U.S. Environmental Protection Agency Industrial Environmental Research     EPA-600/7-78-0
Office of Research and Development Laboratory
                 Research Triangle Park, North Carolina 27711 January 1978
        ENVIRONMENTAL OVERVIEW
        OF TEXAS LIGNITE
        DEVELOPMENT
        Interagency
        Energy-Environment
        Research and Development
        Program Report

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                       RESEARCH REPORTING SERIES
 Research reports of the Office of Research and  Development, U.S.
 Environmental Protection Agency, have been grouped  into  seven series.
 These seven broad categories were established to  facilitate further
 development and application of environmental technology.  Elimination
 of  traditional grouping was consciously planned to  foster technology
 transfer and a maximum interface in related fields.   The seven series
 are:

     1.  Environmental Health Effects Research
     2.  Environmental Protection Technology
     3.  Ecological Research
     4.  Environmental Monitoring
     5.  Socioeconomic Environmental  Studies
     6.  Scientific and Technical Assessment Reports  (STAR)
     7.  Interagency Energy-Environment Research  and  Development

 This report has been assigned to the  INTERAGENCY  ENERGY-ENVIRONMENT
 RESEARCH AND DEVELOPMENT series.  Reports  in this series result from
 the effort funded under the 17-agehcy Federal Energy/Environment
 Research and Development Program.  These studies  relate  to EPA's
 mission to protect the public health  and welfare  from adverse effects
 of pollutants associated with energy  systems.   The  goal  of the Program
 is to assure the rapid development of domestic  energy supplies in an
 environmentally—compatible manner by providing the necessary
 environmental data and control technology.  Investigations include
 analyses of the transport of energy-related pollutants and their health
 and ecological effects; assessments of, and development  of, control
 technologies for energy systems; and  integrated assessments of a wide
 range of energy-related environmental issues.

                            REVIEW NOTICE

This report has been reviewed by the participating Federal
Agencies, and approved for publication.  Approval does not
signify that the contents necessarily reflect the views and
policies of the Government, nor does mention  of trade names
or commercial products constitute endorsement  or recommen-
 dation for use.
This document is available to the public through the National  Technical
Information Service, Springfield, Virginia  22161.

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                                          EPA-600/7-78-003
                                               January 1978
     ENVIRONMENTAL OVERVIEW
OF TEXAS LIGNITE DEVELOPMENT
                           by

                   D. Harner, K. Holland, S. James,
                      J. Lacy, and J. Norton

                      Radian Corporation
                    8500 Shoal Creek Boulevard
                      Austin, Texas 78766
                   Contract No. 68-02-2608, W. A. 6
                   Program Element No. EHE624A
                  EPA Task Officer Roger P. Hansen

                Industrial Environmental Research Laboratory
                 Office of Energy, Minerals, and Industry
                  Research Triangle Park. N.C. 27711
                        Prepared for

                U.S. ENVIRONMENTAL PROTECTION AGENCY
                  Office of Research and Development
                     Washington, D.C. 20460

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                       TABLE OF CONTENTS

                                                            Page
        EXECUTIVE SUMMARY	    vi
1.0     INTRODUCTION.
2.0     THE GULF COAST LIGNITE RESOURCE,
        2.1      Occurrence and Characteristics of Texas
                 Lignites	      6
        2.1.1    Lithologic Units Containing Lignite	      6
        2.1.2    Lignite Characteristics	      6
        2. 2      Recovery and Potential Use	     16
        2.2.1    Mining	     16
        2.2.2    Options for Utilizing Texas Lignite	     18
        2.3      Factors Influencing the Potential Scale
                 of Lignite Development	     25
        2.4      Lignite Development Forecast	     27

3. 0     ENVIRONMENTAL SETTING	     39
        3.1      Human Components	     39
        3.1.1    Population	     39
        3.1.2    Economic Structure	     44
        3.1.3    Land Use	     47
        3.1.4    Infrastructure and Recreational Resources     48
        3.2      Physical Components	     51
        3.2.1    Climate and Air Quality	     51
        3.2.2    Water Supply, Availability, and Use	     55
        3.2.3    Water Quality and Trends	     67
        3.2.4    Soils and Overburden	     71
        3.3      Biotic Components	     73
        3.3.1    Introduction	     73
        3.3.2    Terrestrial Habitat/Vegetation Associa-
                 tions 	     75
        3.3.3    Aquatic Ecology	     78

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                 TABLE OF CONTENTS (Continued)

                                                            Page
        3.4      Sensitive or Unique Areas	     80

4.0     POTENTIAL ENVIRONMENTAL IMPACTS	     85
        4.1      Socioeconomic Consequences of  Lignite
                 Development	     85
        4.1.1    Direct Employment	     86
        4.1.2    Indirect Employment	     88
        4.1.3    Labor for Development and Population
                 Change	     90
        4.1.4    Demands on Infrastructure	     91
        4.1.4.1  Housing	     91
        4.1.4.2  Education	     92
        4.1.4.3  Community Services	     93
        4.1.4.4  Conclusion	     94
        4.2      Cumulative Effects  of Water Demands	     94
        4.2.1    Demand Related to Lignite Development....     94
        4.2.1.1  Direct Demands	     95
        4.2.1.2  Indirect Demands	     98
        4.2.2    Water Availability  for Lignite Development   99
        4.3      Cumulative Effects  on Water Quality	    104
        4.3.1    Water Pollutant Sources and Pathways	    105
        4.3.1.1  Mining Impacts	    105
        4.3.1.2  Impacts of Power Generation	    108
        4.3.2    Alterations to Hydrocarbons	    Ill
        4.3.3    Secondary Effects on Water Quality	    112
        4.3.4    Estimation of Aggregated Effects	    113
        4.4      Cumulative Effects  of Air Emissions	    113
        4.4.1    Regulatory Framework	    114
        4.4.1.1  Emission Standards	    114
        4.4.1.2  Prevention of Significant Deterioration..    115
        4.4.2    Dispersion Potential in the Lignite Belt.    120
        4.4.3    Emission Control Technology	    121
                               ii

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                 TABLE OF CONTENTS (Continued)

                                                            Page
        4.4.4    Impacts on Air Quality by Emissions  from
                 Existing Sources	   125
        4.4.5    Cumulative Impacts of Future Lignite
                 Development	   127
        4.4.5.1  Basis of Impact Determination	   127
        4.4.5.2  Lignite Development to 1985	   128
        4.4.5.3  Lignite Development to 2000	   134
        4.5      Changes in Land Use	   138
        4.5.1    Direct Effects	   138
        4.5.2    Indirect Effects	   141
        4.6      Cumulative Biological Impacts	   142
        4.6.1    Impacts on Terrestrial Communities	   142
        4.6.2    Impacts on Aquatic Communities	   146

5.0     MAJOR ISSUES AND PROBLEMS SURROUNDING LIGNITE
        DEVELOPMENT	   152
        5.1      Issues Affecting the Scale, Location,  and
                 Timing of Lignite Development	   153
        5.1.1    Water Availability	   153
        5.1.2    Consumptive Water Use	   156
        5.1.3    Water Use Conflicts	   159
        5.1.4    Air Quality Maintenance	   160
        5.1.4.1  New Source Standards of Performance	   160
        5.1.4.2 ^Prevention of Significant Deterioration...   161
        5.1.4.3  New Sources in Nonattainment Areas	   165
        5.1.4.4  Federal/State Conflicts	   167
        5.1.5    Issues Related to Lignite Gasification	   170
        5.1.5.1  Factors Influencing the Development of
                 Lignite Gasification	   171
        5.1.5.2  Probable Future of Gasification in Texas..   174
        5.1.6    Issues Related to Mining	   175
        5.1.6.1  Assignment of Ownership	   175
        5.1.6.2  Obtaining a Mining Permit Under PL 95-87..   177
                               iii

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                 TABLE OF CONTENTS (Continued)

                                                           Page
        5.1.6.3  Other Potential Issues Arising from
                 PL 95-87	 180
        5.1.6.4  Effects on the Competition Between Lignite
                 and Imported Coal	,	 181
        5.1.7    Capital Availability	 183
        5.2      Issues Surrounding Impact Mitigation	 185
        5.2.1    Water Quality	 185
        5.2.2    Growth Management	 187
        5.2.2.1  Planning for Increased Service Demand	 187
        5.2.2.2  Financing	 189
        5.2.2.3  Land Use Planning	 191
        5.3      Camp Swift:   A Case Study of Federally
                 Owned Texas  Lignite	 193
        5.4      Summary Evaluation	 197

6. 0     RESEARCH NEEDS	 202
        6.1      Forecasting	 202
        6.2      Baseline Data and Impact  Analysis	 203
        6.3      Developing National-Regional Problem-
                 Solving Strategies	 205
        6.4      Developing State-Level Problem-Solving
                 Strategies	 207

        BIBLIOGRAPHY	, ,	 210
                               iv

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EXECUTIVE SUMMARY

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                       EXECUTIVE SUMMARY

          The Resource

          The Texas lignite resource is estimated at 122 billion
tons of which 10.4 billion tons are amenable to surface mining
(i.e., within 200 feet of the surface).  The known portion of
this "strippable" resource which can be mined under current
technology, economics, and regulatory requirements is estimated
at between 3 to 8 billion tons.  Roughly three quarters of the
near-surface lignite lies north of the Colorado River.  The best
quality lignite--higher Btu values, lower ash and sulfur contents-
also predominate in the central and northeast portions of the
Texas lignite belt.

          The immediate prospects are that most Texas lignite
will continue to be used as a bo'iler fuel for power plants near
the lignite mines since long-range transport of lignite is
not economically justified.  Lignite is not suitable for slurry-
ing; therefore, it appears that when lignite must be shipped--
most likely for boiler fuel uses along the heavily industrialized
upper Gulf Coast--the railroads will be the primary mode.

          Currently, lignite-fired power plants account for 3,410
MWe of capacity (about 8 percent of the state total) with an
additional 8,079 JWe officially announced for 1985.  Lignite
production has increased from 2.2 million tons per year (mtpy)
in 1970 to 14.2 mtpy in 1976 with estimates for increases to
58.7 mtpy in 1985,

          The economics of importing western coal vis-a-vis mine
mouth lignite plants have been altered by the recent enactment
of the 1977 Clean Air Act Amendments,  This legislation requires
the use of best available control technology on all new coal-
fired plants.  This measure removes the primary advantage of
                               vi

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importing low-sulfur coal and may give Texas lignite a distinct
competitive edge in satisfying future Texas boiler fuel require-
ments .

          Based on electric utility power production alone,
lignite demand is projected to increase from 18 mtpy in 1977
to 59 mtpy in 1985, and to a minimum of 128 mtpy and a maximum
of 257 mtpy in 2000.  The size of the surface-mineable resource
itself may not sustain this upper limit.  Assuming a hypothetical
plant size of 1500 MWe (two 750 MWe units), the number of lignite-
fired plants will increase from 9 to 1985 to between 16 and 30
in year 2000.

          Potential Adverse Environmental Effects

          Under the growth assumptions noted above, lignite de-
velopment is forecast to increase 10- to 20-fold over 1976 levels.
The socioeconomic and environmental impacts along the Texas lig-
nite belt will be significant.

          This growth is forecast to result in between 10,000 and
20,000 new mining jobs and between 6,000 and 13,000 jobs in new
power plants by 2000.   Secondary employment in the lignite belt
is expected to result in between 31,000 and 64,000 new jobs by
2000 for a total employment of between 47,000 and 97,000.   This
could cause considerable impacts on a region characterized by
small rural communities and decades of little or nor growth.
Other socioeconomic impacts can be expected in public schools,
a wide range of municipal services (such as water and sewer
facilities), and the more subtle political and social conflicts
between the influx of "newcomers" and the resident "old-timers".

          A critical factor influencing the full-scale development
of lignite is the availability of surface water.  Water demands for
                               vii

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RA0IAN
  lignite  development are  direct  (reclamation and dust control in
  mining,  boiler makeup, ash handling,  stack gas scrubbing, and
  cooling  in power production)  and  indirect (to serve the increased
  population).  By 2000, direct demands will range from 228,000 to
  427,000  acre-feet per year, most  of which will be located in East
  and East Central Texas,  By comparison,  the indirect water use
  by 2000  is less than one-tenth  the direct demands and is largely
  non-consumptive (water is returned to surface or subsurface
  sources).  Based on forecasts of  availability, these demands
  will  seriously strain surface water  supplies on a local basis
  resulting in sharp competition  with  other users.

           For the long term,  the  greatest threat to water quality
  is a  deterioration of the ground-water  supply.  Aquifers may be
  locally  unusable for drinking water  supplies if their recharge
  zones contain many unlined ash  and scrubber sludge ponds.  Without
  appropriate  mining and reclamation controls, surface water may
  be polluted  from eroded  spoil banks  and overburden.

           Another possible environmental constraint on the fore-
  cast  lignite development levels by 2000 is air quality regulation.
  Mine-mouth,  lignite-fired power plants  emit appreciable levels
  of particulates, sulfur  oxides, arid  nitrogen oxides.  Despite
  improvements in control  technology,  the announced new plants
  will  result  in a three-fold increase  over 1975 levels during
  the next few year% but still  remain  within state and Federal
  limitations.  Currently, the  lignite  belt meets Federal ambient
  air quality  standards.   To insure that  cumulative impacts on air
  quality  due  to significant plume  interaction do not occur, 1500
  MWe stations should be separated  by  about 30 miles,  Closer
  spacing  (to  less than 10 miles) is possible, however, and is
  allowed  by current law under  some conditions.  The actual spacing
  of plants is dependent on a variety  of  local factors requiring
  case-by-case analysis.   The maximum  of  30 plants forecast by
                               viii

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by year 2000 cannot all be separated by 30 miles if sited at the
mine mouth.  This constraint could prohibit development at some
locations unless stack-gas clean-up is raised to a level exceeding
the New Source Performance Standards.

          The total amount of land to be disturbed by Texas lig-
nite development through 2000 could reach 454,000 acres.  With
adequate reclamation, the effects will be minimized.  Much of
the agricultural land to be disturbed is considerably less pro-
ductive than agricultural lands on either side of the lignite
belt.  Since much of the mining and reclamation will occur in
stages, the overall effect on wildlife habitat will be minimized.
In fact, with the exception of mature forests, it is possible
to reclaim much of the lignite belt lands such that wildlife
carrying capacity can be increased.  On a local level, aquatic
life may be adversely affected by the deterioration in water
quality.  The additional demands on water quantity from lignite
operations may exacerbate threats to the survival of aquatic
populations in drought conditions.  Other possible adverse ef-
fects on aquatic life may result from reduced freshwater flow
to coastal estuaries and localized thermal loading from power
plant cooling operations.

          Policy Issues and Problems

          The State's water rights appropriation system, operat-
ing on a first-in-time, first-in-right basis, may not be adequate
to accommodate water use disputes resulting from lignite develop-
ment.  The recent combination of the three State water agencies
into the Department of Water Resources may facilitate the develop-
ment of a coordinated planning approach necessary to maximize
benefits to all users.   Although Federal initiatives may compel
change, allocation based on price alone could drive agricultural
users out of the market.
                               ix

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          Similarly, the problem of maintaining adequate flow
in streams to supply coastal estuaries could be addressed through
       «>
the systematic operation of reservoir levels--a technique whichi
is presently constained by legal and regulatory barriers.  The.
location of lignite with respect to existing lakes,  the seasonal
variation in water availability and, to a lesser degree, Federal
permitting regulations, have necessitated the widespread use of
cooling ponds over the more water-conserving "once-through" cool-
ing methods,

          The deep basin (below the strippable zone) lignite re-
source is believed to be recoverable only through in situ
gasification.  The environmental advantages of this technology
include the reduction of air pollutants and the elimination of
surface mining.  However, there is considerable uncertainty re-
garding the contamination of ground water from in situ combus-
tion.

          The likelihood of the commercialization of any form
of lignite gasification is dependent on both advances in techn-
nology and policy decisions affecting the pricing and allocation
of natural gas.

          The mandatory boiler fuel conversion policies of the
Texas Railroad Commission and the more severe gas phase-out re-
quirements contemplated by Congress may provide an incentive
to replace natural gas with a synthetic low- or medium-Btu gas
for future use in existing peak-load gas-fired boilers.  Gasified
lignite may also replace some natural gas as a feedstock,  However,
the greatest potential for Texas lignite in this century is for
use as direct-fired boiler fuel.

          The problem of accommodating some 30 lignite-fired
1500 MWe units on or near the lignite belt in the face of cur-
rent air quality regulations suggests the need for greater volun-
tary power plant siting coordination among utilities.

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          Texas lacks a consistent legislative policy regarding
disputes that arise between surface owners and mineral right
owners over the assignment of lignite ownership.  The point is
that surface mining will temporarily--and maybe permanently--
affect the surface owner's use of this land.  Recent State Supreme
Court decisions, such as Reed versus Wylie, have ruled that lignite
is assigned to the surface estate where no specific mention of
surface mining is made in the mineral interest lease or deed.
Although the issue is not clearly resolved, this situation could
impede lignite development depending on the extent of such con-
flicting property rights.

          On the whole, it appears that the additional require-
ments imposed on current State regulations by new Federal strip
mining law will have less effect on the mining of Texas lignite
than on the surface coal production in other regions where the
overburden consists of prime agricultural land, environmentally
sensitive areas, or unreclaimable and severely steep slopes.

          The communities along the lignite belt are not pre-
pared to cope with the multitude of environmental and socioeconomic
impacts they may face during the next quarter century.  Municipal
governments are typically reluctant to act in the face of uncer-
tainty regarding proposed developments.

