? 50% 70% of tubers use shuttle b) How many people (or what percentage of people) arrive at river tubing/raft launch locations by private vehicle versus shuttle bus? 60% private 40% shuttle

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 37 c) Is one method of arrival preferable over the other? Shuttle is preferred 6. Do most users access / launch from public/city owned property or pr ivate property? Public:City Parks a) Plea se list all known points of access and launching . Hinman Island Tubers Chute (Prince Solms) Wurst Fest (Landa Falls) Texas Tubes Resort properties on the Comal 7. Do most users exit the river at public/city owned property or private property? 70% exit on public a) Please list all known points of exit . Last tubers/public exit (@Union) Garden St. Resort Properties Rock’n R 8. What recreational activities other than tubing, rafting and fishing occur along the river? Rop e swinging Camping scuba Wading/water play /water lounging/ drinking/sunbathing grilling/picnicking swimming fire dept. swift water rescue training nefarious activity 9. What specific locations are most frequented by these other users? Tube Chute Hinman Island Landa Park Wurstfest 10. What are the positive aspects of recreation on the river? Economic: tourism $, Jobs for young people Education about the river Outdoor enjoyment: mental, physical health

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 38 11. What are the negative aspects of recreation on the river? T rash Negative behavior (3 5% of users cause trouble, of which half are local) Wear on the landscape 12. How important are river based recreational activities to the local economy? Extremely as it is the ‘brand’ of New Braunfels; impacts everything, not just water related activities a) What are its contributions: i.e. sales tax, property taxes, other taxes/fees, spinoff businesses (related revenue sources for the city)? Employment & wages City & other local taxes from hospitality industry b) How much does recreation activity contribute to the local economy? (in $ or % of city revenue) $12 million annually in tax revenue (response closely approximated what was reported by Impact Data Source, 2009) $469.7 million in 2009 (response closely approximated what was reported by Impact Data Source, 2009) 13. What is your perception of the level of enforcement on the river? Too much, not enough? Why? Good, sometimes excessive 1 4. Is the amount of regulation with regards to activities on the river acceptable? Should there be more? Or less? Less a) Are there certain things that should be regulated that aren’t currently? Alcohol on the river Access points aren’t managed/controlled Pop up tents and crowding at access points b) Are there certain things that are currently regulated that shouldn’t be? No other than: number of coolers per tube and size of ice cooler 15. What is your perception of the level of maintenance? Too much, not enough? Why? Ok, Acceptable 16. Are there operational issues with regards to emergency flood situations? None

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 39 Additional Notes: Tubers: 50% rent, 50% bring their own The amount of negative behavior associated with river activity is within normal range of any ‘open source, no price point activity’; placing a $ value on the activity would make a difference NBU has a wastewater facility that has flooded 3x in the last 12 years: contamination downhill, especially @ Lake Dunlap A study done in 2008(interviewee did not specify) showed overall positive economic impact of recreation but not as great as thought (see page 63: average daily expenditure per individual) Regulating alcohol is an ongoing contentious issue

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 40 B. San Marcos The San Marcos River, as compared to the Comal, has a greater variety of uses in specific zones of the river. Spring Lake, near the San Marcos springs is an area with restricted recreation activities: sightseeing (glass bottom boats), and scuba diving and snorkeling for the purposes of research. . Down river ha s much greater activity with tubin g and swimming as the primary day use activities and canoeing and kayaking as the night time activities. It is informally agreed upon that the kayak / canoe community uses the river during night time hours, in addition to the off season. It is unknown as t o how many total users there a re of the San Marcos River at any given time. D ata from year 2000 reported 500,000 people visit the river each year (Greater San Marcos Economic Development Council 2000) ; it is also reported that there is approximately 25 00 kayaks per year that travel the river and that the only tube rental outfitter in town reported to have rented out 29,829 tubes in the year 2005, which estimated to account only for about 50 60% of tubers. These numbers do not account for all others that sw im, snorkel, dive, picnic, wade, play, lounge or bring their dogs. The city has restrictions on hours of use (nighttime curfew: 11pm 6am) for their parks, however, kayakers and canoeists are tolerated during these hours. When asked if there should be rest rictions on hours of use of the river, most of those that responded said no while one responded that the hours should be restricted to 6pm when the less desirable users seem to arrive. Recreation seekers in San Marcos typically arrive by private vehicle an d though there is a shuttle in place to transport those who rent tubes back upstream , most people tubing will use the park trails (walk) to return upriver, which is unlike those tubing the Comal River in New Braunfels. It is important to note also that the tube trip in San Marcos is approximately 45 minutes as compared to 2 to 2 1/2 hours on the Comal River in New Braunfels. Aside from the already stated positive and negative aspects of recreation on the San Marcos River, there is perceived gang activity, social disorder, degradation of the river banks and bed. It is undetermined as to how much recreation on the river contributes to the local economy but it is an attraction to visitors whose primary focus may not necessarily be recreation on the river . R egardless, visitors contribute to the local economy via patronizing local retail and hospitality services and businesses. Although the level of law enforcement didn’t seem to be an issue, it was reported that there is only one park ranger on staff and part time staff is added

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 41 to patrol the parks during peak times. With the growing population and popularity of the river, more law enforcement is welcomed. San Marcos does not have restrictions regarding litter (food/beverage packaging) type, cooler size, or alcohol consumption in their parks though it was reported that some individuals felt alcohol should be banned and that there should be stricter rules regarding litter including prohibiting Styrofoam containers . In general, it was expressed that maintenance wise, it was challenging to keep up with the amount of tr as h generated at these park sites. There is perception that the growing popularity of the river is degrading the surrounding parks and that there is conflicted sentiment about the lack of dredging of the river bed, to remove the wild rice, as once was the practice, with some users perceiving the water not as clean as it once was. Although not ranked by priority, the following table illustrates number of respondents who identified specific issues.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 42 Sa n Marcos Stakeholder Interview Responses June 29, 2010 1. What are the peak times of recreation use: days, seasons, months, holidays, hours? Memorial Day to Labor Day Weekends/Long weekends 11am 4pm a) How many people are using the river at these times? Approx 2500 kayaks/ year MaySept 2005: tube rentals: 29,829 (estimate to represent only about 50% of tube users) Data from 2000 (Greater San Marcos Economic Development Council): 500,000 visitors/yr b) What areas of the river see the highest amount of use? Univer sity & City parks on the river 2. Should there be restrictions on times of use or hours of use? No 3. Does use have any correlation with water flow or river levels? No, because the spring is a constant flow 4. Can recreational activities on the river continue at current levels of activity? No Increasing levels each year but somewhat capped by having on 1 tube rental outfitter a) Why or why not? No due to degradation to water quality and parks Yes, if it is possible to create a culture of respect and stewardship for the river 5. If arriving at the river by vehicle, where do people park (private lots, owned by recreation outfitters or other private lots? Street? Public park?). There is current exploration on utilizing a shuttle to/from remote (private) parking lots Pu blic: streets, parks, city owned lots Private: illegally on TSU campus a) Do the majority of recreational users use commercial shuttle buses and are those desirable? Most people walk the park trails for tubing Most arrive to/nr river by private vehicle b) How many people (or what percentage of people) arrive at river tubing/raft launch locations by private vehicle versus shuttle bus? Most arrive at river via private vehicle c) Is one method of arrival preferable over the other? Non motor is preferable

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 43 6. Do most users access / launch from public/city owned property or private property? City Park (90%) a) Please list all known points of access and launching. City Park Sewell Park Dog Park (San Marcos Plaza) All City parks along the river Rio Vista Immediately south of I -3 5 (kayaks) Stokes Park Nr. Water treatment plant/ Animal Shelter Rd. Ramon Lucio (ball) Park (dogs) Children’s Park 7. Do most users exit the river at public/city owned property or private property? a) Please list all known points of exit. Rio vista Beyond City Limits 8. What recreational activities other than tubing, rafting and fishing occur along the river? Swimming Wading, water lounging (lawn chairs in the water) barbecuing/ picnicking canoeing, kayaking dog swimming Ducky Derby (no longer) special olympics (kayak) practice junior (kayak) olympics trials (both at Rio Vista canoe racing tours on glass bottom boats at Spring Lake scuba @ Spring Lake Power Olympic outdoor kayak courses 9. What specific locations are most frequented by these other users? Sw imming at the Spring Lake Dam (all over but this is the ideal location because of clarity of the water) dog swimming at Dog Park (San Marcos Plaza) Wading at all park locations: City Park, Sewell Park, Rio Vista Park Kayak instruction at Rio Vista Falls Ca noes at City Park All city and university parks

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 44 10. What are the positive aspects of recreation on the river? Economic benefits: liquor sales, restaurants, employment, tourism Wellness, health, quality of life 11. What are the negative aspects of recreation on the river? Environmental degradation: pollution, litter, erosion Parking issues/ traffic congestion Water safety issues Crowding issues 12. How important are river based recreational activities to the local economy? Hard to determine exactly Important but does not drive the economy a) What are its contributions: i.e. sales tax, property taxes, other taxes/fees, spinoff businesses (related revenue sources for the city)? Tourism & entertainment businesses b) How much does recreation activity contribute to the loc al economy? (in $ or % of city revenue) Lions Club tube rentals returns between $110k $125k/yr to local charities Unknown. Check with Michael Ravel & Richard Earl of TSU geography department for studies 13. What is your perception of the level of enforcement on the river? Too much, not enough? Why? Enforcement is not an issue, but more is better 14. Is the amount of regulation with regards to activities on the river acceptable? Should there be more? Or less? Need regulation to protect wild rice and prevent overcrowding issues a) Are there certain things that should be regulated that aren’t currently? More stringent litter laws including restrictions on food and beverage containers (glass & Styrofoam) Ban or limit alcohol from the river (4x) Crowding issues & river access points to disperse crowds b) Are there certain things that are currently regulated that shouldn’t be? No 15. W hat is your perception of the level of maintenance? Too much, not enough? Why? With regards to litter: there is never enough trash maintenance Sentiment that the river should be dredged annually as in previous years 16. Are there operational issues with reg ards to emergency flood situations? Well prepared: dams control many of the severe floods

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 45 OTHER COMMENTS Much degradation over last 8 years People feel conflicted over the alcohol consumption on the river/parks The revenue from the river helps maintain the river Though the city parks are closed after dark, canoeists and kayakers operate during this time and the city is tolerant of canoeists and kayakers moving through the parks at this time; there seems to be a general understanding that daytime (summer) is for tubers and all else times are best for canoeists and kayakers There is only 1 tube vendor for San Marcos: Lions Club; they run the shuttle Richard Earl, Geography Dept. at Texas State has studies regarding number of users and revenue generated fr om river activities OTHER CONTRIBUTORS TO THE ECONOMY: Outlet malls: 25 30% sales tax revenue (over 11 million visitors /yr, 3 rd highest visitor attraction inTexas) University Conference Center River in general is a draw; people attend TSU because of the setting, people move here because of the setting OPERATIONAL ISSUES Not enough restrooms & drinking fountains to support the peak capacities Need to disseminate information about the river as a natural entity so users can more fully understand what the experience of tubing on the river will be The Lions Club contributes between $110k $120k/year to local charities There is abuse of the Domestic Water Rights in that certain land owners have been drawing water to stock their ponds for uses other than agriculture (TCEQ permits 200 acre/ft / year ) Cummings Dam at the confluence of the Blanco has had a possible effect on Fountain Darter population as it stagnated a 3 mi. length and the population has shown decline (Tom Goynes article) San Marcos’s water supply is 7374% surface drawn, city has made effort to minimize their draw on the aquifer

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 46 V. WATER QUALITY DATA Water quality in the San Marcos and Comal Rivers is a measurable parameter that is being monitored on a regular basis by the TCEQ Clean Rivers Program. The data obtained through monthly sampling at specific locations can be a useful tool to assess the current health of the protected species in the two river systems, and possibly draw correlations between the frequ ency/type of recreation that contribute to measurable changes in water quality, and how these changes could affect protected species. Initially for this study, it was proposed that aquatic specialists would review existing water quality data trends and indentify potential spatial and temporal correlations between water quality data, recreational use, and protected species habitat. However through recreational research for this study, it was realized that there is not a comprehensive monitoring program to c ount the number of recreational users, or reliable user counts readily available. Data for protected species was limited and thus this initial recreational study was limited to only providing the available historical water quality data in the GIS geodatabase to build a framework for future analysis. No correlations were made during this process due to lack of data for recreation and limited data for protected species. GIS analysts obtained data from the TCEQ Water Data Management & Analysis, Water Quality Planning d ivision. This information is considered to be the most recognized, comprehensive scientific data for this area that is readily available in GIS format. The TCEQ surface water quality monitoring program coordinates the monitoring and assessment of surface water resources and oversees the statewide network of monitoring sites. The Texas Clean Rivers Program (CRP) is a state fee – funded program for water quality monitoring, assessment, and public outreach. The CRP is a collaboration of 15 partner agencies and the TCEQ. The TCEQ monitors the quality of surface water to evaluate physical, chemical, and biological characteristics of aquatic systems. Water quality is monitored in relation to human health concerns, ecological condition, and designated uses. (TC EQ website, 2010) During this study, additional water quality data sources were identified. These studies are either in progress or have just recently been published. For example, the contracted study between TCEQ and Guadalupe Blanco River Authority (2009 and 2010) to collect water quality samples is a newer ongoing study. The results of this study are scheduled to be incorporated into the future published TCEQ Clean Rivers Program. Tables 9 and 10 list the TCEQ Clean Rivers Program monitoring stations within the study area identified on map exhibits A1 to A25. The Comal River section of the study area consists of 18 surface water monitoring sites. The San Marcos River section consists of 8 surface water quality monitoring sites. Of these 26 sampling locations, monitoring data presented in the GIS geodatabase spans various months over a nineteen year period from 1990 to 2009.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 47 Future investigations can utilize the GIS geodatabase created during this study, and update it with the most current readily available data from the TCEQ Clean Rivers Program. Once numerical recreation use data becomes available, it can be compared to the water quality data to ascertain any correlations between the frequency and intens ity of recreational use and water quality. Then layering any protected species mapping data may allow analysis of any potential relationship between species sustainability or proliferation and recreation use. Two recognizable studies conducted by the USGS in the 1990’s can be used as a model for future studies (See Appendix D). The GIS geodatabase of TCEQ data includes the parameters that the

