City staff and various experts testified recently on behalf of the City of Granbury’s application to build a new Wastewater Treatment Plant (WWTP) at 3121 Old Granbury Road. The testimony was presented to State Office of Administrative Hearings judges (SOAH) as they consider a recommendation to the Texas Commission on Environmental Quality (TCEQ) for approving the City’s permit for a new wastewater treatment plant for the City’s east side.
 
TCEQ requires the City to begin planning to expand or construct new facilities when 75 percent of current capacity is achieved in three consecutive months. That happened in 2016, the same time planning for a new WWTP began. The City submitted a permit for the new WWTP in June 2020 and the permit and construction plans were administratively approved by the TCEQ. Since property owners near the proposed plant are against it, the TCEQ granted a contested case hearing and asked a SOAH judge to review the case and make a recommendation to them, prompting this week’s testimony.
 
Some of the most impactful testimony came from Dr. Ray Perryman, President and CEO of The Perryman Group. His firm has served the needs of more than 2,500 clients, including two-thirds of the Global 25, over half of the Fortune 100, the 12 largest technology firms in the world, 10 US Cabinet Departments, the 9 largest firms in the US, the 6 largest energy companies operating in the US, and the 5 largest US banking institutions.
 
As a foundation for his testimony, he gave an example of the most comprehensive measure of economic activity, “Total Expenditures.” Suppose a farmer sells wheat to a miller for $0.50; the miller then sells flour to a baker for $0.75; the baker, in turn, sells bread to a customer for $1.25. The Total Expenditures recorded in this instance would be $2.50, that is, $0.50 + $0.75 + $1.25. This measure is quite broad but is useful in that (1) it reflects the overall interplay of all industries in the economy, and (2) some key fiscal variables such as sales taxes are linked to aggregate spending.
 
Dr. Perryman’s complex modeling and analysis found “...the potential reduction in business activity associated with shortages in wastewater capacity was determined by examining the extent to which Granbury serves as a hub of support industries using standard ‘market share’ analysis and computing the direct losses relative to the baseline projections for Hood County during the relevant periods.”
 
Dr. Perryman determined that the Estimated Annual Impact Associated with Inadequate Wastewater Capacity to Support Anticipated Growth on Business Activity in Hood County, Results as of 2040, Total Expenditures are $156,300,000.
 
He found that the annual Job Loss is 1,029. Almost half of the jobs lost (511) are in the Retail Trade industry, which includes restaurants, financial activities, and real estate. Roughly one-quarter of the annual jobs lost (261) are in the Health Services industry.
 
Dr. Perryman provided analysis of numerous time frames and economic categories with his US Multi-Regional Econometric Model, developed about 40 years ago and consistently maintained, expanded, and updated since that time. They are available upon request.
 
“They all lead to the same conclusion,” said Chris Coffman, Granbury City Manager. “Delaying the construction of a new Wastewater Treatment Plant harms residents of the City of Granbury and also Hood County.”
 
The actual on-site water studies and modeling provided by expert testimony indicated the discharge from the wastewater treatment facility will not harm the environment or change Lake Granbury for aquatic life, irrigation, or recreational use.
 
“The site at 3121 Old Granbury Road is the most suitable location from several alternatives. It will have superior technology. It will not damage the environment.  If an additional plant is not constructed, the City will be in violation of TCEQ rules due to not having adequate wastewater capacity,” Coffman added.
 
A recommendation from SOAH Administrative Law judges will be given to TCEQ Commissioners, who then decide if progress on the new WWTP may continue. The TCEQ ruling is expected in early summer 2022.