          Although most of the Texas lignite resource will be
developed by private firms on private property, a unique excep-
tion is the more than 100-million-ton reserve on Camp Swift--
an unused army training camp 30 miles east of Austin.  A recent
Federal law permits coal leasing on military property for use
by publicly-owned utilities.   On balance there appear to be no
major unresolvable environmental problems associated with the
development of Camp Swift lignite.
                                xi

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RADIAN
            Further study needs include improved forecasting, a
  better data base for impact assessment, and more quantitative
  evaluation of impacts, air quality modeling and economic model-
  ing.  Numerous issues bear further examination, in particular
  the influence of exercising the state option of redesignating
  parts of the lignite belt Class III or Class I,  Other issues
  claiming more attention are growth management,  water conserva-
  tion, and the energy conservation opportunities associated with
  lignite development.  An in-depth, regional technology assessment,
  including the states of Texas, Arkansas, Louisiana, Alabama, and
  Mississippi, is recommended,
                               xii

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CHAPTER ONE



INTRODUCTION

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CORPORATION


 1.0       INTRODUCTION

           Continuing energy shortages throughout the nation  and
 changing fuel mixes in the Gulf Coast region indicate that the
 substantial lignite deposits of the Gulf coastal plain will  be
 more intensively exploited as an energy source in the future.
 These low-grade coals are already being mined and used in Texas
 on a limited scale.  Up to now, the emergence of lignite-related
 technologies has apparently not been accompanied by significant
 adverse environmental effects.   However, the rapid expansion of
 lignite mining and utilization may generate both site-specific
 and cumulative adverse impacts that are not currently apparent.
 In particular, a number of policy-related issues may need to be
 resolved before development on a large scale can proceed in  an
 environmentally acceptable manner.

           The EPA Office of Energy, Minerals, and Industry,  act-
 ing through its Special Studies Staff at the Industrial Environ-
 mental Research Laboratory. Research Triangle Park, North Carolina,
 has commissioned this study of potential environmental effects  of
 Texas lignite development.  The purposes of this environmental
 reconnaissance are several.

              to present an overview of the Gulf Coast lignite
              resource and the types and general scale of impacts
              and conflicts associated with its probable use

              to provide perspective and general guidance as  to
              what additional information and analysis are likely
              to be useful in minimizing detriments and maximizing
              benefits related to lignite development

              to furnish an environmental issue-oriented appraisal
              of what EPA and other federal policies are likely

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             to affect or be affected by lignite development,
             with special reference to the desirability and
             utility of a regional-level technology assessment

          This environmental reconnaissance has been prepared  by
Radian Corporation, Austin, Texas, and is based on in-house ex-
perience, non-proprietary resources, and other information that
is readily available.  Lack of regional data and other limita-
tions focus most of the analysis on Texas lignite.  A special
effort has been made to include only pertinent illustrative
or documentary material.

          This report is organized in six chapters, of which
this introduction is the first.  Chapter Two is a description  of
the lignite resource: what it is, where it occurs, how it may  be
used, and what affects its current and future uses.  Also included
in Chapter Two is an estimate of potential lignite development
rates that is used for impact analysis and discussion.

          Chapter Three characterizes the physical, biological,
and cultural components of the lignite region of Texas and the
Gulf Coast.  The geographic variations and current trends in
these characteristics are emphasized where appropriate.  The
chapter is specifically not intended to be a detailed descrip-
tion of the existing environment.

          Chapter Four addresses potential environmental impacts
associated with lignite mining and use.  The assessment of impacts
recognizes the types of site-specific effects that may occur,
but generally emphasizes aggregated or cumulative primary and
secondary effects and apparent resource conflicts.  The lignite
development scenario described in Chapter Two places the scale
of these impacts in a temporal perspective.

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CORPORATION


           Chapter Five presents a more detailed discussion of
 current issues related to lignite development.   The issues are
 discussed chiefly from the standpoint of how they may affect the
 type,  magnitude,  location, and timing of changes in one or more
 environmental aspects.  No attempt has been made to limit this
 discussion to those issues that are within the current purview
 of EPA, so that a more comprehensive picture may be obtained.
 However, this discussion should not be considered a complete
 enumeration of all potential problems and issues; rather it only
 illustrates some of the major ones and how they may interact with
 one another.

           Chapter Six summarizes major areas in which further
study is needed.  It emphasizes the most obvious and pressing of
these needs, where real data gaps exist or complex policy inter-
actions must be disentangled.  Finally, it discusses the
need for a unified in-depth regional analysis.

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        CHAPTER TWO



THE TEXAS LIGNITE RESOURCE

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CORPORATION
 2-,0
THE TEXAS LIGNITE RESOURCE
           Despite its  size,  the lignite resource  of the  Gulf
 States has not been extensively explored.   Figure 2.0-1  illus-
 trates roughly the geographic extent of the lignite-bearing
 formations through Texas,  Louisiana, Arkansas.  Alabama,  and Mis-
 sissippi.   Only in Texas,  where the size of the strippable re-
 source is  judged to be about 10.4  billion short  tons,  is there
 a reliable estimate of Gulf  Coast lignites.   However,  strippable
 resources  in the remaining states probably total  several billion
 tons.   Deep-basin lignite  resources that may be amenable to in
 situ gasification may  be an  order of magnitude  larger.

           Because of the general lack of exploration and develop-
 ment in the other states,  and insufficient data on the  resource
 itself,  the following  discussions will center around the Wilcox
 and Yegua-Jackson lignites of Texas.  Though these formations
 also make  up the bulk  of the Arkansas and Louisiana resource,
 generalizations must be made with caution on the  basis  of the
 Texas  data.   Sulfur and sometimes ash contents  appear  to be signi-
 ficantly higher in Alabama and Mississippi lignite, than in
 Texas, Arkansas, and Louisiana lignite.  Heating values  are also
 expected to be slightly higher in Alabama and Mississippi lignite
                             FIGURE 2.0-1
               LIGNITE  OCCURRENCE IN THE TERTIARY OF  THE
                       SOUTH-CENTRAL UNITED STATES

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2.1       Occurrence and Characteristics of Texas Lignites

2.1.1     Lithologic Units Containing Lignite

          Lignite is found throughout the Texas Gulf Coastal
Plain from the Rio Grande to the Red and Sabine Rivers as near-
surface and deep-basin deposits.  Near-surface deposits occur
within three principal outcrop areas of lower Tertiary (Eocene)
rocks in East Texas (Figure 2.1-1).  The principal commercial
lignite deposits are found in the lower Eocene Wilcox Group,
which crops out as a narrow band extending from Maverick County
on the Rio Grande to Bowie County on the Red River.  This unit
also crops out in the Sabine Uplift region centered on Panola
and adjacent counties.  Deposits of secondary importance are
found in the upper Eocene Yegua Formation and Jackson Group along
a narrow outcrop band extending from Starr County on the Rio
Grande to Sabine County on the Sabine River.  Two areas of deep-
basin lignite are located downdip and coastward from the near-
surface deposits (Figure 2.1-2).  The largest of these represents
subsurface Wilcox lignite deposits (KA-152).

2.1.2     Lignite Characteristics

          Lignite occurs as a component facies of ancient fluvial,
deltaic, and lagoonal rocks.  The northeastern deposits are asso-
ciated with fluvial deposits.  These grade into deltaic deposits
in the central parts of the lignite belt and into lagoonal deposit!
in the southern regions.  Detailed descriptions of these deposi-
tional frameworks are given by Kaiser (KA-152).  Figure 2.1-3
shows the stratigraphic occurrences of lignite deposits.

          Through an examination of known lignite deposits and
their geological contexts, the Texas Bureau of Economic Geology
(KA-152) estimated that a total of 10.4 billion short tons of

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      DISTRIBUTION  OF TEXAS NEAR-SURFACE  LIGNITE


                     (SOURCE:   KA-152)

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DISTRIBUTION OF TEXAS DEEP-BASIN LIGNITE


           (SOURCE:   KA-152)
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Jackson












Cloiborne





Wilcox



Midway

Major lignite occurrences  *
Other lignite occurrences
                    Conglomerate
                    Shale
Sandstone
Sandy Clay
                                 FIGURE 2.1-3
         STRATIGRAPHIC COLUMN. EAST  TEXAS; ADAPTED FROM THE
                     GEOLOGICAL HIGHWAY MAP OF  TEXAS

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lignite with a minimum thickness  of 4 to  5  feet may be located
within 200  feet of  the surface  (Table 2.1-1).   These estimates
have since  been locally corroborated by actual  exploration, and
are thought to be a fairly  accurate description of the amount of
lignite which could have potential  commercial value.  Estimates
of the known portion of this  resource which could be mined eco-
nomically with present technologies,  economics, and regulatory
requirements1 have  ranged from  3  to 8 billion tons (WH-124).   Es-
timates of  both the total resource  and economically recoverable
reserves are subject to revision  as exploration proceeds.  It
should be noted, however, that  the  relatively low heating value
of Texas lignite, and its high  ash  and sulfur  content and  thin
seams, make the economics of production fairly  marginal and highl;
sensitive  to environmental  policies affecting  the cost of mining
or use.
                           TABLE 2.1-1
              NEAR-SURFACE POTENTIAL LIGNITE RESOURCES

                       Amount-(Billion Tons) Percent of Total
       East Texas              5.085                49
       Central Texas           2.846                27
       Southeast Texas          1.386                13
       South Texas             1.109                11
              Total          10.426               100
       Source: KA-152
          The  extent  of deep-basin lignites is less well known,
but the Texas  Bureau  of Economic Geology estimates, using geo-
physical logs  from  oil and gas drilling, that at least 112 billion
short tons are present.   Most of this lies in the Wilcox Formation
in Central Texas, from 200 to 5,000 feet below the surface.
1 Prior to enactment of  the  Surface  Mining Control and Reclamation
 Act of 1977.

                               10

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          Compositional variation in Texas lignite results in
differences in grade or quality of these deposits.  Figures 2.1-4
through 2.1-6 illustrate regional variations in heating values.
sulfur and ash content.  These characteristics were used to rank
the desirability of the principal near-surface resources, shown
together with other potential resources in Figure 2.1-7.  This
figure shows that the highest-quality lignite deposits are found
in the Wilcox outcrop from Bastrop County to Bowie County and
in Harrison, Rusk, and Panola counties in the Sabine uplift area.

          The most economically attractive deposits (numbered 1
and 2 in Figure 2.1-7) have already been partly developed.  To
date, severe adverse environmental or socioeconomic consequences
have not been observed in the vicinity of these mines, where post-
development environmental studies have been made.1  Subsequent
development would normally proceed from these areas to the next
most favorable ones, with the least favorable developing last.
A number of other factors, however, may actually produce a some-
what different development pattern.

          Presently the bulk of the best lignite is held by a
few companies, most notably the Texas Utilities Company and sev-
eral major oil and gas firms.  Other would-be lignite users may
therefore have to look to the less desirable but still available
deposits.  In addition, current clean air policies may restrict
power plant siting options in the northeast and central areas
of the lignite belt where the greatest demands and the best de-
posits of lignite lie.  This situation will also favor the develop
ment of the less desirable deposits to the south earlier than
would otherwise be expected, especially if the demand for lignite
is high.
1The studies referred to are proprietary surveys conducted in
 the vicinity of the Sandow and Big Brown generating stations
 (see Figure 2.2-2).
                              11

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                              ASH CONTENT IN PERCENT
                                        10
    \	r^,—-
                   FIGURE 2.1-4
REGIONAL VARIATION IN ASH CONTENT OF TEXAS LIGNITE
                 (As-Received Basis)
                  (SOURCE:  KA-152)
                         12

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                                x-»
        L     I    /
        I—         /
            —*	. s
         SAN ANTONIO-^/
                                      YG  YEGUA
                                          JACKSON
                     FIGURE 2.1-5

REGIONAL VARIATION IN SULFUR CONTENT  OF TEXAS LIGNITE

                 (As-Received Basis)

                  (SOURCE:  KA-152)
                          13

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                         .	DALLAS
                                   BTU PER POUND
                                          7500-8000
                                          7000- 7500
                                          <7000
                                          6500-7000
                                          < 6500
                                      YG  YEGUA
                                      JK  JACKSON
                     FIGURE 2.1-6
REGIONAL  VARIATION IN HEATING VALUE OF  TEXAS LIGNITE
                 (As-Received Basis)
                  (SOURCE:   KA-152)
                           14

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t_n
                                     ANTONIOL~1AUS,T4
                                                      \
                                                                         ^HOUSTON
                                                     Potential Lignite Deposits
                                                     Principal Lignite Deposits

                                                     Summary Quality Ranking
                                                                                               TYLEI
                                                        FIGURE 2.1-7

                                 POTENTIAL AND PRINCIPAL L1GNITL DKPOSITS AND QUALITY OF EACH
                                                                                                        SCALE IN MILES
                                                                                                             "c=
                                                                                                    0   20    50
100
                                                                                                                    02-1980-1

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2.2       Recovery and Potential Use

2.2.1     Mining

          Prior to 1946, most mining was by underground room-and
pillar methods through shafts 50 to 150 feet deep.  The Malakoff
district in western Henderson County was the most important of
the old mining districts.  The Alba district of southwestern
Wood County and the Como district of south-central Hopkins County
were also very active from 1890 to 1946.  Some open-pit mining
also occurred, where  holes  30 feet  in  diameter were dug.

          Lignite is presently mined by area stripping.  In flat
to gently rolling terrain where lignite occupies a wide continuous
area, overburden is removed in a series of rows.  Overburden from
the first row is piled next to the pit away from the direction
mining will take, and the lignite is removed.  Subsequent cuts
are made parallel to the first and the overburden is deposited
in the immediate preceding pit.

          Modern earth-moving equipment and the availability of
large lignite reserves below shallow, unconsolidated overburden
make surface mining more economical than underground mining.
Large shovels and draglines with 90-cubic-yard buckets remove
overburden (KA-152) .  About 80 to 85 percent of the lignite bed
is typically recovered.

          The size of draglines presently available limits strip-
mine depth to less than 200 feet.  Because the Eocene deposits
dip coastward at about two degrees, the strippable near-surface
deposits are confined to a narrow band (ten miles wide at most)
except in the Sabine uplift region, where some deposits are
areally extensive.
                                16

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RADIAN
            Approximately 50 to 100  feet of  overburden  is  typically
  removed.   Lignite beds presently mined are from 6  to  15  feet
  thick with rare beds attaining 20  feet of  thickness.

            Present lignite-fired power plants  (the  dominant users
  of lignite) are built adjacent to  surface  mines.   Lignite is
  either carried in 180-cubic-yard trucks over  company  roads or
  transported by conveyor belts to the plant.   Because  of  the
  relatively low heating value of lignite (around 7,000 Btu/pound),
  it is not economical to transport  long distances.  A  more impor-
  tant constraint, however,  arises from the  tendency of Texas lignite
  toward spontaneous combustion because of its  high  volatiles content,
  Because of this problem, lignite is generally used within 5 to  15
  miles of the mine.  Slurrying, which might otherwise  permit ship-
  ment of lignite over long distances,  presents problems when applied
  to lignite, which disintegrates easily and is difficult  to sepa-
  rate from the slurry medium.

            Reclamation as practiced at Big  Brown begins by re-
  working the spoil with dozers and scrapers to contours and drain-
  age patterns benchmarked in pre-mining surveys.  Topsoil and
  underlying materials are very similar chemically and  texturally;
  consequently topsoil is not segregated and respread.   The reworked
  surface is then fertilized and disked.  In the spring, coastal
  Bermuda grass is then planted by sprigging;  in the fall, crimson
  clover is seeded in.  The next year, the Bermuda can  be  harvested
  as hay.  Small impoundments are developed  for stock and  wildlife
  use, with appropriate vegetation planted around them. In addition
  to restoring use to pastureland, studies are  being conducted of
  the feasibiltiy of planting trees  and row  crops.  Black  locust,
  green ash, sycamore, cottonwood and several other  native and
  introduced woody species have been planted.   Shrubby  species
  suitable for browse as well as trees are planted.   Corn, soybeans,
  and sorghum have been grown successfully on the mine.
                                17

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 2.2.2      Options for Utilizing Texas  Lignite

           As  is true of all United  States  coals, Texas lignite
 can  potentially be combusted directly,  or  converted into synthe-
 tic  gaseous and liquid products.  A specially funded effort at
 Texas A&M is  researching the possibilities of using World War
 II German technology to convert lignite to a variety of petro-
 chemical  products (see Chapter  Five).   However, the short- and
 mid-term  possibilities appear limited  to more conventional
 gasification  and liquefaction technologies.

           Convention combustion is  by  far  the greatest potential
 use  for Texas lignite in this century.   Lignite has been used for
 steam-electric power generation in  Texas since 1927, and currently
 supplies  about 970 of the state's  capacity.  Today, 3,410 MWe are
 generated in  lignite-fired  stations.   A total of 8,079 MWe of
 additional lignite-fired capacity is currently planned to be in
 operation by  1985.   There are no  technological impediments to
 direct combustion of Texas  lignite,  although the variability
 among the fuels may  require combustion studies to optimize boiler
 operation.

           The Texas  lignite belt  lies  primarily within the utility
 service areas of four investor-owned electric utilities;   Texas
 Power and Light, Southwestern Electric Power, Gulf States Utilities
 and  Central Power and Light, as shown  in Figure 2.2-1.   Between
 the  service areas of Texas  Power and Light  (a subsidiary of Texas
 Utilities Services,  Inc.) and Central  Power and Light is a twenty-
 county area served by-municipal and other  public utilities
 Texas Utilities Services, Inc.  presently operates all of the in-
 stalled lignite-fired steam electric stations in Texas for the
 private utilities (Figure 2.2-2).   However, Imperial Chemical In-
dustries  (ICI-United States,  Inc.)  uses  local lignite as a feed
stock for manufacturing activated carbon near Darco, Texas
                               18

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VO
                                                                                                       MONTICELLO
                                                                                                      i1150/1975
                                                                            BIG  BROWN
                                                                             1150/1972
                                                           SAtyDOW
                                                           360/1954
                                                      MARTIN LAKE
                                                        750/1977
                                                                                                     SCALE IN MILES
                                                                                                  0   20    50
                                      360/1954
Potential  Lignite Deposits

Principal  Lignite Deposits

Total MWe/Year On-Line

       FIGURE 2.2-2
                                                                  100
                                    EXISTING LIGNITE-FIRED STEAM ELECTRIC STATIONS (1977)

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ro
o
                                                                                               SOUTHWESTERN
                                                                                               ELECTRIC POWER
                                      SOUTHWESTERN
                                      PUBLIC SERVICE
                                        COMPANY
                                                      WEST  TEXAS
                                                   UTILITIES COMPANY
                                                                        TEXAS POWER AND LIGHT
  COMMUNITY   " "**
PUBLIC  SERVICE
  COMPANY
                                                                                           GULF STATES
                                                                                          UTILITY  COMPANY
                                WEST TEXAS UTILITY COMPANY
                                     MUNICIPAL AND
                                      OTHER UTILITIES
                                                                                          HOUSTON
                                                                                          LIGHTING
                                                                                          AND POWER
                                                         CENTRAL POWER AND LIGHT COMPANY
                       FIGURE 2.2-1
                     AREAS SERVED BY
              ELECTRIC  UTILITIES  IN TEXAS

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HAINAN
            As natural gas is phased out as  a boiler fuel,  most new
  generating capacity in Texas will be fired either with coal  or
  with lignite.   Until the passage of the Clean Air Act  Amendments
  of 1977,  the economics of using imported coal versus lignite in a
  large,  new utility boiler were roughly equivalent.  The cost of
  imported coal is high, especially when transported by  rail.  Per-
  ton delivered costs to Houston ranged from $20 to $23  in 1976 for
  Wyoming and Illinois coal, respectively.   By 2000,  these costs may
  rise to $40 or more, in 1976 dollars.   The capital investment in
  rail cars, usually undertaken by the utility, as well  as the cost
  of unloading facilities at the plant,  adds to the cost.  The
  total investment (in 1976 dollars) required to move 2  million tons
  per year of western coal a distance of 1,500 miles may be from
  $24 million to $28 million (WH-124).