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 48 USGS used: pH, temperature, dissolved oxygen, major ions, nutrients, trace elements, selected organic compounds, and stream flow. A list of all of the parameters monitored by TCEQ are illu strated in Table 11. TABLE 11. TCEQ WATER QUALITY SAMPLING PARAMETERS 00060 FLOW, STREAM, MEAN DAILY (CUBIC FEET PER SEC) 00061 FLOW STREAM, INSTANTANEOUS (CUBIC FEET PER SEC) 00078 TRANSPARENCY, SECCHI DISC (METERS) 00090 OXIDATION REDUCTION POTE NTIAL (MILLIVOLTS) 00094 SPECIFIC CONDUCTANCE,FIELD (UMHOS/CM @ 25C) 00095 SPECIFIC CONDUCTANCE,LAB (UMHOS/CM @ 25C) 00300 OXYGEN, DISSOLVED (MG/L) 00301 OXYGEN, DISSOLVED (PERCENT OF SATURATION) 00400 PH (STANDARD UNITS) 00403 PH (STANDARD UNITS) LA B 00410 ALKALINITY, TOTAL (MG/L AS CACO3) 00480 SALINITY PARTS PER THOUSAND 00530 RESIDUE, TOTAL NONFILTRABLE (MG/L) 00535 RESIDUE, VOLATILE NONFILTRABLE (MG/L) 00593 NO2 PLUS NO3N, TOTAL, WHATMAN GF/F FILT (MG/L) 00608 NITROGEN, AMMONIA, DISSOLVED (MG/L AS N) 00610 NITROGEN, AMMONIA, TOTAL (MG/L AS N) 00613 NITRITE, DISSOLVED (MG/L AS N) 00615 NITRITE NITROGEN, TOTAL (MG/L AS N) 00620 NITRATE NITROGEN, TOTAL (MG/L AS N) 00623 NITROGEN, KJELDAHL, DISSOLVED (MG/L AS N) 00625 NITROGEN, KJELDAHL , TOTAL (MG/L AS N)

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 49 TABLE 11. TCEQ WATER QUALITY SAMPLING PARAMETERS 00630 NITRITE PLUS NITRATE, TOTAL 1 DET. (MG/L AS N) 00631 NITRITE PLUS NITRATE, DISS 1 DET. (MG/L AS N) 00665 PHOSPHORUS, TOTAL, WET METHOD (MG/L AS P) 00666 PHOSPHORUS, DISSOLVED (MG/L AS P) 00671 ORTHOPHOSPHATE PHOSPHORUS,DISS,M G/L,FLDFILT<15MIN 00680 CARBON, TOTAL ORGANIC, NPOC (TOC), MG/L 00681 CARBON, DISSOLVED ORGANIC, DNPC (DOC), MG/L 00689 CARBON, SUSPENDED ORGANIC POC (MG/L) 00900 HARDNESS, TOTAL (MG/L AS CACO3) 00915 CALCIUM, DISSOLVED (MG/L AS CA) 00925 MAGNESIUM , DISSOLVED (MG/L AS MG) 00930 SODIUM, DISSOLVED (MG/L AS NA) 00935 POTASSIUM, DISSOLVED (MG/L AS K) 00940 CHLORIDE (MG/L AS CL) 00945 SULFATE (MG/L AS SO4) 00950 FLUORIDE, DISSOLVED (MG/L AS F) 00955 SILICA, DISSOLVED (MG/L AS SIO2) 01000 ARSENIC, DISSOLVED (UG/L AS AS) 01005 BARIUM, DISSOLVED (UG/L AS BA) 01010 BERYLLIUM, DISSOLVED (UG/L AS BE) 01025 CADMIUM, DISSOLVED (UG/L AS CD) 01030 CHROMIUM, DISSOLVED (UG/L AS CR) 01035 COBALT, DISSOLVED (UG/L AS CO) 01040 COPPER, DISSOLVED (UG/L AS CU )

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 50 TABLE 11. TCEQ WATER QUALITY SAMPLING PARAMETERS 01046 IRON, DISSOLVED (UG/L) 01049 LEAD, DISSOLVED (UG/L AS PB) 01056 MANGANESE, DISSOLVED (UG/L AS MN) 01060 MOLYBDENUM, DISSOLVED (UG/L AS MO) 01065 NICKEL, DISSOLVED (UG/L AS NI) 01075 SILVER, DISSOLVED (UG/L AS AG) 01090 ZINC, DISSOLVED (UG/L AS ZN) 01095 ANTIMONY, DISSOLVED (UG/L AS SB) 01106 ALUMINUM, DISSOLVED (UG/L AS AL) 01145 SELENIUM, DISSOLVED (UG/L AS SE) 01351 FLOW:1=No Flow,2=Low,3=Normal,4=Flood,5=High,6=Dry 22703 URANIUM, NATURAL, DISSOLVED 31616 FECAL COLIFORM,MEMBR FILTER,M FC BROTH, #/100ML 31648 E. COLI, MTEC, MF, #/100 ML 31673 FECAL STREPTOCOCCI, MBR FILT,KF AGAR,35C,48HR 31699 E. COLI, COLILERT, IDEXX METHOD, MPN/100ML 32211 CHLOROPHYLL A UG/L SPECTROPHOTOMETRIC ACID. METH 32218 PHEOPHYTIN A UG/L SPECTROPHOTOMETRIC ACID. METH. 32764 7,12DIMETHYLBENZ(A)ANTHRACENE, SED, DRY WT 32772 DIBENZ(AJ)ACRIDINE, SEDIMENT, DRY WT, UG/KG 32778 M,P CRESOL, SEDIMENT, DRY WT, UG/KG 34203 ACENAPHTHYLENE, DRY WT, BOTTOM (UG/KG) 34208 ACENAPHTHENE, DRY WT, BOTTOM (UG/KG) 34223 A NTHRACENE DRY WTBOTUG/KG

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 51 TABLE 11. TCEQ WATER QUALITY SAMPLING PARAMETERS 34233 BENZO(B)FLUORANTHENE,SEDIMENTS, DRY WT,UG/KG 34245 BENZO(K)FLUORANTHENE DRY WTBOT UG/KG 34250 BENZO -APYRENE DRY WTBOTUG/KG 34276 BIS (2CHLOROETHYL) ETHER DRY WTBOTUG/KG 34281 BIS (2CHLOROETHOXY) METHANE DRY WTBOTUG/KG 34286 BIS (2CHLOROISOPROPYL) ETHER DRY WTBOTUG/KG 34295 N BUTYL BENZYL PHTHALATE, SEDIMENTS,DRY WT,UG/K 34323 CHRYSENE DRY WTBOTUG/KG 34339 DIETHYL PHTHALATE DRY WTBOTUG/KG 34344 DIMETHYL PHTHALATE DRY WTBOTUG/KG 34349 1,2DIPHENYLHYDRAZINE, DRY WT , BOTTOM (UG/KG) 34379 FLUORANTHENE DRY WTBOTUG/KG 34384 FLUORENE DRY WTBOTUG/KG 34389 HEXACHLOROCYCLOPENTADIENE DRY WTBOTUG/KG 34399 HEXACHLOROETHANE DRY WTBOTUG/KG 34406 INDENO (1,2,3CD) PYRENE DRY WTBOTUG/KG 34411 ISOPHORONE DRY WTBOTUG/KG 3443 1 N NITROSODI N PROPYLAMINE DRY WTBOTUG/KG 34436 N NITROSODIPHENYLAMINE DRY WTBOTUG/KG 34441 N NITROSODIMETHYLAMINE DRY WTBOTUG/KG 34445 NAPHTHALENE DRY WTBOTUG/KG 34450 NITROBENZENE DRY WTBOTUG/KG 34455 PARACHLOROMETA CRESOL DRY WTBOTUG/KG 34464 PH ENANTHRENE DRY WTBOTUG/KG

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 52 TABLE 11. TCEQ WATER QUALITY SAMPLING PARAMETERS 34472 PYRENE DRY WTBOTUG/KG 34524 BENZO(GHI)PERYLENE1,12 BENZOPERYLENDRYWTBOTUG/KG 34529 BENZO(A)ANTHRACENE1,2 BENZANTHRACENDRYWTBOTUG/KG 34539 1,2DICHLOROBENZENE DRY WT, BOTTOM (UG/KG) 34554 1,2,4TRICHLOROBENZENE DRY WTBOT UG/KG 34559 1,2,5,6DIBENZANTHRACENE DRY WTBOTUG/KG 34569 1,3DICHLOROBENZENE, DRY WT, BOTTOM (UG/KG) 34574 1,4DICHLOROBENZENE, DRY WT, BOTTOM (UG/KG) 34589 2CHLOROPHENOL, DRY WT, BOTTOM (UG/KG) 34594 2NITROPHENOL DRY WTBOTUG/KG 34599 DI-NOCTYL P HTHALATE DRY WTBOTUG/KG 34604 2,4DICHLOROPHENOL DRY WT, BOTTOM (UG/KG) 34609 2,4DIMETHYLPHENOL DRY WT, BOTTOM (UG/KG) 34614 2,4DINITROTOLUENE DRY WT, BOTTOM (UG/KG) 34619 2,4DINITROPHENOL DRY WT, BOTTOM (UG/KG) 34624 2,4,6TRICHLOROPHENOL ,DRY WT , BOTTOM (UG/KG) 34629 2,6DINITROTOLUENE DRY WT, BOTTOM (UG/KG) 34634 3,3' DICHLOROBENZIDINE, DRY WT BOTTOM (UG/KG) 34639 4BROMOPHENYL PHENYL ETHER, DRY WT, BOT (UG/KG) 34644 4CHLOROPHENYL PHENYL ETHER, DRY WT, BOT (UG/KG) 34649 4NITROPHENOL ,DRY WT, BOTTOM (UG/KG) 34660 DNOC (4,6DINITRO ORTHO CRESOL) DRY WTBOTUG/KG 34695 PHENOL(C6H5OH) SINGLE COMPOUND DRY WTUG/KG 34721 2,3,4,6TETRACHLOROPHENOL SEDIMENT, DRYWT(UG/KG)

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 53 TABLE 11. TCEQ WATER QUALITY SAMPLING PARAMETERS 39036 ALKALINITY, FILTERED SAMPLE AS CACO3 MG/L 39061 PCP (PENTACHLOROPHENO L ) IN BOT DEPOS DRY UG/KG 39102 BIS(2ETHYLHEXYL) PHTHALATE SED, DRY WT,UG/KG 39112 DI-NBUTYL PHTHALATE, SEDIMENTS,DRY WT,UG/KG 39118 PENTACHLOROBENZENE IN SEDIMENT UG/KG 39121 BENZIDINE IN BOTTOM DEPOS (UG/KG DRY SOLIDS) 39191 TOTAL CHLORONAPTHALEN E (1AND 2) IN SED, UG/KG 39631 ATRAZINE IN BOTTOM DEPOS (UG/KG DRY SOLIDS) 39701 HEXACHLOROBENZENE IN BOT DEPOS (UG/KG DRY SOLIDS 39705 HEXACHLOROBUTADIENE BOT. DEPOS. (UG/KG DRY WT) 70300 RESIDUE,TOTAL FILTRABLE (DRIED AT 180C) (MG/L) 70507 ORTHOPHO SPHATE PHOSPHORUS,DISS,MG/L,FILTER >15MIN 72053 DAYS SINCE PRECIPITATION EVENT (DAYS) 73031 PRONAMIDE IN SEDIMENT, DRY WEIGHT (UG/KG) 73116 P DIMETHYLAMINOAZOBENZENE, SED, DRY WT, UG/KG 73117 PHENACETIN IN SEDIMENT, DRY WEIGHT (UG/KG) 73118 ETHYLMETHA NSULFONATE IN SEDIMENT, DRY WT (UG/KG) 73119 METHYLMETHANESULFONATE IN SEDIMENT, DRY WT (UG/K 73122 2,6DICHLOROPHENOL IN SEDIMENT, DRY WT (UG/KG) 73124 2NAPHTHYLAMINE IN SEDIMENT, DRY WEIGHT (UG/KG) 73125 4AMINOBIPHENYL, SEDIMENT, DRY WT (UG/KG) 73129 N NITROSOPIPERIDINE IN SEDIMENT, DRY WT (UG/KG) 73143 1NAPHTHYLAMINE IN SEDIMENT, DRY WT (UG/KG) 73156 3METHYLCHLORANTHRENE, SEDIMENT, DRY WT(UG/KG)

