REASONS TO OPPOSE THE CONSTRUCTION OF
MARVIN NICHOLS AND GEORGE PARKHOUSE RESERVOIRS

I. DAMAGE TO NORTHEAST TEXAS

The construction of Marvin Nichols Reservoir would flood 60,000 to 70,000 acres in Northeast Texas. The construction of George Parkhouse II Reservoir would flood another 12,000 to 17,000 acres. In addition to the approximate 80,000 taken from private landowners for the reservoirs, the Clean Water Act provides that additional acreage must be taken to mitigate the loss of fish and wildlife habitat caused by the flooding of these reservoirs. Attachment #1 illustrates an estimate of the mitigation requirements performed by the Texas Parks and Wildlife Department and the U.S. Fish and Wildlife Service, two of the entities that will be involved in the mitigation process. This joint study concluded that Marvin Nichols alone would require a minimum of 163,000 acres in mitigation land.

Although those in favor of building these reservoirs have stated that they will attempt to have the mitigated land taken from an area other than Northeast Texas, Corps of Engineer Guidelines as well as a written agreement between the Corps of Engineers and the Environmental Protection Agency state that the mitigated land will be as close to the flooded area as possible and should be taken from the same watershed.

Removing this land from production, whether it be timber production, farming or ranching, will have a tremendous negative impact to the economy in Northeast Texas and will result in a loss of jobs in our area. It will also remove this land from private ownership and result in a loss of tax base for our local governments and schools.

II. REGION C DOES NOT NEED THESE RESERVOIRS TO SATISFY ITS WATER REQUIREMENTS

Our regional water board (Region D) has stated that our region does not need to construct any additional reservoirs to satisfy our region's water needs for the next 50 years. Marvin Nichols and George Parkhouse are being recommended to supply Region C (Dallas/Fort Worth area) with additional water. Region C does not need these reservoirs if it would implement any of the following measures:

A. Conservation -- See Attachment #2 regarding Region C's lack of conservation and abuse of its water usage for municipal (residential) purposes. By agreeing to institute conservation measures over the next 50 years to enable Region C to bring its municipal water usage to the state average, Region C would save far more water than Marvin Nichols would ever supply.

B. Utilize Other Water Resources
..... 1. Lake Texoma
..... 2. Toledo Bend
..... 3. Oklahoma Water
..... 4. Mesa Ltd. Water
..... 5. Raise lake levels Region C already relies on for water supply
..... 6. Institute aggressive reuse of water as other cities have already done
..... 7. Desalination (See Attachment #3)

ATTACHMENT #1 -- MARVIN NICHOLS I RESERVOIR

Location: Sulphur River in Franklin, Titus, Morris, Bowie and Red River Counties. Dam site approximately 17 miles northeast of Mount Pleasant.

Normal Pool Elevation: 312 feet msl.
Type of Field Evaluation: WHAP
Date of Field Evaluation: 1986

[At this point in the document there is a chart which I'll edit a bit for this transcription. R.]

Acres Lost of Mixed Bottomland Hardwood Forest: 30,041. Accompanying Acres of Animal Habitat Units Lost: 24,333.
Acres Lost of Mixed Post Oak Forest: 15,469. Accompanying Acres of Habitat Units Lost: 9,745.
Acres Lost of Grasses: 12,723. Accompanying Acres of Habitat Units Lost: 5,344.
Other Acres Lost: 8,288. Total Acres Lost: 66,521.

Texas Parks & Wildlife Listed Endangered Species
* Black Bear
* Eskimo Curlew
* Bald Eagle
* Red-Cockaded Woodpecker
* Interior Least Tern
* Louisiana Pine Snake
* Paddlefish
* Shovelnose Sturgeon

Texas Parks & Wildlife Listed Threatened Species
* Rafinesque's Big-Eared Bat
* American Swallow-Tailed Kite
* Wood Stork
* Bachman's Sparrow
* White-Faced Ibis
* Artic Peregrine Falcon
* Texas Horned Lizard
* Timber Rattlesnake
* Northern Scarlet Snake
* Creek Chubsucker
* Blackside Darter
* Bluehead Shiner
* Blue Sucker

ATTACHMENT #2 -- MUNICIPAL WATER USAGES, REGION C

Pursuant to the attached page compiled from the State Water Plan, the average per capita water usage for all 16 regions in Texas excluding Region C is projected to be 151.45 gallons per person per day in the year 2050 (2271.75/15=151.45) Region C has the highest projected use of 200.12 gallons per day.

Region C projects a total population in the year 2050 of 9,481,157, an increase of 45% in population in 50 years. Even assuming those projections hold true, Region C would save 516,890 acre-feet per year if that Region would drop its municipal water level usage to the statewide average of 151.45 gallons per day.

Marvin Nichols I, according to Region C's Water Plan, will provide Region C with between 440,000 and 495,000 acre-feet per year of water. Requiring that Region C institute conservation measures that would bring it to the state average of municipal water usage would easily eliminate any supposed "necessity" for the building of Marvin Nichols I or any other reservoir on the Sulphur River to supply Region C with future water. It would also eliminate the flooding of approximately 80,000 acres in Northeast Texas, the mitigation acreage that would be required, and the negative impacts that the loss of these lands would have on the Northeast Texas economy, its environment and its tax base.

Formula To Determine Municipal Water Usage
Year 2050
Population Projection (per Region C Water Plan): 9,481,157
Municipal Water Usage (per Region C Water Plan): 2,125,330 acre-feet

2,125,330 (acre-feet) / 9,481,157 (population) = 0.224164 acre-feet of usage per year, per person
1 acre foot = 325,851 gallons
0.224164 X 325,851 = 73,044.06 gallons per year per person, Region C
73,044.06 / 365 = 200.12 gallons per person, per day for year 2050

Year 2050 -- Using Average Water Usage Throughout State

151.45 X 365 = 55,279.25 gallons per year usage on average statewide
55,279.25 / 325,851 = 0.169646 acre-feet of usage per year, per person
0.169646 X 9,481,157 (Region C population) = 1,608,440 acre-feet of municipal water usage using state average

Projected Water Usage Using Current Projections: 2,125,330 acre-feet
Projected Water Usage For Region C Using State Average: 1,608,440 acre-feet

Acre-Feet Of Municipal Water Usage Saved By Conservation: 516,890 acre-feet

[This is a larger saving by Conservation than the size of Marvin Nichols I Reservoir!

[Then there follows a table comparing water usage in all 16 Water Regions in the State of Texas, with data from the State Water Plan. Attachment #3 relates to Governor Rick Perry's recent comments about DESALINIZATION, also included at this website. R.]