            Before passage of the Clean Air Act Amendments of  1977,
  it was  possible to meet Federal New Source Performance Standards
  without scrubbers by using low-sulfur Western coal. Under these
  circumstances, the savings in flue gas desulfurization equipment
  and power consumption counterbalanced the higher cost  of imported
  coal.  Added to this, the additional capital and operating costs
  of the  larger boilers needed to produce power from the relatively
  low-Btu lignite made the total economic outlook approximately the
  same for the two fuels.  The new Amendments, however,  call for flue
  gas clean-up or coal pretreatment, according to best available
  technology.  Thus, this equalizing factor is now removed. Trans-
  port and coal costs now become dominant.   Under these  new require-
  ments,  lignite generally becomes the more attractive of the  two.
  The recent imposition of steep severance taxes in Western states
  has further increased the attractiveness of lignite vis-a-vis
  Western coal.   Chapter Five contains a more detailed description
  of the  potential impact of the Amendments  on the scale of lignite
  development in Texas,
                                21

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RAMAN
            Much of the power generated with lignite will be  con-
  sumed by industry.  The 360 MWe Sandow station in Milam County
  presently supplies power to the adjacent Alcoa alumina reduction
  plant, while in Freestone County, the 1150 MWe Big Brown  station
  produces electricity for the Lone Star Steel Company  fumances.
  Both these plants are operated by Texas Utilities Generating  Com-
  pany.   In addition, a substantial number of industries, particular!
  the petroleum refining and petrochemical industries,  burn fuels
  on-site to produce heat, power, and process steam.  In the  future,
  increasing amounts of lignite will be used by these industries.

            In addition to direct combustion, lignite can be  con-
  verted to a liquid fuel or gasified for use as fuel or feedstock.
  Liquefaction processes, especially those based on pyrolysis,  ap-
  pear adaptable to Texas lignite,  although there have  been few tests
  to date of the suitability of such a liquid feedstock.  Develop-
  ment of these processes lags behind gasification, and they  have
  not yet been proven in a commercial operation in the  United
  States.  Furthermore, the wastewaters from these processes  typicalli
  contain phenols and other toxic hydrocarbons,  with trace  metals
  and polynuclear aromatics up to saturation.  Problems also  exist
  in disposing of spent reagent solutions containing a  variety  of
  organic and inorganic compounds and trace elements.   Biological
  treatment technologies, considered by many to be the  most applicable
  approach to cleaning up these wastes, may take time to adapt, and
  will probably be difficult to operate.   In addition,  fugitive
  emissions associated with many liquefaction processes contain
  substances known or thought to be carcinogenic.  The  necessary
  tight  housekeeping procedures to protect employee health  will be
  costly, and could ultimately make liquefaction processes ;unattractii

            Gasification processes show more promise, both  environ-
  mentally and economically.  Gasification processes currently  under
  investigation produce a low-Btu fuel gas, to be used  directly as
                                22

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RADIAN
 a boiler fuel  (often immediately upon its exit, at a high temper-
 ature, from the gasifier).  A medium-Btu "synthesis gas," high
 in hydrogen and carbon monoxide, may also be generated; its major
 use is as a feedstock, especially  for ammonia and methanol production

           Texas lignite varies in quality as gasifier feed, and
 a batch test may often be the only way of determining its suit-
 ability.  Typically, it is partially oxidized and high in vola-
 tile components, making it highly reactive.  These characteristics,
 along with its non-caking properties, make it particularly well
 suited for certain processes, particularly the C02-acceptor pro-
 cess and the first-generation fixed-bed gasification processes.
 The fixed-bed processes preserve  the volatile components of the
 lignite, including methane.  Since ash from Texas lignite fuses
 at high temperatures, the new fixed-bed slagging Lurgi process
 now under development by  the British Gas Corporation may prove
 even more applicable.

           The first-generation gasification processes were
 largely developed for German brown coals, which resemble Texas
 lignite; there is, however, no direct operating experience with
 the Texas fuel.  A pilot project to convert lignite to synthesis
 gas, funded by ERDA, is under way near Houston.  Also, Exxon has
 proposed to build a Lurgi test facility near Longview, Texas,
 producing a medium-Btu synthesis gas to be piped to the coast.

           Because the bulk of Texas'  lignite resource is too deep
 for surface extraction and too low in heating value to justify
 the cost of conventional underground mining techniques, in situ
 gasification appears to be the only economical way of recovering
 its energy value.   Present interest centers around technologies
 which first fracture the lignite,  then introduce air and steam
 under pressure through one of a pair of boreholes.   The resulting
 product gas is drawn off through a second borehole as the reaction
                                23

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RADIAN
  proceeds.  Econmically,  this process is potentially very attractive
  because of its low capital and operating costs, relative to above-
  ground gasification.  Furthermore,  since the  reaction proceeds
  underground, emission control is not a problem.  However, the
  technology has not been proven commercially in Texas.  Texas
  Utilities has leased rights to use  a Soviet technology, reportedly
  proven in the U.S.S.R.,  which is being tested on the Wilcox lignite
  in Freestone County.  Texas A&M University is also conducting
  studies of in situ gasification on  the Yegua  lignite near College
  Station.

            Texas lignite  appears very promising for in situ gasifi-
  cation.   Its high reactivity and ash content  may reduce or prevent
  problems  of subsidence and water inflow by filling the voids left
  by the reaction.   Since  the process may produce relatively high
  concentrations of potentially harmful aromatics, some concern has
  been voiced over the problem of ground-water  contamination.  The
  deep-basin lignites, however, usually lie at  some distance from
  freshwater aquifers.  The strata immediately  surrounding the lignit
  are also  most often mud, which forms a relatively impermeable seal
  as the reaction proceeds.  This not only retards water inflow, it
  permits high pressures to develop,  which improves yields.  The
  Texas Utilities pilot study carefully monitors water quality and
  will provide some concrete data on  this question.  Hydrologically,
  the lignites of the less permeable  Yegua formation are,generally
  less liable to ground-water contamination by  leaching than those
  of the Wilcox.   The reasonably thick seams of deep-basin lignites
  promote good utilization of the heat evolved, but slagging could
  tend to inhibit the gasification process (ED-073).

            The leading factor affecting the development of a coal-
  or lignite-based gasification industry in Texas is the cost of
  producing and using synthetic gas,  as compared to natural gas or
  direct combustion of coal.  In general, trends in both capital and
                                24

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RAMAN
  operating costs  seem to  favor  the replacement of natural gas as
  a fuel with  direct  combustion  of coal or lignite.  Recent studies
  have  investigated intermediate measures, in which older, natural-
  gas-fired equipment remains  in service, fired with synthetic gas.
  These do  not appear to be  as cost-effective as building new coal-
  or lignite-burning  facilities, even  at  the cost of phasing out
  extensive existing  facilities.  Peaking units appear to be the
  only  exception.

            The economics  of converting smaller boilers  include the
  additional factor of siting.   In some instances, an industrial
  facility  may be  unable to  convert to on-site direct combustion
  of coal because  space is unavailable for the needed coal storage
  and handling facilities  and  for disposing of ash and scrubber
  sludge.   The aggregate cost  of converting a large proportion of
  such  users to a  synthetic  fuel base  is  unfavorable for the same
  reasons that apply  to large  utilities:  in addition to building
  gasification facilities, modification must be made in  processes
  and equipment to use the new fuel.   A few may simply be shut down
  and replaced,  especially if  owned by large concerns that can
  capitalize the development of  new sites.  However, there may be
  a potential  for  supplying  a  small proportion of  them with synthe-
  tic gas,  if  a single gasifier  can be built to serve several users.
  Co-generation or other cooperative ventures burning lignite di-
  rectly  to produce process  steam and  heat afford  another possible
  avenue, competing with gasification.

  2.3       Factors Influencing  the Potential Scale of Lignite
            Development

            Given  the present  trend of national energy policy and
  the decreasing supplies  and  rising costs of natural gas and oil,
  it is clear  that Texas'  use  of solid fuels will  increase dramati-
  cally by  the end of the  century.  The state's economy  is in large
                                 25

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RADIAN
CORfHMUmC
  part founded upon the abundance of oil and natural gas.  Now that
  cheap oil and gas supplies are no longer available, it seems log-
  ical to turn to Texas'  other abundant fossil  fuel--lignite--to
  support its important petroleum,  petrochemical and related indus-
  tries.   The degree to which lignite,  rather than nuclear energy
  or imported coal, will fill the gap left by gas and oil will depend
  upon the relative costs and availability of alternature fuels.
  The balance struck between these  other fuels  and lignite in com-
  peting  for Texas markets will,  therefore,  ultimately determine
  the scale and location of the environmental impacts experienced
  by the  state as a result of developing its lignite resource.

            A host of economic and  political factors will influence
  the continuing trade-off between  coal and lignite.  These factors,
  discussed at greater length in Chapter Five,  fall into several
  categories:

               Availability of coal,  as influenced by rail
               capacity,  policies concerning interstate slurry
               pipelines, leasing of federally  held coal, and
               implementation of the new Surface Mining Control
               and Reclamation Act  of 1977.

               Relative economics of sulfur removal and emis-
               sion control under the provisions of the new
               Clean Air Act Amendments of 1977.

               Policies concerning natural gas  production,
               pricing, and allocation, which will largely
               determine whether the vast deep-basin lignite
               resource is developed.

            •  Environmental and economic constraints on mining
               lignite and siting lignite-using plants.
                                 26

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           •  Legal and institutional constraints.

          Many of these factors are fluid and uncertain at pre-
sent.  Nevertheless, for convenience in discussing the potential
impact of  lignite development, some sort of forecast is necessary.
Consequently, an "envelope," rather than a series of curves, has
been developed, as described below.  Impacts will be discussed
in terms of the upper and  lower bounds of the envelope.  It should
be understood that the envelope does not represent a continuous
gradation  of possible futures.  Because the factors listed above
depend mainly on discrete, independent government policies, the
envelope actually bounds a series of discontinuous curves, reflect-
ing the various combinations of these policies.  A detailed examina-
tion of these combinations is outside the scope of the present
study.  A more thorough treatment would certainly be necessary
for any impact assessment  intended as a framework for actual
planning.  Pending the action of Congress on several outstanding
pieces of  legislation, such a study is strongly recommended.

2.4       Lignite Development Forecast

          An ideal forecast of lignite development would incor-
porate demand components for electrical generation, on-site power
generation for industry, process heat and steam, and feedstocks.
Of these,  the needs of electricity can be predicted most effec-
tively, since the fuel conversion patterns of utilities are
well known and quite uniform.  By comparison, very little detailed
data on fuel use patterns  in other industries are available.
Furthermore, these patterns are very complex (for example, natural
gas used in olefin plants  is first "stripped" of some of its com-
ponents, which are used as a feedstock; coal or lignite could not
be directly substituted into this system).  Variability between
individual installations is also great, which further limits
accurate prediction of how much lignite could--and would—be used.
                               27

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A few rough industrial demand estimates have been published.
These range from 54 million short tons (MST) per year of both
coal and lignite in 1985 and 142 MST in 1990, assuming complete
phaseout of natural gas as a fuel (WH-124) .   Petrochemical feed-
stock demand is even less predictable.  While it can be said with
certainty that at least some of the future industrial fuel demand
will be met by lignite, it is by no means certain that any lignite
will be used as a feedstock by 2000.  Not only economics, but re-
gulatory policies, will have a controlling impact on this component
of demand, as is discussed in detail in Chapter Five.

          Under these circumstances, no attempt was made to fore-
cast industrial and feedstock demand, because of the degree of un-
certainty surrounding them.  Consequently, all quantitative dis-
cussions that follow in Chapters Four and Five will be based on
the use of ligni±e by utilities alone.  While power generation will
undoubtedly be the largest user of  lignite for many years, this
should not be construed to imply that other uses are negligible.
The reader should bear in mind that industrial uses probably fall
in the same order of magnitude and that cumulative impacts could
be significantly increased by this additional demand factor.

          A number of electricity demand forecasts for the State
of Texas have recently been made (HO-400; TE-301; BA-560).  The
projections of the Texas Water Development Board (TE-301) have
been chosen as the basis of the present study, since they attempt
to take into account several of the factors actually influencing
demand growth, rather than using a simple overall growth rate.
Some interpretation has been applied to the Board's figures to
produce a forecast of lignite growth alone.

          The Board based its power demand projections on consid-
eration of actual announced developments, future population growth
and changing per-capita consumption of electricity.  Three fore-
                               28

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RADIAN
  casts were produced, extending to the year 2030.  All the fore-
  casts follow official announcements for the period 1977 to 1985;
  since the lead time necessary to put a lignite-fired plant on
  line is roughly seven years, this segment of the forecasts is
  likely to remain  fairly correct, even if the demand picture chan-
  ges radically.1   The high-  and medium-demand forecasts use the
  power industry's  linear extrapolations of the curve for tne 1975-
  1985 decade to project the  next decade, to 1995.  The two forecasts
  differ in that the medium forecast  assumes that per-capita con-
  sumption rates stabilize after 1995.  The low forecast assumes
  no increase in per-capita consumption rates after 1985, leaving
  population growth the controlling factor from that point on.
  Population figures used by  the Board are presented in Table 2.4-3,
  and reflect regional demographic trends and economic prospects
  on a county-by-county basis (TE-301).
TABLE 2.4-3
PROJECTED TEXAS POPULATION,
USED AS BASIS FOR POWER DEMAND
Projected
Year Population
1980 13,400,000
1990 15,594,000
2000 18,276,000
Source: TE-301
1980-2000
PROJECTIONS
Percent Change
10-Year
Period
19.6
16.4
17.2

  1 Figure 2.4-1  shows  the  location of all present and announced
  lignite-fired stations  for which sites are known.  Tables 2.4-1
  and  2.4-2  list the  capacities, schedules, and owners/operators
  of these plants  and the associated mines, respectively.
                                29

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LO
O
                                                                                         SCALE IN MILES
                                                                                         -i     i—
                                                                                      0  20   50
100
                    PRESENT  (*) AND  PLANNED (•) LIGJITE-FIRED MINE-MOUTH  POWER PLANTS

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RADIAN
CORPORATION
                               TABLE 2.4-1

                        LIGNITE GENERATION PLANTS
Year of
Start-Up

1976 and
earlier
1977
1978
1979
1980
1981
1982
1983
1984
1985
*Plant name
Plant Name
Lignite
Sandow #1, 2 & 3
Big Brown #1 & 2
Monticello #1 & 2
Martin Lake #1
Monticello #3
Martin Lake #2
Martin Lake #3
San Miguel #1

Sandow #4
Gibbons Creek //I
Forest Grove #1
Martin Lake #4
San Miguel 92
Twin Oak #1
LCRA*
South Hallsville
Twin Oak #2
Gibbons Creek #2
and location not yet
mw

360
1150
1150
750
750
750
750
400

545
400
400
750
400
562
750
660
562
400
assigned.
Operator

Texas Power and Light /Alcoa
Texas Utilities Services, Inc. (TUSI)
TUSI
TUSI
TUSI
TUSI
TUSI
South Texas and Medina Electric
Co-op

Texas Power and Light /Alcoa
Texas Municipal Power Pool
TUSI
TUSI
STM Electric Co-op
Texas Power and Light
Southwest Electric Power
Texas Power and Light
TMPP

SOURCE:   WH-124
                                    31

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                                                       TABLE 2.4-2
N>
PROJECTED LIGNITE PRODUCTION
BASED ON INDUSTRY ANNOUNCEMENTS
1977 1978 1979 1980
Freestone County
TU— Big Brown 5.4 5.4 5.4 5.4
Grimes County
TMPP — Gibbons. Creek
Harrison County
SWEP — South Hallsville
Henderson County
TU — Forest Grove
Limestone County
TU~Oak Knoll
McMullen County
STM— San Miguel i.u *./
Milam County
TU— Rockdale 2.0 2.0 2.0 2.0
Panola County
TU — Martin Lake 4.5 8.0 11.5 11. i
Robertson County
TU — Twin Oaks
Rusk County
TU--Mill Creek
Titus County
TU— Monticello b.O y.b y.b y.o
Total 17.9 25.0 29.5 31.2
FOR POWER
GENERATION
(Million Tons
1981
5.4
2.7
1.0
2.7
4.8
11.5
9.6
37.7
1982
5.4
2.7
3.8
2.7
4.8
12.5
9.6
41.5
Per Year)*
1983
5.4
2.7
3.8
2.7
4.8
14.0
1.0
9.6
44.0
1984
5.4
2.7
3.0
3.8
3.7
4.8
14.0
4.5
9.6
51.5
1985
5.4
5.4
3.0
3.8
5.4
4.8
14.0
7.0
9.6
58.4
Full
5.4
5.4
6.0
3.8
7.0
5.4
4.8
14.0
7.0
7.0
9.6
75.4
        TU—Texas Utilities
        TMPP—Texas Municipal Power Pool
SWEP—Southwest Electric Power
STM—South Texas and Medina Electric Co-op
                                                            II
        *Assumes 75% capacity factor,  10,400  Btu/kwh,  and lignite  heat  content typical  for  location  of  plant.