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 54 TABLE 11. TCEQ WATER QUALITY SAMPLING PARAMETERS 73158 2METHYLPYRIDINE IN SEDIMENT, DRY WEIGHT (UG/KG) 73159 N NITROSO DI -NBUTYLAMINE, DRY WT,SE DIMENT (UG/K 74069 STREAM FLOW ESTIMATE (CFS) 75212 BENZYL ALCOHOL IN SEDIMENT, DRY WEIGHT (UG/KG) 75315 BENZOIC ACID IN SEDIMENT, DRY WEIGHT (UG/KG) 75647 DIBENZOFURAN, SEDIMENT, DRY WT (UG/KG) 78299 2NITROANILINE IN SEDIMENT, DRY WEIGHT (UG/KG) 78401 2,4,5TRICHLOROPHENOL IN SEDIMENT,DRY WT (UG/KG) 78543 CARBAZOLE IN SEDIMENT, DRY WEIGHT (UG/KG) 78755 ACETOPHENONE, SEDIMENT, DRY WT (UG/KG) 78866 ANILINE IN SEDIMENT, DRY WEIGHT (UG/KG) 78867 4CHLOROANILINE, SEDIMENT, DRY WT (UG/KG) 78868 2MET HYLNAPTHALENE IN SEDIMENT, DRY WEIGHT (UG/K 78869 3NITROANILINE, SEDIMENT, DRY WEIGHT (UG/KG) 78870 4NITROANILINE, SEDIMENT, DRY WT (UG/KG) 78872 2METHYLPHENOL(OCRESOL) SEDIMENT DRY WT. (UG/KG 80154 SUSP. SEDIMENT CONCENTRATION EVAP AT 110C (MG/L) 80256 SEDIMENT PRTCL.SIZE CLASS >2.0MM GRAVEL %DRY WT 81373 SOLIDS IN SEDIMENT, PERCENT BY WEIGHT (DRY) 81808 PENTACHLORONITROBENZENE IN SEDIMENT, DRYWT (UG/K 81818 SEVIN IN SEDIMENT DRY WEIGHT (UG/KG) 81951 TOTAL ORGANIC CARBON,NPOC(TOC), SED DRY WT, MG/KG 82003 MOISTURE CONTENT IN SEDIMENT (%) 82008 SEDIMENT PRTL.SIZE CLASS.0039.0625 SILT %DRY W

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 55 TABLE 11. TCEQ WATER QUALITY SAMPLING PARAMETERS 82009 SEDIMENT PRCTL.SIZE CLASS <.0039 CLAY %DRY WT 82079 TURBIDITY,LAB NEPHELOMETRIC TURBIDITY UNITS, NTU 88811 CRESOL IN SEDIMENT, DRY WEIGHT, (UG/K G) 88817 N NITROSODIETHYLAMINE, SED DRY WT (UG/KG) 88823 PYRIDINE SEDIMENT DRY WEIGHT (UG/KG) 88826 1,2,4,5TETRACHLOROBENZENE SEDIMENT DRY WT (UG/K 89835 FLOW MTH 1=GAGE 2=ELEC 3=MECH 4=WEIR/FLU 5=DOPPL 89991 SEDIMENT PRCTL.SIZE CLASS,SAND .06252MM %DRYWT In addition to data collection, the TCEQ assesses water quality throughout the state. Formerly called the "Texas Water Quality Inventory and 303(d) List," the Integrated Report evaluates the quality of surface waters in Texas, and provides resource managers with a tool for making informed decisions when directing agency programs. The Texas Integrated Report describes the status of Texas’ natural waters based on historical data. It identifies water bodies that are not meeting standards set for their use on the 303(d) list. The Texas Integrated Report satisfies the requirements of federal Clean Water Act Sections 305(b) and 303(d). The TCEQ produces a new report every two years in even numbered years, as required by law. The 303(d) List must b e approved by the EPA before it is final. The TCEQ monitoring program also reports the status of water quality in the biennial Texas Water Quality Inventory and 303(d) List of Impaired Waters. The Texas Water Quality Inventory and 303(d) List reports the information on Texas' surface waters, including concerns for public health, fitness for use by aquatic species and other wildlife, and specific pollutants and their possible sources (TCEQ website, 2010). Table 12 lists the stream segments within the study area. According to the 2008 Texas Water Quality Inventory and 303(d) List of Impaired Waters, no segments (1811, 1812, and 1814) within the study area were considered impaired. See Appendix D for the results of this analysis.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 56 TABLE 1 2 2008 TEXAS W ATER QUALITY INVENTORY STREAM SEGMENTS IN STUDY AREA 1811 – Comal River From the confluence with the Guadalupe River in Comal County to Klingemann Street in New Braunfels in Comal County (4 miles) 1811A – Dry Comal Creek Unclassified (Not assessed in 20 08) From the confluence of the Comal River in New Braunfels in Comal County to the upstream perennial portion of the stream southwest of New Braunfels in Comal County (30 miles) 1814 – Upper San Marcos River From a point 1.0 km (0.6 miles) upstream of the confluence of the Blanco River in Hays County to a point 0.7 km (0.4 miles) upstream of Loop 82 in San Marcos in Hays County (5 miles)

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 57 VI. PERTINENT SCIENTIFIC STUDIES Sources for the following studies come from the City of San Marcos, the City of New Braunfels, and River Systems Institute . Halff is aware there are relevant studies beyond what has been summarized in this document, however those relevant studies were either not accessible or not made available at the time of this report . I t would likely be of benefit for the EARIP to take into consideration the results of those complementary stud ies. The studies reviewed include habitat conservation plans, academic theses, articles and books and provide insight into the management of rivers for the sake of habitat and/or the physical and chemical affects on rivers from human activity, including re creation. Of greatest relevance is the current on going study of Texas State University student Jenna Winters; although methodologies were not specifically revealed, her data on the San Marcos River is the most site specific and significant of information gathered. A. Pertinent Studies Doctoral Study of San Marcos River between Sewell Park and Rio Vista falls by Jenna Winters, unpublished data from 2007 2009 Geographical points of study of San Marco River from upstream to downstream order: Last bridge Ju st before City Park Just after City Park Hopkins St. Bridge Bicentennial Park Beginning of Rio Vista Park Dam at Rio vista Park Turbidity: Measurements of turbidity were taken at 6’ from each bank and center of current channel Correlation was found betwee n number of people and turbidity levels. Levels of turbidity in San Marcos River between Sept and April: mostly recorded at 2.00 NTUs and under, rarely more than 3.00 NTUs. Spikes in turbidity during this time correlated with rainfall events. Turbidity inc reased with summer months. The correlation was found to be consistently 0.72 in both 2008 and 2009.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 58 Years when flow of the river was low, turbidity was higher and vice versa. Peak days were summer season (Memorial Day weekend – Labor Day) Saturdays and Su ndays, with greater amount of people on Saturdays. Holiday Mondays showed higher numbers as well and in general, Thursdays and Fridays averaged greater numbers than Tuesdays and Wednesdays. In one counting survey performed during a July 4 weekend taken between 12pm and 2pm, 1756 people (swimming or tubing) and 6 dogs were counted to be in the river. On June 5, 2009 (a Friday), a count was documented at 706 people and 4 dogs. In her 2008 survey of 717 people, the following information was revealed: Reported primary activity of visitors to the San Marcos River: 33% swim 28% socialize 16% tube 6% boat 2% fish Mean age of user: 34 53% were from San Marcos area 76% were from the Austin San Antonio IH 35 corridor 98% were Texas residents 98% reported they would r eturn 87% were repeat visitors Average duration of stay at the river: 4 hours This duration does not vary with weekend or weekday days 50% brought their own tubes For that particular visit: 75% spent less than $25 13% spent between $25 $50 6% spent between $50 $75 7% spent >$100 6% were overnight guests 24% advised that fuel prices would affect their decision to visit Awareness of listed species in the San Marcos River : 59% advised they were aware 27% advised they learned this from school programs

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 59 18% ad vised they learned this from friends 13% advised they learned this from signage 67% of Caucasians were aware 44% of Hispanics were aware Cleanliness of the River : 29% perceived the water as very clean 50% perceived the water is mostly clean Perception of crowding 82% reported to have no issues with levels of crowd 94% reported to not feel crowded or only slightly crowded Ethnicity Percentage of Hispanic and Caucasian visitors proportionately mirrored the San Marcos city demographic USFWS, Summary of 2009 sampling efforts related to Edwards Aquifer Authority Variable Flow Study under USFWS permit number TE037155 0, 2009 Methods and findings of federally listed species in specific locations of the Comal and San Marcos Rivers were explained. This repor t provides current and specific information of where and in what kinds of densities each of the Fountain Darters, San Marcos Salamander, Texas Wild Rice, Comal Spring Riffle Beetle w as found, along with other fish and crustaceans, arachnids and insects. Information regarding current flow, time of year and water quality was also provided, as well as findings from previous years for comparison. This report is useful in ascertaining information about population fluctuations and habitat conditions and may provi de clues as to where recreation use could be altered to accommodate for these habitats. Owens, Chetta S., John D. Madsen, R. Michael Smart and Michael Stewart Dispersal of Native and Nonnative Aquatic Plant Species in the San Marcos River, Texas Five sites were sampled 5 times each on a quarterly schedule reflecting seasonal trends for introduced and native vegetation types. The article focuses on the proliferation of hyrdrilla and East Indian hygrophila and their effects on the native listed species Texas Wild Rice. References to other sources noted times and season of recreation use and the finding that recreation negatively impacts

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 60 Texas wild rice, additionally that recreation users disturb, tear and uproot native species allowing more aggressive nonnative species to proliferate. Bussemey, Michelle, Analysis of Landscape Change of the Rio Vista Dam in San Marcos, Texas . MS Thesis, Texas State University, San Marcos, Texas, 2007 Repeat photography documents the changes of the river and adjacent banks at the location of the current day Rio Vista Dam dating back from 1917. A cultural and physical history is documented and concludes the landscape changes which include opening this part of the river to the community (for recreation use) and the reconstruction of the dam and construction of step pools has resulted in congestion, increased turbidity and trash in and around the river. The author also warns the alterations in the dams and the introduction of pools will also result in sediment bars and ultimately c ould alter the channel and the flow of the river. City of San Marcos Habitat Conservation Plan (Draft – not yet implemented) This report outlines options in strategies in which to protect and minimize disturbance and limit take (to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct) of federally listed aquatic species found in the San Marcos River during the course of maintenance and construction projects and activities for the next twen ty (20) years . Those species include the fountain darter, the Comal Springs riffle beetle, the San Marcos salamander and Texas wild rice. Requirements under the take permit, known as a Section 10(a)(1)(B) permit, issued by US Fisheries and Wildlife Service (USFWS) include biological data, impact assessments, geographical area, activities of listed species within the project area, provisions to monitor, minimize, and mitigate impacts and procedures to deal with unforeseen circumstances. This report aims to support a comprehensive watershed management plan for the San Marcos River within the city limits which includes the city’s Recreation Master Plan as well as the Environmental Protection Agency Phase II Storm Water Management Program. The projects and activities that apply to this study are those surrounding the San Marcos River corridor between the springs at Spring Lake and Rio Vista Falls. This draft publication describes the physical attributes of the affected area, including hydrology, climate, water quality, existing land use, vegetation and wildlife including the listed species. The draft publication also makes an assessment of threats which include sedimentation, increased pollution, increased nutrient levels, expanding population of nonnatives and recreational activity, on which this report focuses.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 61 River recreation activities cited include scuba, swimming, tubing, canoeing/kayaking, fishing, wading, dog playing, snorkeling and boat touring. Recreation causes disturbance to the river bottom and v egetation, streamside issues include erosion, litter and pollution , while fishing specifically can introduce nonnative bait species. Maintenance is performed to maintain a clear corridor for water recreation; this includes clearing vegetation from the ce ntral 5 meters of the current channel to a depth of 12 ”. The city will manage a strategically timed incremental removal of high growth and nonnative vegetative species while replacing with low growth native species, in addition to sediment removal. The proximity of Texas State University golf course incurs strict regulations by USFWS on use of fertilizers and pesticides, as well as watering regimes. In addition to outlining ongoing maintenance activities within the area, this draft publication also lists future projects by Texas State University, including construction of a new hike/bike trail and an expanded academic curriculum of water activities (at Spring Lake) by Texas State University. City projects include bank stabilization projects and provision of controlled river access points taking care to remediate with native rock and riparian vegetation. Edwards Aquifer Authority. ‘Comprehensive and Critical Period Monitoring Program to Evaluate the Effects of Variable Flow on Biological Resources in t he Comal Springs/River Aquatic Ecosystem Final 2009 Annual Report ’ . BIO WEST Inc. March 2010 This report was made known to the Halff team late in the process of producing this report and was thus not thoroughly reviewed. Relevant information found in this document include s monitoring efforts by the Master Naturalist volunteers who collected data on river users (numbers, types/activities) and water quality (pH, carbon dioxide ) on a weekly basis in the year s 2006 through 2009 . Five (5) sites were visited reg ularly at roughly the same time for the same duration at each of the five locations . Tubing was found to be the dominant recreation activity, with emphasis between May and September of each year and 2009 showed a higher number of users at four of the five locations over 200 7 and 2008. With regards to water quality, pH levels were shown to be consistently lower nearer the springs than downstream and carbon dioxide concentrations showed higher levels nearer the springs and less downstream. Edwards Aquifer Authority. ‘Comprehensive and Critical Period Monitoring Program to Evaluate the Effects of Variable Flow on Biological Resources in the San Marcos Springs/River Aquatic Ecosystem Final 2009 Annual Report’ . BIO WEST Inc. March 2010

