Protect the Coastal Bend’s Bays from Desalination

The City, Port of Corpus Christi, and other entities are proposing to build multiple desalination plants that will pump hundreds of millions of gallons of water out of the Coastal Bend's bays every day and discharge the concentrated brine back into the bays or nearshore Gulf waters. The cumulative impacts from these plants will be added to that of the existing desalination plant inside the Port's Inner Harbor. With barrier islands separating the bays from the Gulf, water exchange is limited and there will be little opportunity for the brine discharged into the bays to blend with a fresh supply of water. For example, Corpus Christi Bay is mostly enclosed and it takes about 1.5 years for the water in it to be exchanged. Meanwhile, the Laguna Madre is revered by fishermen. According to the National Park Service, it is "the most productive Texas bay fishery; currently, it is one of the best places for recreational fishing for red drum, black drum, and spotted sea trout in North America." Such a highly productive habitat merits special protections.

The Texas Commission on Environmental Quality (TCEQ) has not considered the possible cumulative impacts from multiple desalination plants inside the bays when reviewing the water rights and discharge permit applications for the plants, and their general approach and oversight of the permitting process has been called into question by officials at the EPA. People ranging from local residents to experienced marine biologists have expressed concerns about a variety of issues surrounding the proposed plants, including the high costs to construct and operate them, environmental justice issues and potential harm to fish, birds and other animals living in and around the bay. Scientists at Texas A&M University-Corpus Christi are concerned about the possible negative effects that multiple brine discharges may have on fish, shrimp and crab larvae, dolphins, bottom dwelling organisms and other aquatic life.

The Surfrider Foundation Texas Coastal Bend Chapter's position is that water conservation, reuse, repairs to infrastructure, and groundwater wells should be the first alternatives considered by the City of Corpus Christi or any other water providers when evaluating additional sources of water for the community and industry. After that, desalination of brackish groundwater and reuse of the salt byproduct or injection of the brine into a groundwater well should be the second option.

If the first options have been exhausted and desalination of bay or Gulf waters is to be undertaken, all intakes and brine discharge outfalls must be located in the Gulf in areas
identified by the Texas Parks and Wildlife Department and Texas General Land Office in
their Marine Seawater Desalination Diversion and Discharge Zones Study, 2018 - see
the second publication listed at tpwd.texas.gov/publications/landwater/water. As shown
on the maps on pages 21 and 23 of the study, the area near Corpus Christi Bay and the
Upper Laguna Madre begins 3 nautical miles off the coast. To arrive at this conclusion,
they considered the presence of marine organisms and protected areas, the proximity to
passes through the barrier islands, the bathymetry and the seasonal currents.

Moreover, precautions must be taken so that the placement and construction of any
facility pipelines crossing the bays and Gulf cause minimal disruption to habitats and
aquatic life. The facilities must also use the best available technology and appropriate
facilities siting so as to minimize the impacts of impingement and entrainment at their
intakes, and to avoid impacts to public beach access and/or the need for coastal
armoring. Finally, desalination facilities must utilize renewable energy sources such as
wind and solar power rather than energy sources that contribute to climate change.