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RAMAN
            The  low forecast was chosen for this study, based on a feel-
  ing  that higher prices  and advances in energy-saving technology will
  tend to  curtail growth  in per-capita electrical energy consumption.
  The  Board  broke out its statewide  totals into component river
  basins and basin  segments, based on the assumption that the pre-
  sent relative  production of  power  between them prevails through-
  out  the  forecast  period.  From these figures a composite was de-
  rived of total power production  in all those basin units which
  could be served by lignite.   Figure 2.4-2 shows the  geographical
  extent of  this somewhat arbitrary  area.

            To arrive at  a forecast  of the proportion  of this total
  power output that might be  fired by lignite, it was  first assumed
  that in  1990,  15  percent would come from nuclear power and 10
  percent  from gas  and oil, and that by 2000  only 5 percent would
  still be gas-fired and  15 percent  would be  nuclear power.1  These
  estimates  are  purely subjective  and are loosely based on the
  amount of  nuclear capacity  currently planned for Texas, expected
  to grow  moderately due  to the limited availability of uranium and
  uncertainty over  the availability  of other  fuels.   Although pre-
  sent  federal policy strongly favors phasing out all natural gas
  in industry and utility boilers, it is felt that there will be
  some  exemptions made for peaking units.  Also, the practical dif-
  ficulty of tying  down fuel supplies needed  for the short-term,
  massive  conversion required  in Texas will probably force some
  utilities  to continue using  gas  after 1985,  even if faced with eco-
  nomic penalties.

            Up to now,  a  fifty-fifty split in the Texas utility
  market has been envisioned between lignite  and western, low-sul-
  fur coal.   However,  the recently enacted Clean Air Act Amendments

  Although  most projections give nuclear a larger than 15% share by
  2000  this  conservative estimate  reflects  the growing uncertainty
  over'such items  as  the licensing  and cost of plants, fuel costs,
  waste disposal,  and nuclear proliferation  in general.

                                33

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       Canadian
     EXPLANATION

^*»^*- River and Coastal Baiin Boundaries

—	Zone Boundaries

   © Zone Numbers
                Neches
               Nvchrv
               Trlnitv
            '-Trinity
          , ..Trinity-
            San Jacinto
         •San Jacinto
       San Jacinto-Brazos
      Brazos-Colorado
   LColorado-Lavaca
  t-lavaca
 L Lavaca*Guadal u pa
 'Guadalupe
 San Antonio
San Antonlo-Nuecei
Nueces
Nuec**-Rio Grande
                          FIGURE  2.4-2
  RIVER AND COASTAL  BASINS  AND ZONE  DELINEATIONS
          SHOWING AREA POTENTIALLY  SERVICE BY
           LIGNITE-GENERATED  ELECTRIC  POWER
                         (SOURCE:   TE-301)
                                   34
                                                                            02-195

-------
and the Department of Interior's "short-term criteria" for leas-
ing federal coal both suggest a sharp increase in demand for Texas
lignite.1  Figure 2.4-3 presents an envelope of lignite demand
for the years 1985-2000.  This envelope is bounded by the two
extremes of zero coal imports and fifty-fifty sharing, reflecting
these recent developments.  When regulations and implementation
strategies for the new clean air and leasing policies are developed,
a certain amount of competition from non-federal western and
perhaps midwestern coals will pull the curve away from the upper
limit.  Furthermore, consumption at this rate would consume vir-
tually all of the present strippable lignite resources, using
the most generous estimates, by 2030.  Universal requirements
for "best available control technology" (BACT) to control sulfur
emissions—scrubbers, fluidized-bed combustion, or coal-cleaning--
will probably continue to favor lignite over western coal.
Thus, the half-and-half distribution prevailing in currently
planned new generating capacity may never again be realized.

          The cumulative  demand for lignite to 1985 was calculated
on the basis of announced plants, and thereafter on the basis of
6,000 tons per year per MWe.  The conversion factor is based on
an average of the ratios  of fuel input to power output for nine
announced plants, covering the full range of lignite character-
istics  (WH-124).  Table 2.4-4 summarizes both power generation
and mine output for the year 2000 and indicates the number of
new, 1500 MWe generating  stations that correspond to those fore-
casts.  This station size reflects current planning, and consists
of two side-by-side 750 MWe units, operating at 60 percent load
capacity.  (This capacity was assumed by the Texas Water Develop-
ment Board, based on historical operating experience, and is
carried over into this forecast.)
aA more detailed discussion of these policies is found in Chapter
 Five.
                               35

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                                                               257
CO
259 -i
252 -
245 -
236 -
231 -
224 -
217-
210.-
203 -
196 -
189 -
182-
175 •
168 •
161 -
154 -
147-
140 -
133-
126 •
119 -
112 •
105 -
  98-
  91 •
  84 -
  77-
  70-
  63-
  56-
  49-
  42-
  35-
  28-
  21 -
  14-
   7-
   0-
            EXIST1NG  PLUS
              ANNOUNCED
              CAPACITY
                        44
           25
             30
                32
         18
                                                                   UPPER  BOUND:
                                                                  NO COAL IMPORTS
                         128
                             LOWER BOUND:
                         HALF  COAL. HALF LIQNI
                       1
           FORECAST CAPACITY
        ASSUMING STABLE PER-CAPITA
           POWER  CONSUMPTION (?)
       1977   1980
                       1985
1990        1995
FIGURE 2.4-3
2000
                    POTENTIAL RANGE OF LIGNITE CONSUMPTION BY UTILITIES

   Q  Lignite consumption based  on known quality of lignite in site area
   ©  Lignite consumption based  on average of 6,000 tons/MWe
                                                                         36

-------
       Upper
       Bound
       Lower
       Bound
UJ
Existing and Planned, to 1985
Generating
Capacity
10,739 HWe
10,739 me
No. Of
Stations
9
9
Yearly Lignite
Production
59 MST
59 MST
Additional Growth Total in Year 2000
Generating
Capacity
32.061 MWe
10,661 MHe
No. Of
Stations
21
7
Yearly Lignite
Production
198 MST
69 MST
Generating
Capacity
42,800 MWe
21,400 MWe
No. Of
Stations
30
16
Yearly Lignite
Production
257 MST
128 MST
                                                 TABLE 2.4-4

                                SUMMARY OF  FORECAST LIGNITE USE BY UTILITIES

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    CHAPTER THREE



ENVIRONMENTAL SETTING
          38

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RADIAN
3.0       ENVIRONMENTAL SETTING

3.1       Human Components

          The purpose of this section is to present a brief
cultural overview of the Texas lignite belt.  Emphasis is on
those cultural features which may be important considerations in
future lignite development.

          A macro-regional approach has been adopted since such
a large area is being considered.  This approach emphasizes the
geographical variation of cultural factors within the region.
The lignite of Texas is in 66 contiguous counties; however, to
sufficiently show the variation, a 124-county area encompassing
most of East and South Texas has been adopted.  This is necessary
because the important features of the region become obvious only
when examined from this broader perspective.

3.1.1     Population

          Historical Trends

          Texas is a rapidly growing area with substantial in-
migration from other states and countries.  However, the process
of in-migration has been  in progress throughout the area's history.
An examination of the origins of the early  in-migrants give  con-
siderable insight into the present cultural variation of the study
area.

          Figure 3.1-1 shows the traditional cultural patterns which
evolved in the nineteenth century in East and South Texas  (JO-257,
JO-258, JO-259, ME-189).  Eastern Texas was colonized by at  least
four distinct groups coming from different  directions.  From the
south came the Spanish and Mexican influx.  From overseas  came
Europeans who settled in  the "German Hill Country" and the area marked

                                39

-------
                                \ '( 4 > \	-2V,	X  >%.
                                >S [ 1 )  \   /  v   /     \
                                x  \ v   v  xN  x    x. y      x
                                  X"^—^ ~Z  \/      V*s!      V,
2VV-A	/   —
/>\    /   ->
                                    \  X\ X      /  V.     ? 'f\

                                     \y   vf"      .-^    \   x   1

                                     Y     \    /  ^~\.\  S  	>
                                     f     ^ j^^>^     ^ \ S      J

                                     J     X  I  \      :k       I
                                    ^   ^x   \   \     s*^      V
                                     \x  ^   V-_-/\~__  y  f^    ^\

                                                    SCALE IN MILES


                                                    se=E=

                                                0   20     50       100
UPPER  SOUTH


LOWER SOUTH


GERMAN HILL  COUNTRY


SPANISH-MEXICAN


MIXED



    FIGURE 3.1-1
                                     SOURCE:  ADAPTED AR-RF-089
                          r.- tsn-r f i-t i

-------
 RADIAN
 "Mixed."   From the  east  (Louisiana, Mississippi, etc.)  came  the
 "Lower  South"  element, while  from the northeast  (Missouri, Arkansas,
 Tennessee,  etc.)  came  the  "upper  South"  element.

           The  Spanish-Mexican region still has a distinctive
 Latin influence,  but it  has been  moderated by years of  "Americani-
 zation."   The  German Hill  Country retains a Teutonic character,
 especially in  its architecture.   Settlers of that area  came  from
 Europe  just as did  immigrants to  the "Mixed" region of  Central
 Texas.   In the "Mixed" region,  Europeans and settlers from the Upper
 and  Lower  South were dominant,

           The  Upper South  area marked "1" was  settled by middle-
 class white southerners  who engaged in market-oriented  cotton and
 grain farming.  The area labelled "2" was strongly influenced by
 Appalachian hill  folk who  engaged in subsistence agriculture.

           The  Lower South  area had three major components.  Area
 "1" was a  continuation of  the plantation aristocracy with large
 numbers of rural  blacks  and a dependence upon cotton farming.
 Area "2" had mostly poor whites and subsistence agriculture.
 The area marked "3" was  a  blend of the plantation aristocracy
 from Louisiana and  foreign immigrants.

           Today's socioeconomic characteristics strongly reflect
 those nineteenth  century settlement trends.

           Contemporary Trends

           The  clusters of  high population density are associated
with the metropolitan areas (Figure 3.1-2).   Obviously. Dallas/
Ft. Worth  and Houston are  the major centers.  However,  the
urbanized  strip from San Antonio northeast to Waco is also very
dense.   What is critical to this study is the relatively low
population  density which characterizes the lignite belt.

                                41

-------
                                                                                 SSHERMAN-DENISON
                                                                                        TEXARKANA
                                                                  DALLAS-
                                                                FORT WORTH
                                         KILLEEN-
                                         TEMPLE
                                                         BRYAN-
                                                    COLLEGE STATION
   SAN
 ANTONIO
                                                                                         LONGVIEW
                                                                                         MARSHALL
  McALLEN-
   PHARR-
 EDINBURG
                           HOUSTON"
                                                                      BEAUMONT-
                                                                      ORT  ARTHUR-
                                                                        ORANGE    SCALE ,N M|,ES
                                              GALVESTON-
                                              TEXAS CITY
                                                                                0  20   50
                                                                         100
BROWNSVILLE-
 HARLINQEN-
 SAN BENITO
   NOTE: SMSA AREAS ARE EXPANDED WHEN THE
    ESTABLISHED CRITERIA ARE MET. WILLIAMSON
  AND HAYS  COUNTIES HAVE RECENTLY BEEN ADDED
TO THE AUSTIN SMSA.  SIMILAR SITUATIONS MAY EXIST.
SOURCE:
US-RF-303 AND US 343
                                         FIGURE 3.1-2

-------
RADIAN
          Probably more than any other factor, the lack of massive
metropolitan development in the Texas lignite is critical to the
future of the region.  This location of this environmentally  '
sensitive resource between major metropolitan centers is important
to critical impact and policy analysis.

          The lignite belt was not a dramatic growth region in
the 1960's, especially in the central and southern portions.
The northern portion experienced moderate growth because of the
rise of its small metropolitan center  (Tyler/Longview), with the
accompanying industrial diversification that occurred in that
period.  Since 1970, there has been a somewhat surprising resur-
gence of nonmetropolitan areas, not only in Texas, but throughout
the United States (BE-431).  Most of the lignite belt has ex-
perienced net in-migration since 1970, reversing the net out-
migration of the previous three decades.

          Several generalizations can be made regarding future
population growth in the 124-county region.  First, the counties
surrounding large urban centers will experience considerable
growth.  For instance, the counties contiguous to Harris County
(Houston) will grow through in-migration.  Second, nonmetropolitan
counties with access to metropolitan employment and services will
grow through in-migration.  This includes most of East Texas,
but little of South Texas.  Third, there is evidence that very
large cities may not continue to grow in the near future (BE-
431) .  For instance, Dallas and Tarrant Counties both experienced
net out-migration from 1970 to 1974 (US-632).   Smaller metropolitan
centers will be the growth areas of the near future.  Finally.
population projections for Texas are of limited value because the
state is changing so rapidly.  Projections based upon historical
trends cannot reflect unknowns such as energy development in
rural areas.  For this reason, no population projections are
presented.
                              43

-------
RADIAN
            Contemporary Chracteristics

            The "historic trends" section reflects  current  ethnic
  and racial patterns in the study area.   The study area  is multi-
  ethnic/racial in character.   Spanish-surnamed people  (mostly
  Mexican-Americans in Texas)  are dominant in the southern  areas.
  Just as distinctive, although not as  extensive, is the  large
  black population in East Texas counties where plantation  agricul-
  ture from the "lower South"  was important in the  nineteenth cen-
  ture.

            The area with a high proportion of Spanish-surnamed
  has a  low median age.   However,  in areas with large percentages
  of blacks the median age is  relatively  high because large numbers
  of young blacks  in these counties migrated to metropolitan centers
  in the 1950fs and 1960's.  In general,  the population of  the lig-
  nite belt north  of the Colorado River is relatively old compared
  to the state median (26 years)  and has  a low percent in the younger
  age groups.   The area south  of the Colorado River is vastly dif-
  ferent,  with its young,  predominantly Mexican-American popula-
  tion.

            The entire Texas lignite belt is characterized  by a
  high incidence of poverty and low education levels.  The  nonmetro-
  politan lignite  belt of Texas is a relatively depressed area
  when compared to the metropolitan areas to the southeast  (Hous-
  ton, Beaumont, etc.) and the west (San  Antonio to Sherman).
  This under development of human resources may be critical  to the
  future of the area.

  3.1.2      Economic Structure

            As indicated above, the population of the entire lignite
  belt has a high  incidence of poverty1 with respect to the surround
  'As defined by the U.S.  Bureau of the Census (US-343)  baseri
  income level.                                          «ocu
                                44

-------
RADIAN.
  ing metropolitan areas,  and poverty  increases along a line from
  Northeast  Texas  to  South Texas.  Many  factors are highly correlated
  to these trends,  with industrial structure being one important
  consideration.

            The  lignite belt  is  relatively  low in employment in the
  service sector (service,  trade, finance,  insurance, real estate,
  government,  utilities,  etc.)-  The service sector is critical to
  economic prosperity.

            In addition,  the  economy of  the lignite belt  is relatively
  low in manufacturing  employment  (SIC 19 to 39), especially when com-
  pared to the large  metropolitan areas  surrounding the region.  The
  obvious exception is  the Longview-Tyler-Marshall area of North-
  east Texas,  where manufacturing employment is higher.

            Thus,  the lignite belt relies heavily upon agriculture
  and extractive industries.   Oil and  natural gas are produced in
  nearly every county in the  lignite belt with a notable  concentra-
  tion in the  northeast.   Agriculture  is still extremely  important,
  especially in  the Blackland Prairie  region of Central Texas.
  The employment in agriculture  in the East Texas areas near
  Louisiana  has declined in recent  years,  showing the relatively
  poor  potential of that area for row crops.   Both  crops  and
  livestock  are important sources  of revenue throughout  the  124-
  county  region, although the area near  Louisiana is  decreasing
  in productivity.  The Rio Grande  Valley  and South Texas are very
  dependent  upon irrigated agriculture.

            Crop patterns have changed dramatically in the 20th
  century.   Texas cotton production since  1900 has  shifted from
  the Blackland Prairie region of Texas  to  the High Plains,  with
                               45

-------
RADIAN
CORPORATION
 the  advent of irrigation.   Yet,  cotton is still an important crop
 to the region.   Grain sorghum, which has been replacing cotton in
 many areas,  is  most  important in the area south of the original
 Texas cotton belt.

           The peanut is  of  particular importance to the lignite
 belt in that it is perhaps  the only row crop that might compete
 with surface mining  for  the sandy soil that overlies the Wilcox
 formation  lignite.   Hay  is  the other possibility.

           Since hay  and  pasture  are widespread throughout the
 lignite belt, and since  grain sorghum and corn are locally avail-
 able,  cattle production  is  important to the economy.  In fact,
 probably the most significant agricultural trend in the lignite
 belt has been the growing importance of cattle production.

           One last aspect of agriculture is the timberlands of
 East Texas.   For the most part,  the lignite belt vegetation con-
 sists  of species not now vital to Texas forest industries.  How-
 ever,  part of the lignite region extends into the Pineywoods of
 East Texas where timber  is  a valuable resource.

           A  final important measure of the economy is unemployment.
 The  region north of  the  Colorado River has relatively low unemploy-
ment  rates,  while fairly extensive areas of South Texas have ex-
 tremely  high rates.   The portion of the lignite belt north of
 the  Colorado River has no large, significant pockets of unemploy-
ment.  However,  the  entire  State of Texas is experiencing relatively
 low  unemployment since Texas' economy is currently strong.
Also,  the  excess labor of the lignite belt, which might now be
unemployed,  migrated from the region in the 1950's and 1960's
so that  stable  employment characterizes the region today.
                               46

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RADIAN
  3.1.3      Land Use

            Land use  in the  lignite  belt  is  closely related  to the
  quality  of the soils  and the availability  of  other natural resources
  For instance,  the soils  of the Blackland Prairie region  to the
  west of  the lignite belt in Central  Texas  is  extremely productive.
  Consequently,  it is almost completely cultivated  (cotton and sor-
  ghum predominantly).   Scattered through that  region  are  agricultural
  service  towns.

            The  Post  Oak Savannah region, which covers the central
  portion  of the lignite belt, is less productive in  crop  yields.
  Much former cropland  has been allowed to go fallow.   That  region
  has recently experienced a large rise in the  acreage devoted to
  Coastal  Bermuda for improved pasture.  East of the  Post  Oak
  Savannah region is  the East Texas  Pineywoods  region. Relatively
  low acreages in that  area are devoted to crops. Natural resource
  extraction (lumbering, oil, and gas) is an important land  use  in
  this far East  Texas area.