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 62 This report was made know n to the Halff team late in the process of producing this report and was thus not thoroughly reviewed. This document summarizes the methodology and findings of two comprehensive monitoring events and three critical period low flow events. These samplings e xamined water chemistry, current flow, water levels, water temperature, aquatic vegetation and changes in channel morphology. This type of detailed investigation found correlations between the establishment of Texas wild rice with water levels and current flow and subsequently, recreation use as a result of water levels and their impact on the establishment of Texas wild rice. The report cites mechanical disturbance on river banks and bottom and fragmentation of wild rice stands from recreationists . Quantit ative data comes from mapping of wild rice stands and measurement of current flows, water levels, and changes in channel morphology. Observed r ecreation use (areas and activities) correlated with accessibility of the river and water depths. Similarly , foun tain darter found locations correlated with stands of aquatic vegetation and was thus also found to be affected by recreationists. Edwards Aquifer Area Expert Science Subcommittee for the Edwards Aquifer Recovery Implementation Program. ‘Analysis of Speci es Requirements in Relation to Spring Discharge Rates and Associated Withdrawal Reductions and Stages for Critical Period Management of the Edwards Aquifer’. Report to Steering Committee for the Edwards Aquifer Implementation Program. December 28, 2009. T his report was made known to the Halff team late in the process of producing this report and was thus not thoroughly reviewed. Quantitative d ocumentation of water flow and physical changes to vegetation and stream channel were provided for the three (3) years of this study. Information regarding population size and locations of the various species at various times of the year were also provided and qualitative observations were made regarding the context of each sampling period, including human (recreation) activity. The report provides information on which and how listed species are affected by flow rates and the various factors flow rates affect (that ultimately affect the habitat for listed species) : turbidity (sunlight), scouring effects (establishment of Texas wild rice and opportunities for more aggressive (competitive) non native aquatic vegetation ) , sedimentation , recreation ( opportunites for greater human contact with banks and river bottoms, accessibility of shallow depth stream areas). The report clearly indicates recreation has a direct and indirect effect on fountain darters and a direct effect on Texas wild rice but cites such factors as sedimentation, turbidity, presence of exotic species are also variables in their populations. Populations of the Texas blind salamander and listed beetle species are noted to be physically found closer to or with in the spring sources and are thus much less affected by recreation but more so by water table depth (draw) , water flow rates (draw and drought) and wat er quality (pollution within recharge zones) . The San Marcos blind salamander riverbed habitat w as found to be

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 63 impacted near Spring Lake Dam by siltation (allowing extensive vegetation growth) and (accessibility of water) recreation during low discharge ye ars of 2006 and 2009 . The report makes conclusions about minimum flow rates for species survival. Bradsby, D.D. 1994. A Recreational Use Survey of the San Marcos River. MS Thesis, Southwest Texas State University, San Marcos, Tx 82pp. This study was not accessible but was referred to by several sources. Breslin, S.L. 1997. The impact of recreation on Texas wild rice . MS Thesis, Southwest Texas State University, San Marcos, Tx. 69pp. This study was not accessible but was referred to by several sources. On e reference found stated Texas wild rice is found only in the upper 2.5 km of the San Marcos River. Recreation visibly causes considerable damage to Texas wild rice stands with highest occurrence during peak recreational months in the hours between 2 3pm. Earl , Richard A. and Wood, Charles R. ‘Upstream Changes and Downstream Effects of the San Marcos River of Central Texas’. The Texas Journal of Science February 2002 The San Marcos River is recognized as a unique resource; it is attracting a growing population to the city as well as Texas State University. It is documented to have the potential to produce a floodflow of 247 square kil om eters. The flood of May 15, 1970 which resulted in a discharge of 76 ,600 cubic feet per second was the impetus for the formation of the Upper San M arcos Watershed Reclamation and Flood Control District. Another flood on June 13, 1981 prompted the funding for a series of five (5) control dams upstream San Marcos River, the last of which was completed in 1991. These dams h ave a combined capacity of 23 million cubic meters (19,000acre feet) and consequently reduced the uncontrolled drainage are a from 247 square km to 47 square km. Although effective in controlling flood damage (as evidenced by larger than 100 year flood event of October 1998, which produced a peak discharge of what would have been a 25 year event), the construction of the dams have resulted in decreased scouring action (reduced flow), and consequently, increased sedimentation of the river, by as much as 0.5 m eters depth in the main channel . The changes have caused issue with the increases in exotic riparian and aquatic vegetation, and thereby affecting the natural habitats of the four (fountain darter, texas wild rice, san marcos salamander, comal springs riffle beetle) US Fish and Wildlife Services aquatic species . While flooding control measures are effective, they have brought on a new set of management issues. The Texas Parks and Wildlife Department and the City of San Marcos Parks and Recreation Department since 1990 have been closely monitoring the river for critical habitat and for protection of the river as an aesthetic and tourism resourc e.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 64 Comal County, Texas and Comal County Commissioners Court. Comal County Regional Habitat Conservation Plan . April 2010 The r ate of growth in Comal County has induced a desire for a strategy in which to ensure the protection and preservation of open space for the benefit of the County’s citizens, to conserve the County’s endangered species and to help landowne rs comply with Endangered Species Act (ESA)compliance efficiently and cost effectively. Participation in the County’s process by landowners is voluntary, although compliance with the Endangered Species Act is not. A Habitat Conservation Plan (HCP) by Coma l County would help establish a 30 year regional permit that would allow authorization under the ESA for land development activities that could affect the ‘take’ (to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt t o engage in any such conduct) of federally listed or endangered wildlife species listed under the ESA. This type of regional plan specifies the conservation measures that would be implement ed in exchange for a US Fisheries and Wildlife Service section 10(a )(1)(B) permit. The Regional HCP addresses habitats for the golden cheeked warbler and the black capped vireo. (Federally) Listed species not addressed in this HCP are aquatic species associated with Edwards Aquifer: the fountain darter, Peck’s cave amphipod, Comal Springs riffle beetle, and the Comal Springs dryopid beetle. Comal County, Texas and Comal County Commissioners Court. Comal County Regional Habitat Conservation Plan Environmental Impact Statement . April 2010 This report describes t he potential impacts of the ‘take’ permit described in the Comal County Regional Habitat Conservation Plan (RHCP) of April 2010. Although the aforementioned plan addresses only the take of the golden cheeked w arbler and the black capped vireo, this environmental impact statement describes the affect on habitats of other species as a result of land d evelopment; the report provides three (3) scenarios for Comal County: no regional permit (alternative A) , regional permit granted (alternative B) , reduced take regional permit (alternative C , does not cover habitats of the black capped vireo ) . Each scenario is described in terms of the direct, indirect and cumulative effects of take and mitigation as proposed by the RHCP. The proposed action, as the favore d scenario is referred to, is alternative B: to obtain a regional permit that would allow Comal County to process and monitor land development in terms of take and to ensure that the RHCP is adhered to in terms of mitigating environments and allocating habitat in perpetuity for the survival of the golden cheeked warbler and the black capped vireo. A regional permit would require a commitment of resources, including revenue, to monitor and support the RHCP. This direction is described as most strategic in that it

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 65 is projected to least hinder the pace of economic growth in the area while also yielding the greatest potential for preservation. A detailed analysis of various topics is part of this environmental impact assessment: water resources, vegetation , general wildlife, covered species, socioeconomic resources. Of the covered species, the listed species of interest in our river recreation study are identified as other protected species (other = those negligibly or minor affected by land (woodland) deve lopment as outlined in the RHCP ) : San Marcos salamander (Eurycea nana), Texas blind salamander (Typhlomolge rathbuni), Fountain Darter (Etheostoma fonticola), San Marcos gambusia (Gambusia georgei), Comal Springs Dryopid Beetle (Stygoparnus comalensis), Comal Springs Riffle Beetle (heterelmis comalensis), Texas wild rice (Zizania texana) . It should also be noted that The San Marcos salamander, Texas blind salamander, San Marcos gambusia and Texas wild rice are not evident in Comal County. The consequential impacts from land development that may affect our species of interest would be any affects to the Edwards Aquifer (development will not be permitted to draw from this aquifer) such as any draw/reduction in flow and any sedimentation or toxic deposits in su rface waters as a result of development and the reduction of pervious ground (unfiltered recharge). Changes in water levels, temperature and toxicity would be the largest threat, but b ecause there are strict regulations on aquifer withdrawal, water quality control and development over the Edwards Aquifer recharge zone , and with the development of the Edwards Aquifer Recovery Implementation Program (EARIP) , our three species of interest in Comal County (Comal Springs Riffle beetle, Comal Springs dryopid bee tle and the fountain darter) w ould be minor to negligible . It is also stated that developing programs such as the EARIP, of which this study is a part, could be beneficial to such species. The primary focus of this RHCP is the take of black capped vireo an d golden cheeked warbler habitat, which is woodland and is thus theoretically unlikely to affect the habitats of our species of interest. The following ongoing or planned authorities, rules and regulations are expected to minimize the impacts on wa ter resources and aquatic species: Edwards Aquifer Authority Rules Texas Pollutant Discharge Elimination System regulations Environmental Protection Agency and Army Corps of Engineers wetlands program Texas Commission on Environmental Quality total maximum daily load program Groundwater pumping regulation of the Edwards Aquifer Authority Texas House Bill 1763: requiring groups of Groundwater Districts to plan for the desired future condition of the groundwater resources in their Groundwater Management A rea

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 66 Texas Senate Bill 3: process leading to establishment of minimum environmental flow standards for each river basin in the state Water quality regulations of the city of San Antonio Edwards Aquifer Recovery Implementation Program Creation of a groundwat er district over parts of the Trinity Aquifer occurring over Comal County This environmental impact statement states the maintenance of water levels within the Edwards Aquifer area as established and regulated by the Edwards Aquifer Authority is the strongest measure in protecting the aquatic listed species so much so that it concludes that the RHCP measures proposed would minimally reduce cumulative adverse impacts on such species. The report lastly discusses the possibility of climate change and other unavoidable adverse impacts and that they would be offset by the preservation of larger blocks of unfragmented habitat. B. Related Studies : Bowles, David E,. and Arsuffi , Thomas L. Karst aquatic ecosystems of the Edwards Plateau region of central Texas, USA: A consideration of their importance, threats to their existence, and efforts for their conservation. 28 Jun 2006 (online publication), from Aquatic Conservation: Marine and Freshwater Ecosystems: Special Issue: Endangered Aquatic Habitats A Symposium of the Entromological Society of America December 1992 Volume 3, Issue 4, pages 317 329, December 1993 John Wiley & Sons, Ltd 1993 This article identifies the endangered species within the Edwards Aquifer, along with the endemic and unique aquatic biota of the Edwards Plateau. It identifies specific threats from expanding human population including overpumping of aquifers, agricultural practices, pollution, development, recreational activities, introductions of exotic species and changes in regional and global climatic patterns and means for protection and remediation. This article is most relevant to our focus of study by means of its discussion of water conservation, development of alternative water sources and land management and stewardship programmes. Newsome, David. Moore, Susan A.. Dowling, Ross Kingston. Natural Area Tourism, ecology, impacts and management. Channel View Publications, 2002. A book that looks at the evolution of natural area tourism, creation of national parks, preservations are as globally and the means by which

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 67 environmental consciousness is leading us to find more comprehensive means of planning and managing the impacts of environmental tourism in such a way that not only heightens the experience of the tourist but also benefit s the environment simultaneously. The book has many examples of monitoring and surveying techniques used globally to measure various physical and social aspects to first establish a baseline of use and secondly, direction in which to maximize benefits to b oth users and the environment. Of particular interest in this document related to our study of the San Marcos and Comal systems are the physical variables that are measured with regards to soil compaction and bank stabilization/erosion. It also lists some effects that have not been discussed previously: noise levels, changes in nutrient availability and distribution caused by disturbing river bottoms as well as disturbance of mating rituals and deposited eggs of various species. This book is a wealth of exa mples of how and what could be sampled to help monitor the effects of recreation for further study. GCAGS Transactions Volume 48 (1998) Barton Creek watershed and springs located under the Glen Rose Formation : found differences in chemistry of shallow g round water between urban and rural settings, including nutrient levels, pH, temperatures, nitrates, ammoia, Kjeldahl nitrogen, specific conductance and total dissolved solids and potential sources of increased nitrogen levels. Edwards Aquifer Authority. ‘Variable Flow Study: Seven Years of Monitoring & Applied Research’ . BIOWEST Inc. August 2007. This report was made known to the Halff team late in the process of producing this report and was thus not thoroughly reviewed. Over the course of seven years, multiple studies by various academic and government agencies have helped contribute to the findings of variable flows on aquatic habitat with a focus on the federal list of endangered species, the population dynamics and their habitat conditions. Water fl ow (rates), water quality, water levels, temperature, chemistry, aquatic vegetation, stream morphology were all studied with a focus on the effects on the biological communities. One of the major findings is the importance of aquatic vegetation to the biol ogical community whose changes are measurable and relevant with spring discharge/current flow. The findings include an expanded range of habitat for the Comal Spring riffle beetle, stable populations for the San Marcos and Comal Springs salamanders as well as the fountain darter (but found to correlate with establishment of aquatic vegetation) and that the greatest threats to these species include recreation as well as sedimentation, introduction of exotic species and

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 68 aquatic vegetation mats. As so much of water quality is a factor for biological species, such is the importance of aquatic vegetation and Texas wild rice which are most greatly impacted by recreation activities. The document cites direct impacts from recreation on Texas wild rice stands indirec tly affect the habitat availability and quality for fountain darters . The study found stable populations in the beetles, salamander species of the endangered species list. Gramann, James H. Toward a behavioral theory of crowding in outdoor recreation: An evaluation and synthesis of research This document provides r esearch on physical density versus psychological crowding in outdoor recreation. Kuss, FR | Graefe, AR Effects of recreation trampling on natural area vegetation. Journal of Leisure Research [ J. LEISURE RES.] . Vol. 17, no. 3, pp. 165 183. 1985. The injurious effects of recreational use on vegetation of natural areas is influenced by not only plant responses to the direct mechanical effects of trampling, but also by stress factors internal to the ecosystem as well as changes in the physical, chemical and, biological nature of the soil medium. These effects are reviewed by tracing the dimensions of impact through selected stages in the life cycle of vascular plants beginning with seed germination and seedling establishment, growth functions after establishment, vigor and biomass production, flowering, seed production, and finally recolonization of impacted areas. Sabine River Authority of Texas, Orange, Tx, Sabine River Authority, Recreation Us e and Needs Assessment Study Plan, Revised Study Plan Toledo Bend Relicensing Project FERC Project No. 2305.S tate of Louisiana, Many, LA, July 2009 By use of surveys and site analyses, the study explains a methodology for assessing the recreation facilitie s around the Toledo Bend Reservoir, the demand and factors to look at for carrying capacity. This study may be useful in providing a list of variables in which to help determine limits on the various recreation activities that currently exist on our rivers of study and for any future land (recreation: camping, sports fields, amphitheaters, picnic sites, trails and the like) developments adjacent. Smith, Kellen A. Providing the best of both worlds: balancing conservation and recreation in a system of prote cted areas in Texas .