            The  Coastal zone from the  Louisiana border to  the Corpus
  Christi  area is a productive area  agriculturally, with a large
  acreage  in rice,  soybeans, and grain sorghum,   A dominant  feature
  of  this  region is the Houston-Calveston-Beaumont metropolitan  area
  with expanding residential, commercial, and industrial land uses.
  Interspersed all along the Texas cost from Beaumont  to Corpus
  Christi  are refining  and petrochemical  industries and oil  and
  gas extraction activities.

            Far  South Texas  is an arid zone  with relatively  unpro-
  ductive  soils.   The land has a low carrying capacity, so the popu-
  lation is  low.   Range land for cattle and  mineral extraction are
  the notable land uses.   An exception is the Rio Grande River
  Valley,  where  intensively  cultivated, irrigated crops of a wide
  variety  are grown.  However, nearly  all irrigated agriculture  in
  South Texas occur beyond the lignite belt.
                                 47

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RADIAN
CORPORATION
           The  problems  associated with controlling expanding
metropolitan land use exist only in the northeast portion of
the  lignite belt.   The  Tyler-Longview-Marshall area is merging
into one  continuous metropolitan area functionally linked by
commuting and  economic  interdependence.  Controlling undesirable
land use  trends  such as rural "scatterization" (low density tract
developments)  may already be a problem for that region.

           A much more thorough treatment of land use on and near
the  lignite belt will be important as a planning tool as develop-
ment  increases.

3.1.A     Infrastructure and Recreational Resources

           Included  in the classification "infrastructure" are
those systems  or mechanisms by which society serves its aggregate
needs.  Hence, concern is with those facilities and services
which all  people use, and which have such high costs that collec-
tive payment (taxes and/or fees) is required.

           Recreational facilities of major concern are the large
areas such as  state and national parks and wildlife refuges
(Figure 3.1-3).   There are many of these facilities in East and
South Texas.   Both  Davy Crockett and Angelina National Forests
are underlain  by potential lignite deposits, as is Bastrop State
Park.  Particularly noteworthy are the national forests of East
Texas.  Also important as recreational resources are the many
lakes and  reservoirs of the entire 124-county area.

           Some 230  National Register Historic Sites are located
in the 124-county region.  However, the bulk of these are in the
metropolitan areas  outside the lignite belt, such as Austin and
San Antonio.   Fayette County (8 sites), Gonzales County (5 sites),
and Marion County (15 sites) have the highest numbers of National
Register  sites within the lignite belt.

                              48

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                                               I.	
                                              rt	"^—i
                                              I *"*	1	IRII* Olflnc
                                              I      Njtiionil Crani
                                                                                    OKLAHOMA
                                                                                 Oklahoma City
                                                                                                                                 ARKANSAS
                                                                                                                            LmteRock*

                                                                                                                       Hoi Sptlngi*
                                                                                                                                Pta« Blu'l *
                   NEW MEXICO


                              RfHWfll,
               ,L»Crucn
 i       i
•L.-.J
              iru'N
                  '

                         Guidaluiw Mounliln
                           NiUoiMlPick       *»     60.

REPUBLIC OF MEXICO
           STATE AND FEDERAL
      PARKS AND WILDLIFE  AREAS
                 National parks

                 National forests

                 National graitlan
             U   Nstio.ial v/ildlifu rofugcs
             rc   Slate purks
         No;»- To irt*nn;y parks irr the llblF lillld Vniion
         Catiftng SMf Pjtkt on r>»9* 107. Thr number t uied to
         •tftnlily ih« p«tkt xwi
                          *^v    Fon &ntl Noliontl
                            •     HUloricat Silo
                                                              ,Monclovi
                                                         FIGURE  3.1-3
                                             PARKS  AND  RECREATION  LANDS

-------
          The Texas  lignite belt is not well served by highways,
especially  in its Central Texas portion.  Interstate highways
connect  the three corners of a triangle made up of San Antonio,
Houston, and Dallas.  However, highways to these three cities
from within the triangle, a major portion of the lignite belt,
are neither as direct nor as good.  This is a by-product of the
area's relatively sparse population.  Northeast Texas has some-
what better connections with major metropolitan areas via inter-
state highway, reflecting the higher population density.

          By contrast, rail transportation is a positive feature
of the lignite belt.  The entire region is crisscrossed by numerous
lines giving this area access to major regional centers and Gulf
Coast ports.  The nearest port facilities are in the Houston-
Beaumont area.  Major commercial airlines serve Houston, Dallas,
San Antonio, and Austin.  The smaller metropolitan centers
(Waco, Longview, Texarkana) have only limited commercial airline
service.

          The number of people per physician in the lignite belt
is higher than in surrounding metropolitan counties.   This is not
to say that  health care in those areas is deficient.   It appears
rather that  many people of the lignite belt drive to the metropoli-
tan areas for medical services and hospital care.

          Suitable housing is normally in short supply in non-
metropolitan areas as reflected in a recent study in Milam County
by Radian.    Few rental units are usually available and most un-
anticipated  growth has to be accommodated in mobile homes.

          Many educational facilities in the lignite belt--
particularly some rural school districts of the region--may now
be experiencing problems in terms of quantity and quality of
educational  resources.
                                50

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          The same can be said about municipal services and
facilities in the lignite belt.  Already, many areas have sewerage
systems in need of upgrading and/or expansion.  Sewage systems in
other areas might violate water quality and effluent standards if
sudden population growth took place.

          In general, the demand for public services and facil-
ties is low in the lignite belt because of the small size of the
population.  Likewise, the supply is limited to the essentials,
such as water, sewers, police, and fire protection.  The economies
of scale of metropolitan centers, which are necessary for expan-
sion, do not appear to be operating in the lignite belt.  Hence,
a thorough analysis of the existing facilities and services would
be an important tool in planning for increased lignite development

3.2       Physical Components

3.2.1     Climate and Air Quality

          Climatic Characterization

          The climate throughout the Texas lignite belt is humid
and subtropical with hot summers and mild winters.  Precipitation
occurs mostly in the form of showers and thundershowers.  Ex-
tended periods of light rain or drizzle, however, do occur during
the winter months.

          Precipitation amounts vary significantly throughout the
Texas lignite belt.  The southern portion of the lignite belt
(Webb, Zapata, and Starr Counties) receives only 18 inches on an
annual basis, while the northeast portion (Jasper and Newton
Counties) receives 54 inches.  September and May are the rainiest
months throughout most of the area,  while January, March, and
July are the driest.
                               51

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           The  average  annual temperature throughout the lignite
belt  is  69°F,  ranging  from 74°F in the southern portions to 66eF
in the northeastern portions.  Although extended periods of below-
freezing weather  are uncommon, freezing temperatures are recorded
an average of  25  times during the year in the northeastern portion
of the lignite belt.

           Drought conditions are not altogether uncommon in the
study region.  A  region can be arbitrarily noted as undergoing
drought  conditions whenever the region experiences 75 percent or
less of  the normal rainfall during the year.  The highest frequency
of drought conditions occurs along the extreme southern portions
of the lignite belt and over the southwestern portion (Edwards
Plateau).  Throughout these two regions, the drought frequency
is 18 percent.  This means that drought conditions occur in 18
percent  of the years of record.  The lowest drought frequency,
12 percent, occurs in the northeastern portion of the study region.

           Although the drought frequency over the southern portion
of the lignite belt and the frequency over the southwestern por-
tion are the same (18 percent), the duration of droughts varies.
The southern portion has numerous droughts of short duration while
the southwestern portion has less numerous but longer lasting
droughts.

           The  mean annual lake evaporation ranges from 51 inches
in Jasper  and  Newton Counties  (northeastern region of the lignite
belt) to 77 inches in Maverick County  (southwestern portion of
the lignite belt).  Throughout most of the study region, the
mean annual lake  evaporation exceeds the annual rainfall.
                               52

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RADIAN
CORPORATION
          One of the important factors to consider in the assess-
ment of the surface reclamation potential of the Texas lignite
belt is the frequency of occurrence of desiccating or drying
conditions.  Desiccating conditions occur during the combined
presence of low relative humidity, high temperatures, and high
winds.  During these harsh conditions, the increase in the rate
of evapotranspiration from plant surfaces cannot be matched by the
rate water is taken up  through the root system.  Consequently,
wilting can take place  even though adequate moisture is present
in the soil.  The highest potential of desiccating conditions
in the lignite belt occurs in the Maverick-Zavala-Dimmit County
region of South Texas.  Conversely, the lowest potential for
desiccating conditions  occurs in the Jasper-Newton County region
of Northeast Texas.

          The Texas lignite belt has an average growing season
of 275 days, ranging from 235 days in the northeastern portion
to 305 days in the southmost region (Starr County).  This grow-
ing season is defined as the number of days between the last
freeze in the spring and the first freeze in the fall.  (Sources
for the preceeding discussion were OR-021, US-308, NA-360, and
WE-225).

          Existing Air  Quality

          The National  Ambient Air Quality Standards (NAAQS),
which have been established for six pollutants, are summarized
in Table 3.2-1.  Areas  in which the NAAQS have been previously
violated are classified as non-attainment areas.  Areas in which
the NAAQS are currently being violated extensively or areas which
are projected to violate the NAAQS within the next ten years have
been designated as Air  Quality Maintenance Areas (AQMA's).
                               53

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  CORPORATION
                              TABLE  3.2-1
     NATIONAL  PRIMARY AND SECONDARY AMBIENT  AIR QUALITY STANDARDS
Pollutant
Carbon
monoxide
Hydrocarbons
(Nonmethane )
Nitrogen
dioxide
Photochemical
oxidants
*Particulate
matter

*Sulfur
dioxide

Type of
Standard
Primary and
secondary
Primary and
secondary
Primary and
secondary
Primary and
secondary
Primary
Secondary
Primary
Secondary
Averaging
Time
1 hr
8 hr
3 hr
(6 to 9
a.m. )
1 yr

1 hr

2k hr
2k hr
2k hr
2k hr
2k hr
1 yr
3 hr
Frequency
Parameter
Annual maximum1
Annual maximum-
Annual maximum
Arithmetic

Annual maximum 1

Annual maximum
Annual geometric mean
Annual maximum-'-
Annual geometric mean
Annual maximum
Arithmetic mean
Annual maximum-1-
Concentration
Hg/mi
140,000
10,000
160
100

160

260
75
150
60
365
80
1,300
ppai
35
9
0.21)
0.05

0.08

—
— «•
0.03
0.5
*Particulate and sulfur dioxide data reported here were obtained using the specified
 federal reference methods.
1,
 Not to be exceeded more than once a year.
                                     54

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RADIAN
           No  ambient  air monitoring data are available for the
  rural portions  of  the study  area.  The  only monitoring data avail-
  able are  for  the urbanized areas  of Austin, Dallas, Houston, San
  Antonio,  Mt.  Pleasant,  Texarkana,  and Tyler.  These data reflect
  urban conditions and  are therefore not  representative of the
  lignite belt  in general.  The  urban measurements  for 1975 shown
  in Table  3.2-2  list the most rural sampling data  for each city
  in the direction nearest the lignite belt.

           The Dallas  and Houston  Air Quality Control Regions (AQCR)
  are classed as  non-attainment  areas and also as Air Quality
  Maintenance areas  (AQMA) for both particulates and oxidants.
  The San Antonio AQCR  is classed as a non-attainment area for
  particulates.   The other regulated pollutants were below federal
  standards at  all sites  except  for Tyler, which exceeded the oxidant
  standards in  1975.  The pollutant levels in the rural portion of
  the area  are  assumed  to be significantly lower for all pollutants.
  One rural monitor  for particulates in Montgomery  County, Arkansas,
  about 75 miles  from the study  area, measured a maximum 24-hour
  concentration of 73 yg/m3 with an annual geometric mean of 34
  Ug/m3.   This may be similar  to background total suspended (TSP)
  concentrations  in Texas.

  3.2.2     Water Supply. Availability and Use

           Surface Water

           The principal river  basins of Che Texas lignite belt
  are shown in  Figure 3.2-1,   This  area is not drained by any one
  principal stream, but contains portions of several basins cross-
  ing it roughly  at  right angles.  Above  the lignite outcrop area,
  the drainage basins of  these streams are not only smaller but
  also receive  significantly less precipitation and generally have
  higher evaportranspiration than in those parts of the drainage
                                55

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                                                              TABLE 3.2-2
Ui
en
THE 1976 AMBIENT AIR QUALITY CONCENTRATIONS *
IN THE URBAN



Site Location
Austin
Bryan
Dallas
Houston (Cypress)
San Antonio
Ht. Pleasant
Texarksna
Tyler


Identi f lent ion
Number
45022012
45067001
45131002
45233004
45457036
45377001
45516001
45524002
Total
Maximum
24-Hour
Average
193
169
175
166
202
146
194
151
AREAS AROUND THE LIGNITE BELT
Suspended Particulates
2nd Maximum
24 -Hour
Average
163
110
161
148
96
103
180
111

Geometric
Mean
60
74
69
62
53
56
99
55
Maximum
24-H'inr
Average
9
2
19
8
-
96
18
15
Sulfur
Dioxide
(S02)
2nd Maximum
24-Hour
Average
2
2
8
2
2
67
14
2


Arithmetic
Mean
2
2
2
2
2
6
3
2
Nitrogen
Dioxide
._!N02) ...

Arithmetic
Mean
28
4
54
23
24
23
25
30
Pliotorhemlc.il
Oxldnnts

ArltliiiiiM.li-
Mean
108
56
)y
\M
146
150
134
16Q

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                                                       0   20   50
100
               FIGURE 3.2-1
PRINICIPAL RIVER BASINS OF THE  LIGNITE  BELT

-------
 basins nearer the  coast.   This becomes more pronounced  to  the
 south and west,  as is  illustrated  in  the  directional  trend of  low
 flows and average  annual  runoff  from  the  basins  (Table  3.2-3).
 Flood flows  can  occur  at  any  time  of  the  year on  these  streams
 out flows are generally highest  in March  and May.  Some of the
 most intense point rainfalls  in  the United States have  occurred
 in the general vicinity of the lignite belt, and  significant
 flooding  can take  place on even  small tributaries.  Lower  flows
 generally occur  during August and  September (TO-028).

           The natural  flows of these  streams are without exception
 materially affected by upstream  reservoir regulation, agricultural
 md municipal diversions,  and return  flows.  Water from the two
 largest basins,  the Brazos and Colorado Rivers, is highly  regulated
 with very large  consumptive withdrawals during the summer  months
 for rice  farming on the upper coastal plain near Houston,  The
 waters of the Trinity  River and  its San Jacinto tributary  serve
 as part of the water supply for  the City  of Houston,  the nation's
 fifth largest city.  The  Trinity River and the San Antonio River
 (tributary to the  Guadalupe River) receive municipal  and industrial
 effluent  respectively  from the large  Dallas-Fort Worth  metroplex
 and the city of  San Antonio,  the nation's tenth largest city.
 During periods of  low  natural discharge these effluents make up
 most of the  actual flow.

           Figure 3.2-2 indicates the  relative amounts of surface-
 water resources  used for  different types  of demands within the
various basins.  Generally, a much higher percentage of total de-
mand goes  for  irrigation  in the more  southerly basins.  Toward the
 north,  where the bulk  of  the  highest  quality lignite  is found,
 manufacturing and  municipal uses predominate,  In the central
 portion,  municipal and agricultural uses  generally dominate the
 total demand.  Mining  uses very  little of the total water  supply,
                                58

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Ln
VO
                                                        TABLE 3.2-3

                                    SUMMARY OF STREAMFLOW IN GULF COAST LIGNITE REGION
Unregulated
Most downstream
fresh water gaging
station on
Calcasieu River
Sabine River
Neches/Village Creek
Trinity River
Brazos River
Colorado River
Guadalupe /San Antonio
Nueces River
Drainage
Area (I)
(mi2)
1,700
9,239
(8,811)
17,186
44,340
41,650
(9,119)
15,600
Average
Flow (£)
(cfs)
2,613
8,443
(7,082/4,843)
7,155/6,489
7,508
2,285r
(2,219)
858
Average
Runoff
(cfs /mi2)
1.54
0.91
0.80
0.42
0.17
0.55r
0.24
0.55
Average
Annual
Runoff
(in)
20.9
12.3
10.8
5.69
2.30
0.74r
3.24
0.74
Extremes
Low High
(cfs)
r
270
- -
102
40
0
small
0
182,000
121,000
- -
111,000
797,000
84,100
- -
141,000
         Notes:
         2.

         3.
Figures in parentheses indicate summation of data on individual streams;
significant regulation of flow; slash mark between figures indicates unregulated/regulated
flow averages.

Mississippi River data through iy65, others through 1973.

Several very large springs discharge to Guadalupe River system.
         Source:  US-394 through 398; US-146 through 150.

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                                                                   SCALE W MILES
                                                                •aa
                                                                0   20
       100.000 ACRE FEET

       200,000 ACRE FEET

        50,000 ACRE  FEET
IRRIGATION

MUNICIPAL
                                                100
                                  MANUFACTURING  V///J
MINING

STEAM-ELECTRIC

LIVESTOCK
                 FIGURE  3.2-2
19 7 A  SURFACE WATER USE  FOR DRAINAGE BASINS

-------
RADIAN
 power generation uses large quantities in the Trinity and
 Guadalupe basins.  In the Guadalups basin, most of this water
 is used to generate hydroelectric power.   In the Trinity basin,
 however, the entire amount goes to cooling.

           Freshwater instream flow needs must be considered in
 addition to these demands.  This in-stream needs are just now
 being addressed explicitly by federal and state agencies.  The
 minimal flow patterns needed to sustain aquatic life have been
 quantified for only a few streams, none of them in Texas.  Nearly
 every major stream in the lignite belt has a substantial estuary
 and associated marshlands that support an economically significant
 fishing industry.  A critical requirement for these streams is to
 maintain natural seasonal patterns of variation in the quality
 and quantity of inflow.  This pattern is critical to the main-
 tenance of existing estuarine conditions.  These flow variations
 are responsible for the influx of nutrients and movement of sed-
 iments.  Their seasonality is a key parameter of estuarine eco-
 system structure.  Regulatory agencies are now required to evaluate
 water withdrawals and reservoir regulation with respect to
 ecological effects on the estuaries.  The data base for this
 evaluation, however, is only in the formative stages.  The Texas
 Water Development Board (now part of the Texas Department of Water
 Resources) has been charged by the Texas Legislature to prepare a
 detailed report on estuarine freshwater inflow requirements by
 1979.   These studies, which include hydrological and ecological
 simulation modeling, are now in progress.  The U.S. Fish and
 Wildlife Service is also funding similar studies on a more local
 scale, to predict the impact of specific water development projects

           In comparison to streams of the eastern United States
 and to even the main streams of the western united States, the
 numerous rivers that drain the Texas coastal plain are relatively
                                61

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small.  This means that an incremental increase in demand, such
as could result from lignite development, can have a large impact
on flow patterns.  It also means that rising overall demand
potentially affects all the users in the basin.