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 69 MS thesis, Louisiana State University and Agricultural and Mechanical College, August 2007 Texas Parks and Wildlife Department is charged with the task of providing conservation while offering recreational activities. Using the salient points of the Rio Summit of 1992 on Environment and Biodiversity as a guide, the questions of (a) whether the designated wildlife management areas (WMAs) are successful at providing enough area to adequately represent the various ecoregions of Texas (b) what do visitation rates tell us about what these WMAs offer and (c) do these WMAs adequately fulfill the desires of Texans regarding protection of wildlife and providing outdoor recreation. A list of societal, park management, and individual benefits and goals are presented as well as the variables that limit or attract visitors: proximity to urban areas/highly populated areas, size of WMA, clustering of WMAs, types of recreation activities (consumptive and nonconsumptive), existence and number of endange red or threatened species. Though the San Marcos and Comal River systems are not WMAs, it could be asked if they should be treated or managed as such considering their locations in highly populated areas, the benefits they provide and the number of federal ly listed species within these ecosystems.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 70 VII. ECONOMIC INFORMATION A. New Braunfels ‘The Impact of Tourism in Comal County’, TXP, Inc. December 2007 This study looks at growth between years 2001 through 2006 in the county in terms of employment, population, single family building permits, and sales tax as indicators of the local economy. The graphs presented in the report express an accelerated growth with time. The report notes that tourism has grown at a slower pace than the local economy and c ites probable causes such as 911, unusual weather patterns, and loss of shopping outlets. Under the Bureau of Economic Anaylsis of the U.S. Department of Comme rce, ‘tourism’ is not a a distinct industry classification and therefore the numbers in this report are extrapolated from tourist related activity such as restaurant/bar sales and amusement and recreation sales. Using ratios and adjustments in accordance with statistics of growth in factors like employment, population and building permits, it is estimated the full di rect economic impact of tourism for Comal County in year 2002 was $143.6 million, and by year 2006 had grown to $224.9 million. For the year 2006, s ales taxes from tourism generate d approximately $5 million for the City of New Braunfels and Comal County, of which river recreation account ed for approximately 20 percent. 2006 River Tourism Calculation: A survey of 1,046 tubers using the Comal and the Guadalupe entry and exit points at various times in the summer of 2007 yielded the following results: 52 r epsondents resided in Comal County 48 respondents reported that tubing was not their primary reason for their visit to the area approximately 4 86 were day trip visitors Approximately 4 60 were overnight visitors The average dollar expenditure of a day trip visitor was $27 The average dollar expenditure of an overnight visitor was $187.64 River tourism spending and calculated numbers were based on the following: In 2006, the City of New Braunfels reported more than 208,000 tubers w ho paid

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 71 the tube fee, of which it is estimated (based on the 2007 survey of percentages of out of towners and locals) that there were approximately 199,122 tubers who were not local (overnight guests). TXP estimated a blended average daily expenditur e to be $113, yielding direct river tourism at $22.5 million for 2006. The full economic impact of river tourism was calculated based on direct spending, indirect spending (such as the additional costs of cleaning supplies for a hotel operator) and the increase in the overall local economy due to the added income by all the above , known as an induced effect. The results of river tourism are expressed in the report as output (equivalent to all sales directly related to recreation users) = $34.3 mill ion, value added (describes net revenue by reported firms) = $19.2 million , earnings (amount paid out to employees) =$8.3 million and employment = 387 jobs. This output amount represents 12.5% of Comal Country’s total travel and tourism economic impact for 2006. In terms of tax revenue, it is based on revenue from categories with a defined tax rate, such as lodging and the additional tax of indirect services and goods, and the spending of local workers who benefit from the need of additional services due to tourism. For 2006 in Comal County , it wa s estimated that river recreation users contributed $630,270 to lodging taxes and $230,435 to sales taxes, totaling $860,70 5. While the study recognizes the attra ction of the rivers and lakes are the driving force behind tourism in Comal County , it also notes that other aspects of tourism have great potential and that all growth will be synergistically beneficial to C omal County as a whole . Greater New Bra unfels Economic Development Foundation, prepared by Impact Data Source. ‘The Economic Impact of New Braunfels’ Hospitality Industry 2009’ This report is derived from information available from the City of New Braunfels sales tax collections for the year 20 09, and US government data sources, including US Census Bureau’s Business and Industry Economic Census and NAICS (North American Industry Classification System) standard ratios . It is important to note that taxable sales do not represent the total economi c output for the hospitality industry since not all economic output is taxed by the city; this then is adjusted for by analyzing the various tax types (hotel occupancy, mixed beverage). Direct and indirect economic output in terms of employment and earning s is calculated based on census and NAICS ratios.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 72 Based on the information above, the hospitality industry yielded $469. 6 million (direct and indirect sales, induced spending) in 2009. This amount includes various taxes ( sales, hotel occupancy , beverage ) totaling $12.8 million to the city of New Braunfels alone, with a total of $16 million to all local taxing authorities. $12.8 million represents 1 9% of the city’s total revenue and almost 22% of all sales tax revenue for the city. $469. 7 million is the total hospitality economic output in New Braunfels which represents almost 20% of the total economic activity in New Braunfels. Of that dollar amount : 48% can be attributed to direct economic impacts 52% to indirect or spin off economic i mpacts by subcategory: 65% restaurants/ eating establishments 19% entertainment 15% lodging 1% transportation $70.3 million w as paid in wages to those 5,181 people working directly in the hospitality industry and $51.5 million was paid to those 1,798 pe ople working in indirect jobs that support the hospitality industry. The number of jobs represents 27% of the employment in New Braunfels. Similar to hospitality representing approximately 20% of the economic output of New Braunfels, job earnings represented 19% of the total earnings in New Braunfels. In addition to providing jobs and revenue to the city, the hospitality industry has a philanthropic component and is reported to have contributed more $722,000 in cash donations, scholarships and in kind cha ritable donations in 2009. Growth The growth in economic output by the hospitality industry showed a steady increase over the years 2005 through 2009, with an annual growth rate of more than 6%. The growth in workers’ earnings grew 37% in the same period of time and employment grew by 32%

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 73 Visitors The report states o ver 200,000 people participated in water recreation in the Comal and Guadalupe Rivers in 2009, yielding over $300,000 in river management fees to the City of New Braunfels. The civic and convention center expanded in 2007 2008. In 2008, approximately 65,000 people attended more than 380 meetings, celebrations, performances, conferences and trade shows, yielding a $232,000 in revenue in their fiscal year with project ed revenue of $350,000 for the 2009 2010 fiscal year. Lodging in the city increased by 4 hotels in 2009, contributing $2.2 million in hotel occupancy taxes. In addition to this economic contribution, construction jobs were created and local sales taxes wer e increased; cost of construction projects was estimated at more than $21 million. Hotel rooms in the city in 2009 increased to 2,400 rooms. Wurstfest is a fall event that pays homage to the city’s German heritage; it had over 100,000 visitors and yielded over $3 million in 2009. Other events are scheduled at the same time to maximize the draw of visitors to shop, stay and dine. B. San Marcos Total number of visitors to San Marcos annually is estimated to be 10 million and is derived from traffic counts from the outlet malls; it is not a scientifically based number but is commonly quoted. Information f rom the unpublished dissertation of Texas State University Ph. D candidate Jenna Winters, a 2008 survey of 717 visitors to the San Marcos River was conducted; the following spending was reported: 75% spent less than $25 13% spent between $25 $50 6% spent between $50 $75 7% spent >$100 Based on her survey, 16% of visitors were tubing and that approximately 50% of these tubers rented their tubes . From San Marcos Lions Club Tube Rentals numbers of year 2005 (approximately 30,000) , we extrapolate the total number of visitors to the river to be in the realm of 375,000 people.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 74 Based on the percentages of dollars spent, we also extrapolate the revenue from river visitors to be in the order of $12.9 million. ( This amount does not account for any change in number of tube users between 2005 and 200 8) So although we estimate 375,000, the Greater San Marcos Economic Development Council in year 2000 estimated 500,000 annually visit the San Marcos River for water based recreation and civic activities adjacent to its banks ( Earl & Wood art. ‘Upstream Changes and Downstream Effects of the San Marcos River of Central Texas, February 2002). There is no documentation on the number of river visitors during the period from Memorial weekend to Labor Day, nor is there any data available for revenue generated by tourist activity during that same period . As of Jul y 15, 2010 , The total number of booked/contracted and actual (JanJuly) events for 2010 was 780 events (this includes groups from 3 to 3,000) for an estimated total attendance of 70,393. The average attendance number per event is 90 persons . 84 conference s have been booked between May 2010 and December 2010 with 14,470 rooms dedicated. . ( quotation: Ramirez, San Marcos Convention and Visitor Bureau , July, 2010 ). Approximately 2 ,500 canoes and kayaks ( TeGrotenhuis, TG canoes and kayaks , June 2 010 ) are rented out annually and almost 30,000 tubes were rented out in the year 2005 (Fairchild, Lions Club). It is estimated from survey information (Winters, TSU, July 2008 data) that tube rentals represent only about 50% of tubers on the river. No oth er data was provided and t here is no data on total number of boats on the river annually ;

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 75 VIII. RECREATION AL IMPACTS & FURTHER STUDY A. New Braunfels From stakeholder interviews, public parks are the predominant locations for access to the Comal River. Landa Park, as expressed by one interviewee, is felt to be at or beyond capacity as evidenced by the compaction and erosion along the banks of Landa Lake from foot traffic as well as from deterioration of vegetation caused by the foot traffic . The sentiment of general wear on the landscape was reported by a majority of the interviewees. Litter and negative behavior were also cited by stakeholders as on going issues due to recreation. In the more active recreation areas of the river, access is concentrated in various locations such as at Landa Falls, and downstream at various points along Hinman Island and Prince Solms Park and the public exit at Union Avenue. The river banks along these parks have mostly been reconstructed so erosion of the banks are not as much an issue in these areas, however, the limited availability of picnicking makes them most vulnera ble to both t he behavioral and litter issues, as well as overcrowding, which impedes access and egress to the river and continues to damage the vegetation and increases erosion. In spite of these social issues, stakeholders held the value of the river in high regard , citing environmental stewardship, economics and mental and physical rejuvenation as benefits. Quantitative information from weekly monitoring activities of the Texas Master Naturalist volunteers between 2006 and 2009 inclusive (Bio West for Edwards Aquifer Authority, March 2010a) provide insight into optimum habitat variables for the listed species. This report provides a good basis from which to observe how recreation affects these variables. As for reported direct effects, it appears that paddle boats on Landa Lake contribute to the reduction of both exotic and native vegetation (Bio West for Edwards Aquifer, August 2007) which would both reduce the physical habitat of fountain darters as well as affect the amount of carbon dioxide in the w ater. Sedimentation and turbidity , which are both affected by recreation users , may also affect listed species albeit on a short term basis, but most significantly, as a result of low flow and shallow water depths, enabling water recreation enthusiasts to access more of the stream bed (Bio West for Edwards Aquifer, August 2007) . Tubing is reported to be the most popular activity within the water with swimming, fishing as other common activities and rope jumping and

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 76 swift water rescue as seemingly less comm on activities. Along the banks, picnicking and wading and water lounging are activities that one could expect to affect the river. All these activities have varying degrees of direct physical contact/disturbance to the stream bed/bank and thereby affect th e river in terms of turbidity but to what degree these activities affect sedimentation (through erosion of banks) and water quality was not precisely found, although water quality data is available for various parts of the river at various times of the yea r (Bio West for Edwards Aquifer Authority, March 2010). In the Comal Springs system, recreation occurs mostly downstream of the confluence of the Old Channel and Landa Lake, where salamanders and macro invertebrate species populations remain stable (BioWe st for Edwards Aquifer Authority, August 2007) and higher quality habitat exists for the fountain darters ( Edwards Aquifer Authority, December 2009) and thus the recreation along these downstream stretches are not of great concern (Edwards Aquifer Authori ty, December 2009). The salamander and macro invertebrate species were mostly found within the springs or near the springs and the fountain darters were found to be most populous in native Cabomba vegetation found in the deeper waters in the upper reaches of the Comal Springs system including Landa Lake (Bio West for Edwards Aquifer Authority, March 2010a). Where more careful monitoring of recreation could take place then is within Landa Lake and all areas upstream as these areas are noted to be quality hab itat (Edwards Aquifer Authority, December 2009). As there are so many variables (nutrient levels, pH level, dissolved oxygen, carbon dioxide, temperature, sediment, flow, water depth, time of year, pollutant infiltration, herbivory, precipitation) that c an affect listed species populations, it may be challenging to directly link any one source of species disruption. In so far as water based recreation is seen as a cause for concern, it may be helpful to more closely examine the quality habitat areas (upper reaches of the Comal Springs system) and document the following at various times of the year for several cycles to augment other data that exists: Types of recreation (and direct physical contact with banks and stream channel) Number of users Documentati on of pollutants and nonnative species (organisms, plants and vertebrates) Water level s within the river channels Turbidity levels associated with specific recreation types Water quality: temperature, pH, nutrient levels Current flow