          The surface water resource is almost completely allocated,
particularly on those streams southwest of the East Texas region.
Continued growth in surface-water use therefore requires additional
conservation measures and wider application of water re-use.
Water re-use has already begun to expand in industry, under eco-
nomic pressure.  Especially for individual large users, recycling
and re-use can produce significant economic benefits.  Consequently,
those basins where manufacturing is a dominant water use may be
in a better position to adjust to lignite-related increases in
water demand than other basins.  Use patterns in the agricultural
sector, especially in irrigation, are harder to shift than in-
dustrial ones, in part because of the large capital expenditures
required for equipment.  Individual farmers and ranchers may have
more difficulty financing newer, water-saving technologies than
industrial operations.  Municipal demand is very difficult to
curtail, largely because there are few opportunities to conserve
enough water to have basinwide significance.  Also, many indivi-
dual household decisions are needed to produce a measurable de-
mand reduction.  Figure 3.2-2 therefore suggests that the greatest
potential flexibility in water use patterns probably exists in
the northern part of the lignite belt.  Fortunately this coincides
with the greatest expected development of the resource.

          Ground Water

          Most of the ground water in the lignite belt is found
in sandy strata which act as aquifers.  The most important of
these aquifers are the relatively continuous Carrizo and Simsboro
sands, which lie stratigraphically immediately above and below
                               62

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the Calvert Bluff Formation, in which the lignite is found.  The
Carrizo aquifer is a major regional freshwater source for munici-
pal, industrial, and agricultural use, especially on and near
its outcrop.  Other dominantly sand formations occur in a coast-
ward direction and are also widely used as minor aquifers.  These
sands are generally isolated stratigraphically.  and no significant
lignite occurs within their recharge areas.  However, these minor
aquifers (especially the Queen City and Sparta sands) are locally
important sources of water near the Yegua lignite trend.

          In addition to the Gulf Coast aquifers, the alluvial
materials along the major rivers, especially the Brazos River
and to a lesser extent the Trinity River, are also aquifers that
are locally used for water supplies.  These aquifers are relatively
small, hydraulically unconfined to semi-confined sand and gravel
deposits, but can be highly productive.  Their recharge and dis-
charge is controlled primarily by the stream water level.

          The principal aquifers potentially affected by lignite
mining are the Carrizo and Simsboro.  Figure 3.2-3 shows their
relationship to the lignite-bearing Calvert Bluff Formation. The
aquifers actually consist of a complex, hydrologically inter-
connected system of sand bodies which function as a single water-
bearing unit.  The manner of water movement into and through these
aquifers is essentially the same in both.  The Calvert Bluff
Formation which lies between them is a mixed mud and sand forma-
tion.  Although generally less permeable than the two aquiferous
sand strata, the Calvert Bluff can transmit water under pressure.
Thus the two aquifers connected through the Calvert Bluff.

          The Simsboro and Carrizo aquifers are recharged primarily
by rainfall and streamflow infiltrating the sandy strata where
they crop out at the surface.   In these areas,  water is found at
quite shallow depths,  as shown by the location of the water table
                              63

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  SIMSBORO
RECHARGE AREA
                             GROUND
                             SURFACE
   CARRIZO
RECHARGE AREA
                                                                         BASE FLOW
 WATER
 TABLE
          FIGURE 3.2-3

   REGIONAL GROUND WATER  FLOW
 RELATIONS IN THE WILCOX-CARRIZO
         AQUIFER SYSTEM
         (HYPOTHETICAL)
                                        TRANSITIONAL FRESH  WATER -
                                          SALINE WATER INTERFACE

-------
RADIAN
  in Figure 3.2-3.  In a similar manner, a much smaller amount of
  water infiltrates the Calvert Bluff Formation.

           Under the influence of gravity and subsequently under
  hydrostatic pressure, water moves very slowly downward, as shown
  in the  figure.  Because  the water is  confined in the sandy strata
  by the  lower permeabilities of the adjacent strata, it develops
  substantial hydraulic pressure, or head.  At sufficient depths,
  this pressure becomes strong enough to force water outward into
  the adjacent strata above.  For water in the Simsboro aquifer,
  this is the Calvert Bluff.  This outward movement is not uniform.
  It is restricted when locally adjacent to a very impermeable stra-
  tum (aquiclude).  Elsewhere, faults may facilitate this movement
  by transposing strata of greater permeability or by providing an
  actual  avenue for upward movement.  Utimately, a small part of
  the recharge to the combined aquifer  system is discharged into the
  Gulf of Mexico, perhaps  hundreds of thousands of years later.

           Ground water in the Carrizo and Simsboro sands is widely,
  though not intensively, used.  Permeabilities and hydraulic con-
  ductivities vary considerably from place to place, affecting the
  productivity of wells.   Typical sustained yields are on the order
  of 500 gpm.

           The consumptive use of ground water from all of the
  aquifers in the lignite  trend is shown in Figure 3.2-4, according
  to the various surface drainage sectors.  Generally where surface
  supplies and usage are relatively large (Figure 3.2-2), ground-
 water use is small, and  vice versa.    Irrigation use is concentrated
  in the southwestern part  of the trend, and virtually no ground
 water is now used for steam-electric power generation.  With
  institutional and economic constraints on surface-water use in-
 creasing and with the availability of an underdeveloped ground-
 water resource,  the relative proportion of the total water demand
 that is met^ by ground water is likely to continue to increase in
 this region.

                                65

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                                                                          SCALE IN MILES




                                                                       0  20    50
100.000  ACRE FEET



200.000  ACRE FEET



500.000  ACRE FEET
  LIVESTOCK




  MUNICIPAL



i  IRRIGATION
                                                                OTHER




                                                                MINING
                                                                         100
                                                         I***H  STEAM-ELECTRIC
                                        MANUFACTURING
                           FIGURE  3.2-4
J974  GROUND WATER USE FOR DRAINAGE BASINS AND SUB-BASINS

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RADIAN
V^^ ^—^H^hJiMflKJ^PMJ
  3.2.3     Water  Quality and Trends

           Surface Water

           The water quality of most  streams  is  generally good
  during most  of the  year.   There are  no  overriding geographic
  trends in natural water quality,  except that streams  in the
  southwestern part of the lignite belt  tend to be higher in total
  dissolved solids (TDS)  than in the northeastern part.  On all
  streams,  streamflow is  the principal determinant of dissolved
  solids content.  Typically, there is moderately strong inverse
  relationship between flow and TDS.   An  average  TDS value may
  be  500 mg/fc.

           Suspended solids generally vary directly with  stream
  flow, and waters of the streams generally are turbid  except just
  downstream of impoundments.  Sediment yield from  these watersheds
  averages  about 1800 tons/square mile/year.  Most  of these streams
  usually  carry a  moderate load of organic material,  largely of
  natural  or non-point source origin.   Although toxic organics are
  very  low, persistent pesticides,  presumably from  agricultural  land
  runoff,  are  accumulating to a small  degree in bottom  sediments.

           Most streams  that cross the  coastal plain are deemed
  suitable  for all uses,  including public drinking water supplies.
  Pollution of surface streams by drainage from mined lands in the
  lignite belt has not been documented to date, and no  (free) acidic
  mine  drainage to surface streams  is  known to exist.

           These  streams  exhibit a number of  water quality problems
  however,  both in the immediate vicinity of the  lignite and farther
  downstream.   These  problems derive from both natural  and man-
  made  sources.  Drainage from natural salt deposits in the upper
  Brazos River basin  (far above the lignite belt) are a source of
                                 67

-------
 KPORATUMi
brine influent to that stream.  This is the cause of its high
dissolved solids load, especially during low flow conditions.
Several tens of thousands of milligrams of dissolved solids per
liter have been measured occasionally in the Brazos River and
its tributaries.  A similar problem occurs on some small tri-
butaries of older streams, but does not substantially affect
water quality in the lignite belt.  Natural drainage from small
basins containing lignite and its associated strata is also of
imparted quality locally, but is rapidly diluted by waters of
better quality in larger tributaries.

          The water quality of all streams draining the region
is affected by human activity to some extent.  Mere consumptive
use of the water has increased the in-stream salinity owing to
loss of dilution.   Return flows, particularly from irrigated
agriculture, add salts directly.  Below the lignite belt this
has materially added to the dissolved solids loads.  More im-
portant than this, however, is the widespread salt pollution
from oil-field brines.  Abandoned pits and poorly plugged or
cased deep wells under artesian pressure have been of great
local and even regional concern, although remedial and preven-
tive measures have essentially reduced the current problem to
local areas.  Area-wide non-point source control is just now
in the planning stages, under Section 208 of the Federal Water
Pollution Control Act of 1972.  These efforts will most likely
focus on urban and agricultural land drainage as chief non-point
sources.

          Regulatory authorities are now placing most emphasis
on point sources that may adversely affect water quality.
Industrial and municipal (point source) discharges, abetted by
hot weather and nearly stagnant flows, have created locally
severe reductions in the dissolved oxygen content of some coastal
streams.  This has been particularly evident in the San Antonio
River (a tributary to the Guadalupe River) and the Trinity River.
                               68

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RADIAN
 Some improvement in water quality has  been effected  in  recent
 years by upgrading waste treatment facilities.   However,  the
 problems are likely to be difficult to solve  completely,  since
 the low flows of these natural streams are generally effluent-
 dominated.

           Ground Water

           The natural quality of ground water in the lignite
 belt ranges from fresh to briny, depending on a number  of factors.
 Generally water near the outcrop of aquifers  is fresh,  but becomes
 more saline as it move gulfward.  Consequently, at a given loca-
 tion water generally is progressively  more saline with  depth
 even within the same aquifer, although zones  of especially high
 permeability may contain fresh water at considerable depths.  In
 general,  fresh water (containing less  than 100 mg/£  dissolved
 solids)  may be found in the Wilcox-Carrizo aquifer at depths as
 great as 5,000 feet.  In the other Gulf Coast aquifers, ground
 water remains fresh to no more than about 2,000 feet (less in
 the southern part of the region) (TE-231).

           Normal interformational leakage tends to degrade water
 quality.   Salt domes may have a profound yet  erratic adverse
 effect on the quality of nearby ground water.   The area near
 a salt dome is usually fragmented into smaller reservoirs by
 faulting, each of which is variably affected  by dissolution of
 salt.   Upward discharge of brine from  deeper  strata  can occur via
 these faults.   Away from salt domes, the "background" water quality
 in the deeper aquifers ranges typically between 50,000  and 100,000
 mg/JJ, of dissolved solids,  primarily sodium chloride,  with locally
 substantial amounts of dissolved hydrogen sulfide and methane
 (CO-373).

           At shallow depths,  water of  the Wilcox-Carrizo aquifer
 system (comprising the Simsboro,  Calvert Bluff, and  Carrizo
                                69

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Formations)  is generally of considerably higher quality than
other minor  aquifers in the lignite belt.  However, even within
the Wilcox-Carrizo, extreme spatial variability in water quality
exists, dependent upon stratigraphic location and the specific
sediment types present.  Generally, water in the Wilcox-Carrizo
outcrop area is suitable for all uses.  Water downdip (i.e.,
coastward) of the outcrop of the Wilcox-Carrizo aquifer, and
ground water in the other minor aquifers progressively deteriorates
in quality away from the outcrop.  Dissolved solids, iron, sulfate,
and chloride rapidly become only marginally acceptable in this
direction, with respect to the secondary limitations of the National
Interim Drinking Water Standards, and then with less stringent
standards as well.

          Man-induced changes in the quality of these aquifers
are essentially negligible.  Infiltration through lands under
intensive agriculture and changes in quality as a result of al-
tered flows  caused by intensive ground-water development are the
most important potential existing sources of ground-water pollu-
tants.  However, no documented cases of such pollution in the
Wilcox are known to exist.  These effects, if any, are now pro-
bably indistinguishable from natural variations, due to the lack
of such intensive development.
                               70

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RADIAN
3.2.4     Soils and Overburden

          Soil associations are defined as groups of distinct
soil series occurring together in predictable patterns and
characteristic proportions.  Commonly, two or three soil series
comprise the map units in this system.  Each soil series repre-
sents soils essentially uniform in kind, thickness, and sequence
of horizons and very similar in their physical, chemical, and
mineralogical characteristics.

          Most active and proposed surface mining operations are
within three soil-ecological regions of the state; namely:  the
South Texas Plains, the Post Oak Savannah-Blackland Prairie, and
the East Texas Pineywoods.l  Most of the upland soils in the
South Texas area are dark, clayey soils.  Bottomlands are brown
to gray, silt loams to clay, and may contain some free lime.

          Upland soils of the lignite belt in the Post Oak  area
are sandy loams, commonly thin, over gray, mottled or red,  firm
clayey subsoils.  Deep sandy soils with less clayey subsoils
also exist in some areas.  Bottomlands in this region are red-
dish brown to dark gray, loamy or clayey alluvial soils.  In
general, soils in floodplain areas are deep, clayey, slowly
permeable and calcareous.  They are generally much more produc-
tive than the upland soils.

             Most of the upland soils in the East Texas timber-
lands are light colored, acid sandy loams and sands, with some
red soils.  Bottomlands in this region may be light brown to
dark gray, acid, sandy loams, clay loams, and clays.  In general,
they have loamy or sandy surface layers and reddish mottled
loamy or clayey subsoils.
'See Figure 3.3-1
                               71

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RADIAN
CORPORATION
           In  their natural state, most of the soils are good
 grassland  and woodland soils with moderate to low natural
 fertility  in  the A and upper B horizons.   Depending upon the
 soil-formation process, some subsurface horizons may be more
 fertile  than  surface horizons.

           The texture of overburden varies from sandy, sandy
 loams, silty  loams, silty clay loams to silty clays.  In general,
 lignite  seams are separated by clay or sand and clay layers.

           The overburden material, except that in Rio Grande
 and Brazos River areas, presents no potential salinity or
 alkalinity hazard.

           The erosion potential of the mine spoil material
 ranges from low to extremely high levels.  Although, during initial
 years, young  mine soils strongly reflect the nature and charac-
 teristics  of  their parent material, they will not behave as normal
 agricultural  soils.  (They may be variable in water holding
 capacity,  devoid of plant nutrients, contaminated with some salts
 and heavy metals, and subject to wind and water erosion.  Under
 certain  situations, high sulfide content and resulting low pH
 have been  responsible for the lack of adequate plant growth.)

           In  spite of some of these undesirable agronomic
 characteristics, adequate handling will probably improve many
 of them.   The segregation of overburden material offers the
 opportunity to bury the toxic, acid-, or salt-producing strata
 It is expected that replacing finer clay layers at the surface
may improve the water-holding capacity of the upper horizons in
 some areas.   In addition, breaking up and mixing the overburden
will improve not only the nutrient retention capacity, but other
 physical and  chemical properties as well.  The absence of rock
 in the overburden layers will facilitate this improvement.  How-
 ever,  readily available nitrogen, phosphorus, and convertible
                                72

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organic matter are expected to be low in most of these materials
They will need to be supplied by fertilization and surface manage-
ment.

3.3       Biotic Components

3.3.1     Introduction

          Lignite deposits underlie large portions of three
major vegetation areas  (GO-190) of Texas (Figure 3.3-1).  These
are the Pineywoods (15 million acres), the Post Oak Savannah
(8.5 million acres), and the South Texas Plains (20 million acres),
Only a portion of the 43.5 million acres comprising these three
vegetation areas contains mineable lignite.  Less than one percent
of this area is likely  to be disturbed (see Section 4.6.1).  Two
other vegetation areas  are either surrounded by lignite deposit
areas or are located such that they will probably be affected by
lignite-induced developments.  These  are the Blackland Prairies
(11.5 million acres) and the Edwards  Plateau (24 million acres).
Only about one percent  or less of these vegetation areas (pri-
marily the eastern edges of each and  a pocket of Blackland
Prairie surrounded by Post Oak Savannah) may be affected.

          The major biotic provinces  (BL-118) encountered with
respect to fauna in the same lignjite  area are the Austroriparian,
Texas, Tamaulipan, and Balconia.   Various ecosystem or habitat
types can be delineated by the distribution of animals characteris-
tic of these biotic provinces into the main vegetation types.
Each of these major plant-animal associations of the lignite
region is discussed in general terms  in the following sections.
Emphasis has been placed on the current condition and future
trends of the natural environment in  the region.
                               73

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                                                            Texarkona
                                                              Beaumont
                                  •DALLAS'.--'
                                  '•'•".•"•>'•";."'."•]
                                                    Yegua - Jackson

                                                    Pineywoods

                                                    Post Oak Savannah

                                                    Blackland  Prarie

                                                    South Texas Plains

                                                    Edwards Plateau
                     FIGURE  3.3-1
RELATIONSHIP OF STRIPPABLE  LIGNITE IN  THE WILCOX
      AND YEGUA-JACKSON UNITS (AFTER KA-152)
       AND  MAJOR VEGETATION  REGIONS OF  TEXAS
                             74 .

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RADIAN
  3.3.2     Terrestrial Habitat/Vegetation Associations

           Pineywoods

           The Texas Pineywoods  area marks the southwestern limits
  of the Oak-Hickory-Pine  Forests (US-155) in the United States.
  This area has been  logged  for over 150 years and is still being
  used for both lumber and pulpwood for paper products.  Virtually
  no virgin stands  of timber remain in the upland pine forest area.
  Some of the riparian hardwood forests, although probably second
  growth, are approaching  climax.   The large amount of annual
  precipitation (44+  inches)  aids greatly in rapidly restoring
  vegetation following disturbances.  Some of this area has been
  cleared for agricultural purposes and livestock grazing.  A large
  portion of the  remaining forests are privately owned and managed
  primarily for wood production.   Clear-cutting is commonly practiced
  in pure pine stands and  uncommonly in mixed hardwood areas.  The
  state's only national forests are located in this region.

           Due to  the continued  large-scale disturbances of
  habitats from logging, farming  and ranching operations as well
  as direct disturbance from heavy hunting pressure, the animal
  populations are much lower than they were prior to the coming
  of the white man.  The species  diversity is higher because of
  more varied habitats, however.   This has drastically altered the
  original species  composition.

              The  increasing need for wood products and agricultural
  products, along  with an increase in recreational and retirement home
  subdivisions, point to increasing disturbances in the Pineywoods
  region.  The riparian hardwood  forests may be the last affected
  because of the  higher degree of difficulty associated with develop-
  ment in the river floodplains.
                                 75

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           Post  Oak  Savannah

           The Post  Oak Savannah region directly overlies the
majority  of  the surface mineable lignite in Texas.  This Post
Oak-Blackjack Oak Savannah has been extensively cultivated and
grazed  since the first settlers arrived in Texas.  This vegeta-
tion  area is in the transition zone between the eastern United
States  forests  and  the central United States grasslands.  Originally
much  of the  area was prairie interspersed with hardwood forests
in the  drainage areas.  Species of plants and animals from the
western grasslands  and eastern forests inhabit this transition
zone wherever they  can find a niche that suits their requirements.
Disturbance  by  man  (hunting, agriculture, overgrazing, and pro-
tection from fire)  has increased the diversity of habitats, in-
creased the  extent  of the oak woodlands and the mesquite savannah,
and decreased the number of individual animals in this area.  Many
of the  present  oak  forests are situated on cotton fields abandoned
75 to 100 years  ago.

          The Post  Oak Savannah region will continue to be
severely disturbed  overall since the need for beef and agricultural
products is  increasing rapidly.  Most of this area is in the 30
to 40 inch per  year rainfall belt which means that evaporation
more or less equals precipitation in much of the area, thereby
making  revegetation after disturbance occur more slowly.

          Blackland Prairies

          Originally this vegetation region was characterized by
1-2 meter high  grasses that stretched as far as the eye could see.
Presently only  isolated, protected spots contain true prairie
within  the entire region.  Agriculture and cattle grazing have
taken over the  vast majority of the Blackland Prairie area.
Hardwood forests occur in the riparian areas where crops are not
grown.  Overgrazing has favored the growth of unpalatable grass
                               76

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RAMAN
 species and mesquite in the pasturelands of the Blackland Prairie.
 Although no strippable lignite lies under the Blackland Prairies
 of Texas, the lignite belt surrounds a portion of this vegetation/
 habitat type and joins it on most of its eastern border.

           South Texas Plains

           The South Texas Plains region was originally a rocky
 to rolling prairie to savannah area with grasslands interspersed
 with brushy woodlands in the water courses.  Hundreds of years
 of overgrazing, fire control and other poor management practices
 have left most of the 20 million acres in dense "brush" of one
 type or another.  This provides good habitat for many species of
 dry country animals, especially since the density of the brush
 in many vast areas keeps disturbance by man to a bare minimum.
 This areas contains some of the largest trophy white tail deer in
 the United States—a valuable resource for property owners.
 Recent brush control efforts coupled with the re-establishment
 of native grasses and reasonable grazing practices have brought
 many of the less rugged areas back to more nearly natural condi-
 tions.  Since this region receives less than 30 inches of rainfall
 annually, evaporation exceeds precipitation.  This makes revegeta-
 tion after disturbances a slow process without the addition of
 water.

           Since the region is quite fertile when water is avail-
 able and the brush removed, the trend is probably toward more
 clearing for pastures.  This will proceed slowly and only as long
 as beef is in demand and water is available.

           Edwards Plateau

           In its original condition, the southern and eastern edges
 of the Edwards Plateau region, near the Balcones Fault, suported
 a prairie grassland on its upper more level hilltops.
                                77

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 Juniper-Oak  thickets grew on the hillsides, and Oak-Walnut-Cedar
 Elm forests  along  the riparian areas.  Overgrazing, depletion of
 underground  aquifers that supplied the abundant springs, fire
 control  and  cutting of the various trees has greatly reduced the
 quality  of the habitats available.  Many areas are either sparsel,
 vegetated rocky soil or dense stands of Juniper-Oak brush.  These
 support  one  of the densest deer populations in the United States
 along with a good  population of turkeys.  The change in habitats
 has, however, caused declines in other populations such as the
 rare Golden-Cheeked Warbler.

          The primary trend presently obvious is the urbanization
 of  this  scenic area by vacation, second home, and retirement
 communities.  Although this does not place as much large-scale
 pressure on  the habitats as clearing for agriculture might, it
 does greatly affect the wildlife directly through human distur-
 bance and indirectly via changes in water quality, etc.  The latter
 has the potential  for affecting the several rare species of
 salamanders  that inhabit the springs of the Edwards Plateau
 region.

 3.3.3     Aquatic  Ecology

          The surface mineable and deep deposits of lignite in
 Texas cross  almost every major river within the state.  Texas
 rivers and estuaries contain thousands of species of aquatic
 plants and animals, each with its own set of tolerances and pre-
 ferences for various water parameters.  The species composition,
 species diversity, and population sizes vary between rivers and
within each river  depending upon a wide variety of environmental
parameters.   Since Texas has no natural lakes, all of the native
 fresh water organisms are riverine in nature, even though they
may reside in man-made impoundments.  Some species have been
artifically introduced into the Texas river systems from various
 sources outside the state.
                               78

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HAINAN
           In general, the majority of the aquatic organisms found
 within the lignite region in Texas have rather broad tolerances
 of environmental parameters.  Notable exceptions are species
 which inhabit springs or spring fed rivers near or in the Balcones
 Fault Zone along the southern and eastern edge of the Edwards
 Plateau.  These are not in  areas that will be directly affected
 by lignite development.  Data are available for many species con-
 cerning their tolerances to various changes in water quality and
 quantity parameters.  Since the effects of lignite development
 on aquatic ecosystems will  be specific with regard to river
 systems, the aquatic biota  of each specific area of lignite
 development must be studied separately.

           In general, the extensive development of the land
 around the major rivers has altered water quality, quantity,
 and aquatic biota drastically.  From the time of the early set-
 tlers in the 1800's through the early 1900's, the aquatic envi-
 ronments were grossly abused.  They were used as dumping grounds
 for every imaginable waste  material.  In addition they received
 large loads of soil from poorly managed agricultural fields and
 over-grazed pastures.  By the first part of the 20th century most
 of the fish had been removed from the rivers by over-fishing
 (commercial) or the degradation of their habitats.  Efforts by
 the old Texas Game and Fish Commission (now the Texas Parks
 and Wildlife Department) have restored many of the depleted
 populations to reasonable levels.  Still, pollution levels in
 the rivers and consumptive usage of the water resources strain
 most of the states aquatic resources.

           The trend is toward increased water usage thereby
 increasing pressure on the aquatic ecosystems of Texas.
                                79

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 3.4        Sensitive or Unique Areas

           Several areas have been described as "sensitive" or
 in the previous sections.  This section summarizes these discussions
 and presents these areas in a combined form.

           Sensitive or unique areas are areas which for certain
 reasons are thought to be sensitive to the effects of lignite
 development or unique in properties that should be considered in
 the discussions of lignite development.  The sensitivity or
 uniqueness may be natural (wildlife habitats) or man-made (air
 quality maintenance areas).

           State parks, national forests and grasslands, and wild-
 life refuges are considered sensitive to lignite development
 (see Figure 3.4-1).  The flora and fauna of these areas are sensi-
 tive to disturbances of various types that would be aggravated by
many areas of lignite related development.  The Big Thicket area
 in East Texas is especially notable for its close resemblance
 to the natural climax forest as it existed before settlement.

          The "Lost Pines" area near and including Bastrop State
Park is a unique natural area because of the existence of the
disjunct pine forest.  This pine forest area is physically separated
 from the major East Texas Pineywoods by about 100 miles.  This
 area contains other plants and animals usually found only in
the Pineywoods region and is therefore unique in the lignite
belt.

          Areas of mature river bottom hardwoods along rivers or
 streams of Central and East Texas can be considered unique for
their wildlife and scenic value.  A segment of the Guadalupe
River above Canyon Dam has been proposed for inclusion in the
Wild and Scenic Rivers system.  Since there are virtually no
                               80

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oo
                                            GUflOflLUPE
                                              RIVER
                                                        BAtSTROP
                                                      STAT
                                                        PARK
                                              f—©
                                        PALMKTTO
                                            TA
                                            PARK
                                  ARANSAS
                                  NATIONAL
                                  WILDLIFE
HABITAT FOR
 RED WOLF
                             (WHOORP!NGQCRANES)  SAN BERNARD NATIONAL
                                                                DAVY  CROCKETT
                                                               NATIONAL FOREST

                                                                SAM  HOUSTON
                                                               NATIONAL FOREST
                                                                                                          SABINE
                                                                                                       NATIONAL  FOREST
ANGELINA NATIONAL FOREST

    SCALE IN MILES

0   20    50       100
                                                     WILDLIFE REFUGE
                     LAGUNA ATASCOSA
                    NATIONAL WILDLIFE REFUGE
                            ANAHUAC
                            NATIONAL
                         WILDLIFE  REFUGE
                                                                                       BIG THICKET"
                      	    POTENTIAL  LIGNITE  DEPOSITS
                       PRINCIPAL LIGNITE DEPOSITS
                                                         /
                                                                                FIGURE 3.A-1
                                                                       ECOLOGICALLY SENSITIVE AREAS

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virgin  forest areas left in or near the lignite region due to
previous logging operations, these areas of mature, near climax
vegetation can be considered unique.  Their replacement takes
over 100 years under the best conditions; therefore, any dis-
turbance should be considered long-term.

          Air Quality Maintenance Areas (AQMA's) (Figure 3.4-2)
are legally sensitive to further air quality degradation.  Lignite
mining and the related development of power generation facil-
ities can possibly have an adverse effect on the levels of
several criteria pollutants such as S02 and Total Suspended
Particulates (TSP) if not carefully planned.
                               82

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QO
CO
                                                                                              DALLAS/FORT
                                                                                              WORTH AQMA
                              CORPUS
                              CHRISTI
                               AQMA
                                                         GALVESTON
                                                           AQMA
   \
0  20    SO
100
BEAUMONT
  AQMA
                                                  FIGURE 3.4-2
                                    CURRENT  AIR QUALITY MAINTENANCE  AREAS

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         CHAPTER FOUR



POTENTIAL ENVIRONMENTAL IMPACTS
               84

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HAINAN
'^^^^H^^ft^KMM ^K^BBd
 4.0       POTENTIAL ENVIRONMENTAL IMPACTS

 4.1       Socioeconomic Consequences of Lignite Development

           The following discussion will describe the major types
 of activity which can be related to future lignite development
 in Texas.  This is a cursory analysis to be used for illustra-
 tive purposes rather than as a planning tool.  Also, it will be
 used as input to other impact sections  (e.g.,  water supply and
 air quality) so that the total potential impact of  lignite develop-
 ment can be projected.

           A number of simplifying assumptions have been made.
 The most important of these assumptions is that virtually all
 the lignite to be used in Texas between now and 2000 will be
 for electricity generation.  The future demand for  lignite
 for industrial process use, in-plant power generation, and
 gasification is too uncertain to forecast quantitatively without
 substantially greater efforts than  were possible under the present
 study.  However, industrial lignite use will probably fall in
 the same order of magnitude as use  for power generation.  This
 assumption consequently results in  low estimates of impact.  In
 this analysis, the direct economic  impacts of  lignite develop-
 ment have been isolated in two major economic  sectors:  lignite
 mining and electricity generation.

           Excluded from this analysis is the manufacturing of
 machinery and the provision of materials for mining activities
 and electricity generation plants.  This assumption is valid
 since much of the equipment (draglines, trucks, steel, etc.)
 will come from outside Texas, making the impact difficult to
 isolate geographically.
                                85

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          Finally, the economic stimulation related to construction
activities will be excluded from this projection.  As with
materials and machinery, the consequences are difficult to allo-
cate geographically because of "leakage" (spending outside a
region).  Also, the construction activities are of relatively
short duration compared to the ongoing lignite mining and elec-
tricity generation.

          In the sections which follow, the direct employment
associated with various levels of lignite development will be
estimated.  Then, the indirect economic impacts associated with
that development will be developed.

4.1.1     Direct Employment

          To project future employment in lignite mining, it is
first important to know how much lignite is going to be produced.
Section 2.4 presented two projected rates of lignite development
that roughly bound future use of lignite, depending on its attrac-
tiveness relative to other energy  sources.  The estimate of lignite
development for power generation in 2000 ranges from a low of
128 MST (million short tons)  per year to 257 MST per year.

          To determine the number of workers who will be employed
in the production of the lignite, it is assumed that current
mining practices will be employed.   A proposed Central Texas
lignite mine which will produce 5 MST per year will employ 385
people,  or 77 people per MST.  A larger mine might employ fewer
people per MST while a smaller mine might employ more per MST.
However, for this cursory projection, 77 per MST is a reasonable
estimate.
                               86

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RADIAN
           If lignite production grows to 128 MST in 2000,  an
 increase of 120 MST over 1974 levels, approximately 10,000 new
 mining jobs will be created.  Producing 257 MST per year in
 2000 will create approximately 20,000 jobs.  These are rough
 estimates, yet they show the relatively large number of jobs
 which can be created directly in lignite mining.  The total
 employment in 1974 in all energy extraction (coal and lignite,
 crude petroleum and natural gas) for the entire area, was only
 110,000 (TE-257).   Thus lignite development can add significantly
 to employment in this sector.

           The other sector which will be directly affected by
 lignite production will be electrical generation.  The higher
 production figure corresponds to roughly 43,000 MWe in 2000, the
 lower to 21,000 MWe.  As shown in Table 2.4-4, this is equivalent
 to 30 new 1,500 MWe stations at the upper bound, and 16 at the
 lower.  Four plants are now in operation.

           Utilizing contemporary staffing  estimates, a 1500
 MWe plant requires an operating staff of 500.  Therefore, 26 new
 plants (four stations are now in operation) will increase employ-
 ment in electrical generating by roughly 13,000, and 12 plants
 will increase it by 6,000.

           Table 4.1-1 shows a summary of the direct effects of the
 three development scenarios on power production and on employment
 in the year 2000 in mining and power generation.
                               87

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TABLE
4.1-1

SUMMARY OF EMPLOYMENT IMPACTS
Lignite
Development
257 MST
128 MST
a1500 MWe per
Mining
Employment
20,000
10,000
plant.
New Power
Plants1
26
12
New Power
Generation
Employees
13,000
6,000
4.1.2
Indirect Employment
          The economic effects of new activities such as mining
and power generation do not stop with that new employment.   There
is a secondary effect on the economy.  The Texas Input-Output
Model (GR-355) shows how the various sectors of the Texas economy
influence each other.  A product of the model is a set of multi-
pliers which quantitatively relate the change in economic
activity which will result in all other sectors to growth (or
decline) in a particular sector.  Table 4.1-2 shows the forecast
upper and lower bounds of lignite-fired power generation and the
total employment growth which will result by the year 2000.
Considering only the direct and secondary effects of lignite
mining and power generation, there will be from 47,000 to 97.000
new jobs in the lignite region.  This is actually an underesti-
mate of the total effect because there may be changes in the
economic structure of the region as a result of power availability.
Also not considered have been the economic effects of plant
construction.  It should again be noted that these projections
incorporate restrictive assumptions and cannot be used as planning
figures.
                               88

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                                                        TABLE 4.1.2
                                                     EMPLOYMENT FORECASTS
      LIGNITE      EMPLOYMENT                           TOTAL DIRECT   EMPLOYMENT
      DEVELOPMENT  IN LIGNITE               SECONDARY   AND SECONDARY  IN POWER
      SCENARIO     MINING      MULTIPLIER   EMPLOYMENT  FROM MINING    GENERATION  MULTIPLIER
                                                                TOTAL
                                                                DIRECT AND
                                                                SECONDARY
                                                    SECONDARY   FROM
                                                    EMPLOYMENT  GENERATION
00
\O
      257  MST     20,000
      128  MST     10,000
                               1.800
36,000      56,000         13,000
18,000      28,000          6,000
                                                    GRAND TOTAL DIRECT
                                                 AND SECONDARY EMPLOYMENT
                                                                                   2.130
28,000
13,000
41,000
19,000
                                                  257 MST
                                                  128 MST
                    97,000
                    47,000
             II  (indirect and induced effects) multiplier (GR-355).

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4.1.3     Labor for Development and Population Change

          The labor required for lignite mining and electricity
generation is not currently available within the region.  There
is a fair amount of unemployed labor, in absolute numbers, near
the lignite belt; however, many of these lack the skills needed
for jobs in mining or power generation.  A recent study in Milam
County by Radian concluded that most of the new lobs will be
filled by immigrants or commuters.  However, secondary economic
growth may be expected to generate more jobs for unskilled
or semi-skilled labor.

          No attempt will be made to project exactly the total
population change which may occur along the lignite belt.  However,
if 3.0 people per household is a reasonable estimate of family
size, there might be as many as 141,000 new people along the lignite
belt in the 128-MST scenario and 291,000 new people in the 257-
MST scenario.  These projections are artifically high because
they assume 100 percent in-migration.  But even if these pro-
jections are reduced by 50 percent to allow for commuting and
local labor availability, the region will still experience con-
siderable growth.  Since out-migration has been high during the
past three decades, this change is potentially very significant.

          The major conclusion of this analysis is that the
lignite belt may experience a substantial population growth,
for which it may not be prepared.  Furthermore, these projections
are conservative in that they ignore the growth of other indus-
tries, such as forest products, paper, and petrochemicals that
may utilize the lignite.  These industries will stimulate further
economic activity and population growth.  Since the Texas Input-
Output multipliers are based upon existing patterns of energy
use, they tend to underestimate this possibility.
                                90

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RAMAN
 4.1.4     Demands on  Infrastructure

           In  Chapter  Three,  a number of features of the Texas
 lignite belt  were discussed  under the heading "Infrastructure and
 Recreational  Resources".   The discussion was brief and the major
 conclusion was  that the non-metropolitan nature of the lignite belt
 may  create problems which  are not present in metropolitan areas.
 It also means that there may be  some problems, commonplace in
 metropolitan  development,  which  will not be bothersome in the
 nonmetropolitan case.  The actual demands on  infrastructure,
 therefore, will be site-specific and cannot be discussed in parti-
 cular  in  this analysis.  What follows is a general discussion of
 some aspects  of the social infrastructure which may be affected
 by lignite development.