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 77 Precipitation Substrate composition and changes in sedimentation in the riverbed Bank condition / geology / vegetation At the same time, it would be useful to continue to: Map locations of species found Document habitat conditions Document life cycle stage of specimens B. San Marcos As reported by stakeholders, recreation activity along the San Marcos River is concentrated between Sewell Park on the Texas State University (TSU) campus and Rio Vista Park. This stretch of river is almost completely lined with public park lands with the exception of one residential area on the north bank. As such, much of this stretch of river is accessible except where riparian vegetation creates an obstacle. From interviewing stakeholders, prime bank activity occurs at Sewell Park, City Park and Rio Vista Park, where people mostly picnic, socialize and access the river with tubes or for swimming. The banks along Sewell Park and City Park are, for the most part, walled with concrete so access in these areas is by ladder or steps. Ero sion of the banks is not necessarily a concern in these parts of the river, but erosion of stream bank vegetation within the parks is a concern, along with a concern about d isturbance to the stream bottom (Bio West for Edwards Aquifer Authority, March 2010 b) where people tend to congregate not far from their picnic sites. Where there are no concrete walls there is evidence of trampled vegetation and eroded ground cover (Winters, 2010, unpublished). City of San Marcos park staff indicated river bank erosio n issues . The City currently has begun a river bank stabilization project that occurs between Rio Vista falls and Interstate Highway 35. City representatives reported that their community parks master plan aims to provide controlled access points to the ri ver (by planting native riparian vegetation) in an effort to protect their parks and banks from further erosion. The overall sentiment from the various stakeholders is that even though these river side parks provide an opportunity for environmental stewardship and education, an economic resource and a source of mental and physical rejuvenation , the parks (and associated river banks) are experiencing a

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 78 noticeable degradation of landscape through trampling of vegetation, erosion, pollution and lit ter by the park users themselves. An economic study in the year 2000 indicated 500,000 river recreation users come to the City on an annual basis (Greater San Marcos Economic Council, 2000). There was no other published information found in this regard. A doctoral research candidate at Texas State University who is currently studying recreation on the river, provided one account of 1,756 users on/in the river during a peak 2 hour period of time on one summer holiday Monday (peak season, but not necessarily a peak da y) in 2007. Over the course of a 3 year period in which this student has been working, she also documented precipitation rates and dates , turbidity , levels of the water, and also prepared a user survey with more than 700 participants over the course of a three year research project . The s urvey of park users (along the San Marcos River) indicated that 33% stated swimming as their primary activity and 16% stated tubing as their primary activity with an overall of 57% reporting their primary activity was some type of recreation in or on the water. Other than this unpublished data, and information gathered from stakeholders, we found no other specific information on numbers, types of users nor specific locations for San Marcos users was identified. Recreati on posed the most direct and indirect effect on Texas wild rice (Bio West for Edwards Aquifer Authority, March 2010b) with mechanical disturbance (by pulling, walking. wading) and in so doing, indirectly affecting fountain darters by compromising this habi tat. Data documenting changes in Texas wild rice stands, along with corresponding flow and water levels quantifies the observation of deterioration and fragmentation of Texas wild rice stands by recreation in the San Marcos River (Bio West for Edwards Aqui fer Authority, August 2007). Correspondingly, population dynamics and habitat conditions were examined for each of the listed species. The overall conclusions were that salamander species and fountain darter populations were stable while invertebrate pop ulations fluctuated (without conclusive factors) for the period between 2000 and 2007 inclusive, while the range of the Comal Spring riffle beetle expanded ( Bio West for Edwards Aquifer Authority, August 2007) . However, in looking more closely at populatio n relationships with recreation activity, drought and corresponding low water levels in year 2006 provided greater opportunities for recreation and physical contact with the riverbed and in so doing, habitats of fountain darters (aquatic

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 79 vegetation and namely, Texas wild rice) and salamanders were directly adversely affected by increased recreation activity. Reasons cited for the overall stable trend in listed species populations are due to various factors of spring flow, precipitation events (making the sa lamander habitat spillway at Spring Lake Dam less accessible) and likely most significantly, the sanctifying and restriction of recreation use of Spring Lake, helping preserve quality habitat (characterized by certain vegetation types and low velocities) f or namely fountain darters whose reproductive numbers help offset diminished numbers downstream (Bio West for Edwards Aquifer Authority, August 2007). In efforts to more closely examine the correlation between river recreation and listed species habitats, it may be of interest to investigate and document a comparison of river environment and habitat factors between Spring Lake and points between Sewell Park and Rio Vista Park wh ere most recreation occurs . Factors to evaluate include t emperature , current Fl ow , w ater depth , w ater quality: pH, nutrient levels , v egetation , b ank condition , t urbidity levels associated with various activities , s ubstrate composition and changes in the riverbed , n umbers and types of recreation users and documentation of pollutants and nonnative species (organisms, plants and vertebrates) . It would also be prudent to record this data over a course of several seasons and for any critical events (such as flood or high precipitation, hazardous spills etc.).

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 80 CONCLUSION It is clear that the delicate balance of society’s needs for recreating while maintaining a healthy perpetually viable natural e nvironment will become more of a challenge with time as population increases create growing demands on these spring and river resources. Whil e there a re definitive observation s that recreation al activity is adversely affecting the river environment, there is an apparent lack of raw data that could lead to a conclusive threshold of numbers and types of recreation al activities in which populations of endangered and threatened species are critically compromised. Studies reviewed and data collected suggest recreational activities put great pressure on species habitat . With the exception of the unpublished data of Winters and the inaccessible Breslin and Bradsby stud ies , v ery little information was found that specifically evaluated recreation as a source of species habitat disruption. In studies about water flow and it s affects on species, recreational activities w ere observed as a consequential impa ct . In studies about Texas wild rice, low current flow, r esulting recreational activities and opportunities were noted to be factors affecting the wild rice populations. To be conclusive about the impacts recreational activities have on listed species and habitats , a study that is focused on the effects of recreational activities should be conducted . Using w ater quality data taken from locations where habitats supported the highest populations as a basis , one could compare the same factors where recreation activity actually occurs or immediately downstream from where recreation activity occurs. Type and intensity of recreation use and physical contact , and resulting changes within the banks and river bed would need to be documented, measured and evaluated . F rom stakeholder interviews, crow d ing, litter and alcohol are top issues . Beyond the wear and tear human activities cause on the landscape , including riverbed disruption (and resulting turbidity ) from shear numbers, h umans contribute all kinds of pollutants to these rivers via food, alcohol (excrement , vomit and urine) and lotions worn on the skin . These rivers offer unique and highly valued recreation opportunities and as the population of Central Texas grows, recreational users will undoubtedly correspond ingly increase . Although the upper reaches of each of these springs are restricted in terms of recreation, it should be determined if these areas are adequate in cultivating the growth or at least stabilizing the listed species populations. The question s o f adverse and beneficial attributes (of recreation) and thresh old and capacity (of recreation users) remain to be determined.

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 81 BIBLIOGRAPHY Bowles, David E,. and Arsuffi , Thomas L. Karst aquatic ecosystems of the Edwards Plateau region of central Texas, USA: A consideration of their importance, threats to their existence, and efforts for their conservation. 28 Jun 2006 (on line publication), from Aquatic Conservation: Marine and Freshwater Ecosystems: Special Issue: Endangered Aquatic Habitats A Symposiu m of the Entromological Society of America December 1992 Volume 3, Issue 4, pages 317 329, December 1993 John Wiley & Sons, Ltd 1993 Bradsby, D.D. 1994. A Recreational Use Survey of the San Marcos River . MS Thesis, Southwest Texas State University, San M arcos, Tx 82pp. Breslin, S.L. 1997. The impact of recreation on Texas wild rice . MS Thesis, Southwest Texas State University, San Marcos, Tx. 69pp. Bussemey, Michelle, Analysis of Landscape Change of the Rio Vista Dam in San Marcos, Texas . MS Thesis, Texas State University, San Marcos, Texas, 2007 Edwards Aquifer Authority. ‘Comprehensive and Critical Period Monitoring Program to Evaluate the Effects of Variable Flow on Biological Resources in the Comal Springs/River Aquatic Ecosystem Final 2009 Annual R eport’ . BIO WEST Inc. March 2010 City of San Marcos Habitat Conservation Plan (Draft) Comal County, Texas and Comal County Commissioners Court. Comal County Regional Habitat Conservation Plan . April 2010 Comal County, Texas and Comal County Commissioners Court. Comal County Regional Habitat Conservation Plan Environmental Impact Statement . April 2010 Earl, Richard A. and Wood, Charles R. ‘Upstream Changes and Downstream Effects of the San Marcos River of Central Texas’ . The Texas Journal of Science February 2002 GCAGS Transactions Volume 48 (1998) Gramann, James H. Toward a behavioral theory of crowding in outdoor recreation: An evaluation and synthesis of research Greater New Braunfels Economic Development Foundation, prepared by Impact Data Sou rce. ‘The Economic Impact of New Braunfels’ Hospitality Industry 2009’

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 82 ‘The Impact of Tourism in Comal County’, TXP, Inc. December 2007 Kuss, FR | Graefe, AR Effects of recreation trampling on natural area vegetation. Journal of Le isure Research [J. LEISURE RES.] . Vol. 17, no. 3, pp. 165 183. 1985. Owens, Chetta S., John D. Madsen, R. Michael Smart and Michael Stewart Dispersal of Native and Nonnative Aquatic Plant Species in the San Marcos River, Texas Newsome, David. Moore, Sus an A.. Dowling, Ross Kingston. Natural Area Tourism, ecology, impacts and management. Channel View Publications, 2002. Winters, Jenna. Texas State University Doctoral Study of San Marcos River between Sewell Park and Rio Vista Falls . u npublished data from 2007 2009 USFWS, Summary of 2009 sampling efforts related to Edwards Aquifer Authority Variable Flow Study under USFWS permit number TE037155 -0 , 2009

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 83 Appendix A: GIS Mapping Exhibits

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas Recreation Areas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course TubingMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.1Parks Island

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas Recreation Areas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course Paddle BoatsMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.2Parks Island

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course Picnic Areas, RV CampgroundsMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.9Parks IslandRecreation Areas

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas Recreation Areas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course Swift Water Rescue TrainingMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.4Parks Island

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas Recreation Areas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course SwimmingMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.5Parks Island

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Texas Water Recreation District #1 Paddle Boat Rental Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek Comal Tubes Texas Tubes Landa Falls Schliterbahn Schliterbahn Corner Tubes Rock'n R Rides R B's Tube Rental Felger Tube Rental Other Place Tube Rentals Paddle Boat Rental Landa RV Park and Campgrounds 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas AVO 27520OCT 2010 Schliterbahn Landa Park Golf Course Tube, Paddle Boat, Kayak, Canoe RentalsMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman Tube Rental Locations NB.6 IslandRecreation Areas Paddle Boat, Kayak, Canoe Rental Locations

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas Recreation Areas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course FishingMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.7Parks Island

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course Wading, Lounging, Playing, Rope SwingMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.8Parks IslandRecreation Areas

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Recreation Areas New Braunfels Comal County, Texas Recreation Areas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course All UsesMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.9Parks Island

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Potential Wildlife Habitat New Braunfels Comal County, Texas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course Comal Springs Dryopid Beetle, Peck's Cave AmphipodMap Key Area of Potential Habitat Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.10Parks IslandPotential Wildlife Habitat

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Potential Wildlife Habitat New Braunfels Comal County, Texas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course Comal Springs Riffle BeetleMap Key Area of Potential Habitat Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.11Parks IslandPotential Wildlife Habitat

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Fair Park Park Prince Solms Park Cypress Bend Park Park Lamar Park Park Comal River Guadalupe River Dry Comal Creek 0 1,100 550 FeetEARIP Potential Wildlife Habitat New Braunfels Comal County, Texas AVO 27520OCT 2010 Schliterbahn Schliterbahn Landa Park Golf Course Fountain DarterMap Key Area of Potential Habitat Landa Park Hinman TCEQ Clean Rivers Water Quality Stations NB.12Parks IslandPotential Wildlife Habitat

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Sessom Greenspace Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Recreation Areas San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Recreation AreasTubing Spring Lake TSU Sewell ParkSM.1Map Key ENTRY_EXIT Entry/Exit Area Recreation Area TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Sessom Greenspace Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Recreation Areas San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Recreation AreasFishing Spring Lake TSU Sewell ParkSM.2Map Key ENTRY_EXIT Entry/Exit Area Recreation Area TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Sessom Greenspace Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Recreation Areas San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Recreation AreasKayaking, Canoeing Spring Lake TSU Sewell ParkSM.3Map Key ENTRY_EXIT Entry/Exit Area Recreation Area TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Sessom Greenspace Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Recreation Areas San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Recreation AreasPicnicking Spring Lake TSU Sewell ParkSM.3Map Key ENTRY_EXIT Entry/Exit Area Recreation Area TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Sessom Greenspace Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Recreation Areas San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Recreation AreasSwimming Spring Lake TSU Sewell ParkSM.5Map Key ENTRY_EXIT Entry/Exit Area Recreation Area TCEQ Clean Rivers Water Quality Stations Parks

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San Marcos River Purgatory Creek Willow Springs Creek Power Olympic Outdoor Center TG Canoes and Kayaks Lions Club Tube Rental EARIP Recreation Areas San Marcos Hays County, Texas 02,000 1,000 Feet AVO 27520 OCT. 2010Recreation AreasTube, Kayak, Canoe Rental LocationsMap Key ENTRY_EXIT Entry/Exit Area Recreation Area Tube Rental Location Kayak, Canoe Rental Locations Aquarena Nature Center ToursSM.6

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Sessom Greenspace Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Recreation Areas San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Recreation AreasDog Parks Spring Lake TSU Sewell ParkSM.7Map Key ENTRY_EXIT Entry/Exit Area Recreation Area TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Sessom Greenspace Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Recreation Areas San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Recreation AreasWading, Lounging Spring Lake TSU Sewell ParkSM.8Map Key ENTRY_EXIT Entry/Exit Area Recreation Area TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Sessom Greenspace Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Recreation Areas San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Recreation AreasAll Uses Spring Lake TSU Sewell ParkSM.9Map Key ENTRY_EXIT Entry/Exit Area Recreation Area TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Potential Wildlife Habitat San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Potential Wildlife HabitatFountain Darter Spring Lake TSU Sewell ParkSM.10 Map Key Area of Potential Habitat TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Potential Wildlife Habitat San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Potential Wildlife HabitatSan Marcos Gambusia Spring Lake TSU Sewell ParkSM.11 Map Key Area of Potential Habitat TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Potential Wildlife Habitat San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Potential Wildlife HabitatSan Marcos Salamander, Texas Blind Salamander, Comal Springs Riffle Beetle Spring Lake TSU Sewell ParkSM.12 Map Key Area of Potential Habitat TCEQ Clean Rivers Water Quality Stations Parks

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H.E.B. Park San Marcos River Purgatory Creek Willow Springs Creek WWTP City Park (New Treatment Plant) Rio Vista Park Ramon Lucio Park Memorial Park Crook Park/ SM Wildlife Children's Park Veterans Park Bicentennial Park Stokes Park San Marcos Plaza Veramendi Plaza Veterans Plaza Victory Gardens Park Broadway Park Swift Memorial Park A. E. Wood ( San Marcos ) EARIP Potential Wildlife Habitat San Marcos Hays County, Texas 0 1,000 500 Feet AVO 27520 OCT. 2010Potential Wildlife HabitatTexas Wild-rice Spring Lake TSU Sewell ParkSM.13 Map Key Area of Potential Habitat TCEQ Clean Rivers Water Quality Stations Parks

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 APPENDIX B: EARIP Interviews 6/30/2010 NEW BRAUNFELS

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 APPENDIX B: EARIP Interviews 6/30/2010 NEW BRAUNFELS

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 APPENDIX B: EARIP Interviews 6/30/2010 NEW BRAUNFELS

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 APPENDIX B: EARIP Interviews 6/30/2010 NEW BRAUNFELS

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 APPENDIX C: EARIP Interviews 6/29 /2010 SAN MARCOS

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 APPENDIX C: EARIP Interviews 6/29 /2010 SAN MARCOS

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 APPENDIX C: EARIP Interviews 6/29 /2010 SAN MARCOS

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 APPENDIX C: EARIP Interviews 6/29 /2010 SAN MARCOS

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems November 2010 Page 84 Appendix D : USGS Water Quality Assessment of the Comal Springs Riverine System, New Branfels, Texas, 1993 94

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U.S. Department of the InteriorU.S. Geological Survey98 07’o98 07’30"o98 08’o29 43’o29 42’30"o29 42’o RIVE RGUADALUP EGUADALUP ERIVE RRIVERCOMALDryComalCre ekOldChannelNewChannelBl iedersCreekLANDALA K EPanther Creek NEW BRAUNFELS NEW BRAUNFELSLandaSeguin StreetSanHinmanIslandDr iveTorrey Street N. Union Ave.StreetAntonio St.Landa ParkLandaPar k DriveElizabethAve. Clemens Dam B A C D E 08169000Other springs in Landa LakeMain spring 0 0.10.20.30.40.5 MILE Base from U. S. Geological SurveyTEXASSanWater-quality monitoring and U.S. Geological SurveyEXPLANATION New Braunfels and 08169000AustinAAntonio New Braunfels East; New Braunfels WestComal Springs of Central Texas are the largest springs in the southwestern United States. The long-term average flow of the Comal River, which essentially is the flow from Comal Springs, is 284 cubic feet per second (ft3/s). The artesian springs emerge at the base of an escarpment formed by the Comal Springs fault. The Comal River (fig. 1) is approximately 2 miles (mi) long and is a tributary of the Guadalupe River. Most of the Comal River follows the path of an old mill race, here referred to as New Channel, then flows through a channel carved by a tributary stream (Dry Comal Creek), eventually rejoining its original watercourse. The original watercourse, here referred to as Old Channel, has been reduced to a small stream, the source of which is water diverted from Landa Lake and several springs in the channel. In addition to being an important economic resource of the region, the springs and associated river system are home to unique aquatic species such as the endangered fountain darter (Etheostoma fonticola). The Comal Springs riffle beetle ( Heterelmis comalensis ), which exists in the springflow channel upstream of Landa Lake, has been proposed for listing as endangered. The Comal Springs dryopid beetle ( Stygoparmus comalensis ) and the Peck’s cave amphipod ( Stygobromus pecki) are two subterranean species associated with Comal Springs also proposed for endangered listing. The population in the region has increased 20 to 30 percent per decade for the last 3 decades. This increase in population has correspondingly increased the use of both surfaceand ground-Water-Quality Assessment of the Comal Springs Riverine System, New Braunfels, Texas, 1993–94water resources in the region, which in turn has prompted concern for habitats of endangered species that depend on the spring water. To better understand the environmental needs of threatened or endangered species, the U.S. Fish and Wildlife Service (USFWS) undertook an intensive ecological assessment of the Comal Springs riverine system. One component of the study involved the effects of varied springflows on water chemistry and aquatic-species habitat in the riverine system. For that study component, the U.S. Geological Survey (USGS) provided continuous monitoring of selected water-quality properties and collected discrete water samples for analysis at selected sites along the Comal Springs riverine system. The purpose of this fact sheet is to summarize the principal results of the USGS water-quality monitoring, sampling, and analyses for selected properties, major ions, nutrients, trace elements, and pesticides during selected periods in the summer and winter of 1993 – 94. Only high flow (greater than 300 ft3/s) occurred during the monitoring periods; therefore, effects of lesser flows on water quality were not measured. Data collected from this study and subsequent monitoring Figure 1. Comal Springs riverine system, New Braunfels, Texas.Comal Springsstreamflow-gaging station and number sampling site and site ID Spring

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2can be used to evaluate instream flow habitat requirements of the fountain darter and other aquatic species. During the monitoring periods, the New Channel received approximately 92 percent of the total volume of springflow by way of Landa Lake. New Channel has a uniform stream channel and higher velocities than Old Channel. In the upper reach of New Channel, west of Landa Park Drive, stream velocities are lowest and the bottom is predominantly large gravel and cobbles. In the lower reach, from Landa Park Drive to Clemens Dam, the velocities are highest and the streambed predominantly is bedrock and large gravel. In contrast, Old Channel received about 8 percent of the total volume of springflow. Old Channel has the meandering characteristics of a natural stream. In the upper reach of Old Channel, from Landa Lake to Elizabeth Avenue, are intermittent riffles and pools and a streambed of silt and assorted gravels. Downstream of Elizabeth Avenue, the stream mostly comprises slow runs and pools with very little riffle habitat; water velocities are minimal and the water appears turbid. The streambed is mostly coarse sediment and mud.Collection of Water-Quality DataSite selection and data collection were designed to evaluate physical and chemical properties of the riverine system. Five sites were selected for monitoring the upper and lower reaches of the two stream channels. These sites were evaluated to ensure uniform mixing of water and that monitoring points were representative of the sites. Two sites were selected on New Channel. Site A is at the Landa Lake outfall into New Channel. This site represents the start of the riverine system and a composite of the spring-fed lake waters. Site B is immediately upstream of the confluence of Old and New Channels. This site was selected to monitor changes to water chemistry that might have occurred as water passed through New Channel. Within Old Channel, two sites also were selected. Site C is immediately upstream of Elizabeth Avenue and represents a composite of spring-fed lake water as it enters Old Channel. Site D is on Old Channel upstream of Hinman Island Drive and the confluence of Old and New Channels. Data from site E, downstream of the confluence of the two channels and on the Comal River immediately upstream of Clemens Dam, represent the cumulative effects of Old and New Channels. The properties of pH, temperature, specific conductance, and dissolved oxygen were monitored continuously during selected periods in the summer and winter of 1993 – 94. Continuous monitoring of water properties required use of a four-parameter monitoring probe, which was connected to a data storage device and powered by a solar battery. The sites are inaccessible and required use of portable, self-contained floating shelters. To ensure data quality, the instruments were calibrated before and periodically during operation. Monitors measured and logged parameters at 30-minute intervals for periods of 3 to 8 weeks, depending on the site. Property data at the New Channel sites were monitored in the summer from August 20 to September 20, 1993, and in the winter from January 4 to February 3, 1994. Property data at the Old Channel sites were monitored in the summer from June 30 to August 18, 1993, and in the winter from Figure 2. Daily mean streamflow, Comal River at New Braunfels, Texas, during water-quality monitoring periods, 1993– 94. 30 5 10 15 20 25 31 5 10 15 20 25 31 5 10 15 20 July August September 1993 320 440 320 340 360 380 400 420 5 10 15 20 25 31 5 10 15 20 25 28 January February 1994 300 440 300 320 340 360 380 400 420 STREAMFLOW, IN CUBIC FEET PER SECOND 4 MarchSummer WinterJune

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3Table 1. Water properties and major ion concentrations, Comal Springs riverine system, New Braunfels, Texas, 1993– 94 [ S/cm, microsiemens per centimeter at 25 C; C, degrees Celsius; mg/L, milligrams per liter; CaCO3, calcium carbonate; <, less than; NA, not available; ft3/s, cubic feet per second] 1 Daily mean flow, 08169000 Comal River at New Braunfels: 350 ft3/s 8/20/93, 339 ft3/s 9/20/93, 351 ft3/s 2/3/94, 337 ft3/s 3/3/94. Constituent New Channel Comal River1 Site A Site B Site E Summer (9/20/93) Winter (2/3/94) Summer (9/20/93) Winter (2/3/94) Summer (9/20/93) Winter (2/3/94) Specific conductance ( S/cm) 548 509 547 509 544 514 pH (standard units) 7.6 7.4 7.8 7.3 7.8 7.1 Temperature ( C) 24.0 23.0 24.0 22.5 24.5 22.0 Dissolved oxygen (mg/L) 7.2 8.2 9.0 9.5 9.0 9.4 Calcium, dissolved (mg/L) 83 82 81 82 80 82 Magnesium, dissolved (mg/L) 16 16 16 16 16 16 Sodium, dissolved (mg/L) 9.9 9.7 11 10 10 10 Potassium, dissolved (mg/L) .70 1.3 .70 1.3 .70 1.3 Alkalinity (mg/L as CaCO3) 230 230 230 230 240 230 Sulfate, dissolved (mg/L) 23 24 24 24 23 24 Chloride, dissolved (mg/L) 15 16 15 16 15 16 Fluoride, dissolved (mg/L) .20 .20 .20 .20 .20 .20 Silica, dissolved (mg/L) 12 11 12 11 12 11 Dissolved solids, sum of constituents (mg/L) 307 309 308 309 307 310 Constituent Old Channel Comal River1 Site C Site D Site E Summer (8/20/93) Winter (3/3/94) Summer (8/20/93) Winter (3/3/94) Summer (8/20/93) Winter (3/3/94) Specific conductance ( S/cm) 552 529 565 523 547 541 pH (standard units) 7.7 6.9 7.5 7.3 7.6 7.3 Temperature ( C) 24.0 21.5 25.5 20.5 26.0 23.0 Dissolved oxygen (mg/L) 8.1 11.4 4.4 11.8 9.2 12.0 Calcium, dissolved (mg/L) 83 82 85 81 84 81 Magnesium, dissolved (mg/L) 16 16 16 16 16 16 Sodium, dissolved (mg/L) 9.6 10 10 11 9.5 11 Potassium, dissolved (mg/L) 1.9 1.3 1.6 1.3 <.10 1.3 Alkalinity (mg/L as CaCO3) 230 240 240 240 230 240 Sulfate, dissolved (mg/L) 25 24 26 24 25 24 Chloride, dissolved (mg/L) 16 15 16 16 16 15 Fluoride, dissolved (mg/L) .30 .20 .20 .20 .20 .20 Silica, dissolved (mg/L) 12 12 11 10 12 11 Dissolved solids, sum of constituents (mg/L) 309 310 314 310 NA 309 February 7 to March 4, 1994. Property data at the Comal River site were monitored during all four periods. Periodic waterquality samples were collected at each of the five sites. Samples from New Channel and the Comal River were collected near the end of the monitoring periods on September 20, 1993, and February 3, 1994. Samples from Old Channel and the Comal River were collected on August 20, 1993, and March 3, 1994. Samples for major ions, nutrients, and trace elements were collected using a depthintegrated method at multiple intervals along the cross section, then composited. Samples for pesticides were collected using a depth-integrated method at a single interval at the midpoint of the stream.StreamflowContinuous streamflow data (fig. 2) were collected from USGS streamflow-gaging station 08169000 Comal River at New Braunfels during the water-quality monitoring periods. Initial daily mean streamflow of the Comal River for the summer monitoring period was 417 ft3/s on June 30, 1993, and ending streamflow was 339 ft3/s on Sept. 20, 1993. A peak flow of 419 ft3/s occurred on July 5, 1993, and a minimum flow of 338 ft3/s occurred on Sept. 7 and 8, 1993. Initial daily mean streamflow for the winter monitoring period was 353 ft3/s on January 4, 1994, and ending streamflow was 338 ft3/s on March 4, 1994. A peak flow of 357 ft3/s occurred on January 22 and 24, 1994, and a minimum flow of 337 ft3/s occurred on March 3, 1994.Water QualityWater Properties Boxplots summarize the distributions of continuously monitored water-property data at the five sites (fig. 3). In some instances, the median is the same as the 25th or 75th percentile. Data were edited to correct for instrument drift and to exclude instrument malfunction. The number of data values per property per site ranged from 1,054 to 2,644. For New Channel and Comal River, summer median specific conductance shows little variability along the reach, ranging from 547 to 551 microsiemens per centimeter at 25 C ( S/cm). Winter median specific conductance shows more variability than summer, ranging from 525 S/cm at site A to 551 S/cm at site E. Summer median pH increases downstream from 7.3 at site A to 7.6 at sites B and E. Similarly during winter, median pH increases from 7.2 to 7.5. Summer median water temperature increases downstream from 23.5 degrees Celsius ( C) at sites A and B to 23.7 C at site E.

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4 (1.163) (1,193) (1,222) (1,056) (2,344) (2,644) (1,362) (1,299) (1,456) 14 28 16 18 20 22 24 26 (1,480) (1,478) (1,499)SUMMER 1993 SUMMER 1993 WINTER 1994WINTER 1994 NEW CHANNEL AND COMAL RIVER OLD CHANNEL AND COMAL RIVER 7.0 8.4 7.2 7.4 7.6 7.8 8.0 8.2 (1,480) (1,478) (1,499)pH, IN (1,362) (1,313) (1,456) (1,056) (2,344) (2,644) (1,193) (1,215) (1,163)SPECIFIC CONDUCTANCE, IN AT 25 DEGREES CELSIUS MICROSIEMENS PER CENTIMETER (1,160) (1,214) (1,193) C D E (1,056) (1,910) (2,637) C D E (1,362) (1,302) (1,455) AB E SITE 0 15 5 10 (1,499) (1,478) (1,480)DISSOLVED OXYGEN, INA B EEXPLANATION 25th percentile Median (50th percentile) 75th percentile Number of measurements Minimum value Maximum value(1,193)Aug. 20 – Sept. 20 Jan. 4 – Feb. 3 June 30 – Aug. 18 Feb. 7 – Mar. 4Conversely, winter median water temperature decreases from 22.8 to 22.4 C. Summer median dissolved oxygen increases downstream from 5.8 milligrams per liter (mg/L) at site A to 8.5 mg/L at site B and subsequently decreases to 7.7 mg/L at site E. Figure 3. Distributions of specific conductance, pH, temperature, and dissolved oxygen, Comal Springs riverine system, New Braunfels, Texas, 1993 – 94.STANDARD UNITS TEMPERATURE, IN DEGREES CELSIUS MILLIGRAMS PER LITER (1,204) (1,193) (1,162) (2,640) (2,345) (1,054) 200 700 250 300 350 400 450 500 550 600 (1,496) (1,478) (1,483) (1,428) (1,298) (1,324)

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5Table 2. Nutrient concentrations, Comal Springs riverine system, New Braunfels, Texas, 1993– 94 [mg/L, milligrams per liter; NA, not available; <, less than; ft3/s, cubic feet per second] 1 Daily mean flow, 08169000 Comal River at New Braunfels: 350 ft3/s 8/20/93, 339 ft3/s 9/20/93, 351 ft3/s 2/3/94, 337 ft3/s 3/3/94. Constituent (mg/L) New Channel Comal River1 Site A Site B Site E Summer (9/20/93) Winter (2/3/94) Summer (9/20/93) Winter (2/3/94) Summer (9/20/93) Winter (2/3/94) Nitrogen, nitrate, dissolved NA 1.87 NA 1.87 NA 2.38 Nitrogen, nitrite, dissolved <0.010 .030 <0.010 .030 <0.010 .020 Nitrogen, ammonia, dissolved .030 .020 .030 .030 .030 .050 Nitrogen, organic, dissolved NA NA NA NA NA NA Phosphorus, dissolved <.010 <.010 <.010 <.010 <.010 <.010 Phosphorus, ortho, dissolved NA NA NA NA .03 NA Phosphate, ortho, dissolved (as P) <.010 <.010 <.010 <.010 .010 <.010 Constituent (mg/L) Old Channel Comal River1 Site C Site D Site E Summer (8/20/93) Winter (3/3/94) Summer (8/20/93) Winter (3/3/94) Summer (8/20/93) Winter (3/3/94) Nitrogen, nitrate, dissolved NA NA 1.39 NA NA NA Nitrogen, nitrite, dissolved <0.010 <0.010 .010 <0.010 <0.010 <0.010 Nitrogen, ammonia, dissolved .030 .020 .060 .030 .030 .010 Nitrogen, organic, dissolved NA NA NA 0.27 NA NA Phosphorus, dissolved <.010 .010 <.010 .050 <.010 .010 Phosphorus, ortho, dissolved .03 NA .06 NA .03 NA Phosphate, ortho, dissolved (as P) .010 <.010 .020 <.010 .010 <.010 Similarly, winter median dissolved oxygen increases from 6.2 mg/L at site A to 9.1 mg/L at site B, then decreases to 8.3 mg/L at site E. For Old Channel and Comal River, summer median specific conductance increases from 550 S/cm at site C to 562 S/cm at site D, then decreases to 549 S/cm at site E. Similarly, winter median specific conductance increases from 523 S/cm at site C to 540 S/cm at site D, then decreases to 517 S/cm at site E. Summer median pH increases downstream from 7.6 at site C to 7.8 at site D, then decreases to 7.4 at site E. Winter median pH is 7.7 at sites C and D and 7.5 at site E. Summer median temperature increases from 24.6 C at site C to 25.8 C at site D and subsequently decreases to 23.8 C at site E. Conversely, winter median temperature decreases from 21.4 C at site C to 19.7 C at site D, then increases to 22.7 C at site E. Summer median dissolved oxygen decreases from 6.6. mg/L at site C to 6.4 mg/L at site D and increases to 8.0 mg/L at site E. Winter median dissolved oxygen increases from 8.0 mg/L at site C to 10.2 mg/L at site E. In general, specific conductance, pH, temperature, and dissolved oxygen measured at the time of collection of discrete samples (table 1) fall within the range of measurements made by the continuous monitors. Major Ions Only slight variability in concentrations of major ions either along reaches or between seasons (along a reach) is observed for the periodic waterquality samples collected during high-flow conditions (table 1). For example, dissolved solids range from 307 to 309 mg/L for New Channel and from 309 to 314 mg/L for Old Channel. Nutrients Where measured, concentrations of nutrients and variations in concentrations (table 2) are small. For all sites, nitrate nitrogen concentrations range from 1.39 to 2.38 mg/L, nitrite nitrogen concentrations range from less than 0.010 to 0.030 mg/L, and ammonia concentrations range from 0.010 to 0.060 mg/L. Phosphorus concentrations range from less than 0.010 to 0.050 mg/L, orthophosphorus concentrations range from 0.03 to 0.06 mg/L, and orthophosphate concentrations range from less than 0.010 to 0.020 mg/L. Trace Elements Trace elements (table 3) show little variability in concentration either along the reaches or between seasons. Differences in concentrations between sites in the same reach and seasons are small, less than 5 micrograms per liter ( g/L), except for strontium in Old Channel, which decreases by 50 g/L from site D to site E in both seasons and increases by 50 g/L from summer to winter at site C. Concentrations of strontium (610 to 690 g/L) are 1 to 2 orders of magnitude larger than that of other trace elements. Trace elements for which analyses were below detection limits are beryllium (less than 0.5 g/L), cadmium (less than 1.0 g/L), chromium (less than 5 g/L), cobalt (less than 3 g/L), copper (less than 10 g/L), mercury (less than 0.1 g/L), molybdenum (less than 10 g/L), nickel (less than 10 g/L), silver (less than 10 g/L), and vanadium (less than 6 g/L). Pesticides Of 29 pesticides for which samples were analyzed (table 4) only diazinon was detected during the summer at sites D and E, in concentrations of 0.01 and 0.02 g/L, respectively.Selected ReferencesBrown, D.S., Petri, B.L., and Nalley, G.M., 1992, Compilation of hydrologic data for the Edwards aquifer, San Antonio area, Texas, 1991, with 1934– 91 summary: San Antonio, Edwards Underground Water District Bulletin 51, 169 p.

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6Table 3. Trace element concentrations, Comal Springs riverine system, New Braunfels, Texas, 1993– 94 [Constituents not detected include beryllium, cadmium, chromium, cobalt, copper, mercury, molybdenum, nickel, silver, and vanadium. g/L, micrograms per liter; <, less than; ft3/s, cubic feet per second] 1 Daily mean flow, 08169000 Comal River at New Braunfels: 350 ft3/s 8/20/93, 339 ft3/s 9/20/93, 351 ft3/s 2/3/94, 337 ft3/s 3/3/94. Constituent (g/L) New Channel Comal River1 Site A Site B Site E Summer (9/20/93) Winter (2/3/94) Summer (9/20/93) Winter (2/3/94) Summer (9/20/93) Winter (2/3/94) Arsenic, dissolved <1 <1 <1 <1 <1 <1 Barium, dissolved 51 51 52 51 52 51 Iron, dissolved <3 <3 <3 <3 3 <3 Lead, dissolved <10 <10 10 <10 <10 <10 Lithium, dissolved 7 6 8 6 7 7 Manganese, dissolved <1 <1 <1 <1 <1 <1 Selenium, dissolved 1 <1 1 <1 1 <1 Strontium, dissolved 610 610 620 620 610 620 Zinc, dissolved 3 <3 <3 5 <3 <3 Constituent (g/L) Old Channel Comal River1 Site C Site D Site E Summer (8/20/93) Winter (3/3/94) Summer (8/20/93) Winter (3/3/94) Summer (8/20/93) Winter (3/3/94) Arsenic, dissolved <1 2 <1 1 <1 1 Barium, dissolved 51 55 53 55 49 51 Iron, dissolved 3 <3 4 <3 <3 <3 Lead, dissolved <10 10 <10 10 <10 <10 Lithium, dissolved 12 8 13 8 12 8 Manganese, dissolved 2 2 5 4 <1 2 Selenium, dissolved <1 <1 <1 <1 <1 1 Strontium, dissolved 620 670 650 690 600 640 Zinc, dissolved 6 <3 4 <3 <3 5 Table 4. Pesticide concentrations, Comal Springs riverine system, New Braunfels, Texas, 1993 – 94 [ g/L, micrograms per liter; compound in bold was detected] Pesticide Detection limit ( g/L) PCB 0.1 Polychlorinated naphthalenes .10 Aldrin .010 Chlordane .1 DDD .010 DDE .010 DDT .010 Diazinon .01 Dieldrin .010 Disyston .01 Endosulfan .010 Endrin .010 Ethion .01 Heptachlor .010 Heptachlor epoxide .010 Lindane .010 Malathion .01 Methoxychlor .01 Methylparathion .01 Mirex .01 Parathion .01 Perthane .1 Phorate .01 Silvex .01 Toxaphene 1 Trithion .01 2,4-D .01 2,4-DP .01 2,4,5-T .01 Rothermal, S.R., and Ogden, A.E., 1987a, Hydrochemical investigation of the Comal and Hueco Springs systems, Comal County, Texas: Edwards Aquifer Research and Data Center Report R1 – 87, 182 p. ______1987b, Hydrochemical investigation of the Comal and Hueco Springs systems, Comal County, Texas: Edwards Aquifer Research and Data Center Report R2 – 86, 151 p. Wells, F.C., 1985, Statistical summary of water-quality data collected from selected wells and springs in the Edwards aquifer near San Antonio, Texas: U.S. Geological Survey Open-File Report 85– 182, 162 p. William F. Guyton and Associates, 1979, Geohydrology of Comal, San Marcos, and Hueco Springs: Texas Department of Water Resources Report 234, 85 p. —Lynne Fahlquist and R.N. Slattery Any use of trade, product, or firm names is for descriptive purposes only and does not imply endorsement by the U.S. Government. October 1997 Fact Sheet FS – 099– 97 U.S. DEPARTMENT OF THE INTERIOR U.S. GEOLOGICAL SURVEYInformation on technical reports and hydrologic data related to this and other studies can be obtained from:San Antonio Subdistrict Chief U.S. Geological Survey 435 Isom Road, Suite 234 San Antonio, Texas 78216 Phone: 210– 321– 5200 FAX: 210– 530– 6008 E-mail: gbozuna@usgs.gov World Wide Web: http://txwww.cr.usgs.gov/

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 84 Appendix E : Lodging Revenues New Braunfels Hot el / motel tax receipts (rate = 13%) full year 1st & 2nd Quarters 2005 $ 1,875,936.60 $1,424,537.30 2006 $ 1,991,734.20 $ 1,452,416.00 2007 $ 2,116,439.60 $ 1,458,819.80 2008 $ 2,319,141.70 $ 1,682,902.80 2009 $ 2,151,495.20 $ 1,548,257.20 San Marcos Hote l / motel taxes 2008 $ 1,698,905.00 2009 $ 2,030,247.00

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 85 Appendix F : R esponse to TWDB Comments

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 86

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 87

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 88

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 89

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Initial Study on the Recreational Impacts to Protected Species and Habitats in the Comal and San Marcos Springs Ecosystems N ovember 2010 Page 90


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