 4.1.4.1   Housing

           Lignite  development in Texas will generally be restricted
 to areas  where  excess adequate housing  is not now available.  In
 a recent  survey of a  Central Texas  town about to  experience
 expanded  lignite mining,  Radian  found that housing will be a
 critical  problem in the  early years of  the development.  In some
 of these  areas  with abrupt industrial expansion,  large companies
 have had  to subsidize housing developments.   The problem is par-
 tially related  to  the lack of speculative development in non-
 metropolitan  areas when compared to metropolitan housing markets.
 Builders  and  financial institutions hesitate  to act until there
 is demand which has little or no risk.

           Inevitably,  the  shortage  is dealt with by mobile home
 developments  and long-distance commuting.  Where zoning ordinances
 are  favorable and the demand is  sufficient, mobile home parks
 are  a  short-run solution to  part of the problem.  Those who do
 not  find  housing near a new  activity must commute.  This will
 be especially important in the lignite belt because the housing
                                91

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shortage, coupled with the demographic structure of the area,
will insure that much of the labor will come from outside the
region.

          The positive aspect of the housing situation is that
the solution means more jobs, particularly in the construction
industry.  Suppliers of building materials also benefit sub-
stantially.  Financial institutions, savings and loans associa-
tions, in particular, profit from the shortage in the long run.

4.1.4.2   Education

          Populations in those areas which will be immediately
affected by lignite mining and power generation have relatively
high median ages.  This means that educational services in those
areas currently are being provided to a relatively small number of
pupils, especially when compared to suburban areas with relatively
young populations.  An influx of workers to most nonmetropolitan
areas will upset the demographic structure.  Workers will tend to
be younger than the resident population and the number of children
per household will be larger.  This combination will probably
mean that many educational systems will be overburdened.  Radian
found this to be true in an analysis recently conducted in a
Central Texas town of 5000.  Classroom space and the number of
teachers will have to be expanded to meet minimum standards.
In some areas, new schools may be needed.  This was the case in
a lignite-related development in Northeast Texas.

          Stress on a school system is not necessarily a bad
condition in the long run.  Through increased revenues, an area
may be able to renovate poor facilities or add to existing facili-
ties to increase the quality of education.  New ideas and teach-
ing methods may be brought in by new teachers.
                               92

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          Finally, no one community will receive all the impact
of a particular development.  Past experience suggests that com-
muting may insure that the stress is dispersed to a number of
schools and school districts.

4.1.4.3   Community Services

          Municipal governments near lignite developments will
experience varying degrees of difficulty in providing the ex-
pected services.  The provision of basic utilities such as
additional water and sewage  treatment may be very difficult.
Some communities will be forced to finance expansion through
bonding.  Communities that cannot provide additional services
will not be able to attract  their share of the economic activity.

          One positive aspect of the development which may
occur is reflected in the cost per capita of providing community
services.  The total cost is less in nonmetropolitan areas than
in metropolitan areas.  Table 4.1-3 shows the comparison of public
expenditures in the two types of areas.  Only in the per-capita
cost of highways are the nonmetropolitan areas more expensive than
the metropolitan areas.  From a national perspective, nonmetropolitan
growth may be desirable because of this type of savings.
Service
Police
Fire
Hospital
Schools
Sanitation
Welfare
Roads
TOTAL
*Based upon
TABLE 4.1-3*
PUBLIC EXPENDITURES
Non-Metropolitan Cost
($/capita)
6.56
3.46
13.70
136.44
7.03
11.88
26.77
205.89
TW-008 (1966-67 data).
Metropolitan Cost
($/capita)
16.73
9.77
18.30
150.35
15.83
24.17
21.14
256.29
                               93

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4.1.4.4   Conclusion

          Non-metropolitan areas which attract large-scale develop.
ments will change substantially, especially in aspects discussed
in this section.  However, these changes are going to bring about
other changes, particularly because of a natural dichotomy between
"old timers" and "newcomers".

          Newcomers may have more of the higher-paying jobs, which
will cause some local inflation.  Old timers, especially those
on fixed incomes, will be hurt by this.   Newcomers will have values
which may be different from the old timers, especially since many
of the newcomers will have recently experienced metropolitan ways
of life.  Old timers may perceive a change in political structure
based upon these differing values.  These are merely illustrative
of some of the problems which may arise.

          One moderating influence will be the high incidence
of return migration which should accompany these developments.
Many people who left nonmetropolitan areas in the 1950's and
1960's would like to return to their former homes if economic
opportunity were available.  Lignite development may be the
stimulus for many of these people.  The return of former resi-
dents might make the growth easier to accommodate.

4.2       Cumulative Effects of Water Demands

4.2.1     Demand Related to Lignite Development

          Water consumption related to lignite development may
be direct,  such as that required for mineral extraction and power
generation, or indirect, such as that associated with expanding
residential, commercial, public, and other industrial end-use
sectors as a result of lignite utilization.  Both direct and
indirect demands are related to the scale of lignite development,
which has been described in Section 2.4.

                               94

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RADIAN
 4.2.1.1   Direct Water Demands

           Direct water demands from lignite utilization arise
 from both mining and energy conversion,  which in this  analysis
 is limited to conventional lignite-fired steam electric power
 generation.   Industry conversion to lignite as a fuel  will  not
 have as large an effect on water use as  will the shift to lignite
 in power generation.  Additional water demands may be  a factor
 by 2000, but cannot be predicted.  Pipeline slurry transportation
 is not technologically attractive,  because lignite tends to
 disintegrate, when slurried, into a fine powder that is difficult
 to de-water (HO-389).  Hence, cumulative water demands related
 to lignite development appear to be strongly dominated by electric
 power.

           The principal water-consuming  uses at a mine are  dust
 control and reclamation.  An average of  500 acre-feet  per year
 (0.45 MGD) may be required for dust control for a typical 25,000
 ton-per-day mine that supports a 1,500 MWe station.  Generally.
 ground-water seepage that accumulates in the mine pit  is of ade-
 quate quality for dust control, so this  water use may  make  even
 a smaller demand on off-site water resources than 500  AF/year.
 Up to 4000 AF/year (3.6 MGD) may be required for reclamation,
 depending on natural rainfall in a given year and mine location.
 In East Texas and much of Central Texas, irrigation of reclaimed
 land is unnecessary.  Further south, irrigation will probably
 be required for soil leaching and revegetation.  A base amount
 of 500 AF/year has been allocated for reclamation at the typical
 mine under consideration.   This is  more  representative of
 East Texas climatic conditions.  Substantially more water for
 this purpose will be required if mines are to be located in
 southern Central and South Texas (say, south of the Colorado
 River.)  However, the constraints upon extensive development
 there (water supply, lignite quality,  and lignite quantity)
 militate against a larger estimate  for statewide average reclama-
 tion use than 500 AF/year.
                               95

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          Water use in power generation is either for process or
cooling purposes.  The principal process water needs are for
boiler makeup, ash handling (assuming hydraulic rather than
pneumatic systems), and stack-gas scrubbing for sulfur oxide and
particulate control.  About 200 AF/year for boiler feed makeup
and ash handling, and about 2000 AF/year for scrubbing are required
for a 1,500 MWe station at full load.  An additional 500 AF/year
is allocated for miscellaneous in-plant uses.

          Cooling water intake and consumption rates are highly
dependent on the cooling system employed.  Both cooling towers
and cooling ponds consume from 30 to 100 percent more water than
"once-through" cooling systems.  Averaged statewide, about 10,000
AF/year would be consumed by a 1,500 MWe plant for once-through
cooling.  About 20,000 AF/year would be required for cooling
ponds or towers.  Once-through cooling is impractical in most
of the streams in the lignite belt because of irregular flows.
These flows are too variable to supply the volume of cooling
water needed to keep discharge temperatures low enough to meet
state stream quality standards.  From a water-use efficiency
standpoint, the use of once-through cooling on large multi-purpose
reservoirs is optimal (HO-389), but few of these exist along the
lignite belt.   Their use for cooling is also hindered by require-
ments to comply with Federal law (see Section 5.1.2).  Ground
water is more efficiently used in wet cooling towers than as
makeup for a cooling pond or lake.

          No distinction has been made in this analysis between
water use in cooling ponds and cooling towers.   Unless viewed
from an economic and historical perspective, this assumption may
be misleading.  There are, of  course, differences in water require-
ments between these two systems at any one location.  For example,
cooling ponds tend to be more practical in East Texas than South
Texas;  in South Texas,  the very high evaporation rates and low
                               96

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rainfall would increase water use significantly.  Cooling ponds
would tend to use about 20 percent more water than cooling towers.
On the other hand, in East Texas, cooling towers may consume
nearly 20 percent more water than ponds (TE-301).  In Central
Texas, the two systems are about equal in consumptive water use.
A consumption rate of 20,000 AF/year is about the most efficient
level achievable, and economics dictate consuming as little water
as possible.  The 20,000 AF/year rate for a typical 1,500 MWe
station is consequently believed to be a good average figure,
but it must be borne in mind that in East Texas it connotes the
use of cooling ponds and in South Texas, use of cooling towers.
In both of these systems, water intake will be virtually equivalent
to water consumption.

          Aggregated direct demands of lignite utilization in the
year 2000 are presented in Table 4.2-1.  For each mine, 1000 AF
(0.89 MGD) is consumed annually, and its associated power plant
will use about 22,700 AF per year (20.3 MGD).  The water use
figures in Table 4.2-1 are based on an upper bound of 30 mine-mouth
power plants in the year 2000 and a lower bound of 16, as pro-
jected in Chapter Two, with an average load of 60 percent (the.
current load factor for all lignite-fired stations.)  Most of
this demand will occur in or near East Texas where surface-
water supplies are more plentiful than elsewhere, and where ad-
ditional water requirements for mine reclamation are negligibly
small.  On a Btu-output unit basis, water consumption will
slightly increase in a southwesterly direction along the lignite
belt and the proportion of ground water is also likely to in-
crease.  However, on a galIon-consumed basis, the water used
for lignite utilization will progressively decrease in a south-
westerly direction.
                               97

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                           TABLE 4.2-1
            PROJECTED WATER REQUIREMENTS DIRECTLY RELATED TO
                   LIGNITE UTILIZATION IN YEAR 2000
       Mining
       Power Generation
       TOTAL DIRECT
       DEMAND
   Lower Bound
(AF/Yr)   (MGD)
  9,600   8.6
218.000  195

228.000  204
                                             Upper Bound
(AF/Yr)
 18,000
409.000

427.000
(MGD)
  16
 365

 381
4.2.1.2   Indirect  Demands

          Indirect  water usage related to lignite development
derives chiefly  from the increased population  generated by the
utilization of lignite.   As shown in Section 4.1, in the year
2000, between 47,000 and 97,000 new jobs will  be created by
lignite mining and  related power production.   The maximum re-
sulting population  increase could be as much as  141,000 to
291,000 people,1  all of whom will require water, among many
other services.

          Gross  water use by this population increment will range
from 19,000 AF per  year (17.1 MGD) to 39,300 AF  per year (35.4
MGD), based on 120  gallons per capita-day for  domestic, commercial,
and public uses  in  the lignite belt.  Generally, these amounts
of water  are not all consumed, since about  83  percent on average
is returned or introduced to the surface or shallow subsurface
 Assuming  100 percent in-migration.
                                 98

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RADIAN
 water supply system as wastewater, where  it ultimately will be
 reused (not necessarily by humans).   However,  the  gross water
 use figures per se are important, because generally  this water
 is required to be of higher quality  than  water directly related
 to lignite utilization.  Furthermore this water demand, while
 dispersed throughout the lignite belt,  will be locally concen-
 trated in the more urban areas,  especially those of  East Texas.

           Net water usage (i.e., consumption)  by the increased
 population must be used in assessing the  overall effect on the
 hvdrologic balance.  These indirect  effects are quite small;
 even in the year 2000, a maximum of  only  6,680 acre-feet per
 year (6.0 MGD) can be ascribed to consumptive  use  by the in-
 creased population.  This is essentially  negligible  when com-
 pared to amounts directly related to lignite utilization.

           Another indirect water use is that  for new industries
 whose existence is dependent upon lignite extraction and utiliza-
 tion.  This water use has not been determined, but it may  be  a
 significant additional water demand related  to lignite develop-
 ment.  Generally, these demands are  not necessarily co-located
 with direct and other indirect demands.

 4.2.2     Water Availability for Lignite  Development

           By the year 2000, as much  as 260 million tons of
 lignite may be mined annually and burned  as fuel in  the large steam-
 electric stations.  The discussion in the preceding  subsection in-
 dicates that consumptive water requirements may exceed 430,000
 acre-feet per year at such utilization rates.   There seems to be
 no question that such large continuous demands will  strain avail-
 able water supplies at least locally, if  not basin-wide.   Demands
 of large amounts of surface or ground waters  for lignite utiliza-
 tion may not only compete with demands by other users from the same
 river basins or aquifers, but also may combine with  other  uses to
 reduce vital inflows to economically important coastal estuaries
                                99

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 (see Sections 4.6 and 5.1 for further discussion).  A detailed
 assessment of water supplies and availabilty, basin by basin
 or by aquifer, is not within the scope of this study (and may
not now be possible.)  The effects of the increased water demand
 therefore have been addressed only at a regional overview level.
Emphasis of this subsection is on physical availability.  The ef-
fects of institutional constraints on water use are the focus
of Section 5.1.

          Water requirements can be met from both surface- and
ground-water resources,  although the extent to which either re-
source can satisfy the demand is highly site-specific.   Surface-
water availability in the area of the lignite belt depends on
the climate and resultant hydrologic conditions (see Figure 4.2-1).
The availability of water in the lignite belt is discussed accord-
ing to these climatic regions.

          Generally speaking, some supplies of surface water are
available in varying amounts above present usage in Central and
especially East Texas.  In these areas, relatively high average
rainfall in the basins above the lignite and low evapotranspira-
tion promotes high unit runoff.   Nevertheless,  in most  areas
of the lignite belt, surface streams are small and streamflow
is largely dependent upon localized rainfall.  In the immediate
vicinity of the lignite, then,  off-stream impoundments, supplied
by water pumped from larger watercourses, must be used to provide
a dependable water supply.  In most of Central Texas and on some
streams of East Texas. even the present water use exceeds depend-
able supplies, and make-up for the off-stream impoundments will
increasingly make selective use of flood flows, as lignite
development proceeds.  Very little, if any. dependable water is
not committed to existing water rights permits; the ongoing ad-
judication effort by the Texas Water Rights Commission (now in-
                               100

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 CLIMATIC REGIONS
££|£1  EAST TEXAS
                 NECHES-
                 TRINITY
              TRINITY-
              SAN JACINTO
         SAN JACINTO- BRAZOS
      BRAZOS-COLORADO
    COLORADO-LAVACA
  LAVACA-GUADALUPE
 SAN ANTONIO-NUECES
NUECES-RIO GRANDE
      CENTRAL TEXAS
      SOUTH TEXAS
                            FIGURE  4.2-1
     CLIMATIC  REGIONS  IN THE LIGNITE BEARING AREAS  OF TEXAS
                                   101

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 corporated  in  the new Texas Department of Water Resources) should
 reveal to what extent additional supplies for all uses are avail-
 able  for allocation.  However, as a general statement, lignite
 development will strongly exacerbate an existing trend toward
 depletion of the surface-water resource in Central and East
 Texas.

          In South Texas, surface water is not readily available.
 Its availability is generally dictated by economics, because any
 substantial amounts of water must be acquired from existing per-
mit holders on a contractual basis (HO-389).  Even such "contract
water" will contain restrictions as to withdrawal periods and
rates.

          Total water usage projections, according to the Texas
Water Development Board (TWDB) indicate that lignite-related
water use will be a substantial portion of the total surface-
water demand, and will significantly exceed the dependable
supply.  Table 4.2-2 compares total demand to low and average
flow in the affected basins.  Dependable supply is related to
low flow, and lies between the two statistics, but closer to the
low flow of record.  (While lignite-related usage is a component
of the total demand in these TWDB projections, the analyses of
this study  indicate that the lignite-related demand in the more
northern basins will be more severe than that projected by the
TWDB, and the demand on more southern basins less severe.)

          Ground-water availability must be evaluated on a site-
specific basis.  Generally, though, ground water of suitable
quality is more available in a southwesterly direction.  This
water resource is generally undeveloped and the sustained
yield of ground water from the Carrizo Wilcox, Queen City, and
Sparta aquifers is likely to be a more important water source in
the future, especially for domestic and agricultural demands in
                               102

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TABLE 4.2-2
MAJOR RIVER BASIN FLOW STATISTICS AND SURFACE-WATER USE*
(1000 fs Acre-Feet/Year)
Drainage
Basin
Sulphur River
Cypress Creek
Sablne River
Neches River
Trinity River
Brazos River
Colorado River
Guadalupe River
San Antonio River
Nueces River
TOTAL
*Streamf lows are
Streamflow-Period of Record
Low Flow
0
0
195
46
74
29
93
10
1
5
values at furthest
NOTE: Streamflows based on U.S.G.S
Water use
based on (TE-301)
Average Flow
1,101
250
6,102
4,570
5,184
6,055
1,774
1,240
448
629
Total
Water Use
1974 2000
50.8 97.5
171.3 122.5
105.4 310.8
170.2 371.8
616.8 1516.7
504.9 1412.1
315.8 643.1
48.6 125.6
40.7 175.1
75.8 88.5
2100.3 4869.7
downstream gaging stations
. data (US-676)




-------
 the  southern portion of the lignite trend.  However, the massive
 ground-water supplies in extreme South Texas (in the "Winter
 Garden" area) are already now being mined because irrigators are
 withdrawing water from the prolific Carrizo-Wilcox aquifer at
 a rate exceeding recharge over wide areas.  A continuation and
 areal expansion of ground-water mining is a probable consequence
 of lignite development in South and southern Central Texas.  It
 appears likely that more intensive use of the surface-water re-
 source, even in East Texas, as a direct result of lignite develop-
ment will cause increasing reliance on ground water as a source
 of municipal and domestic water supplies.  (These supplies must
be of high quality and are therefore more limited).   This in-
 creasing reliance is not necessarily unfavorable, but may lead
 to increased water production, transmission, and possibly treat-
ment costs to be borne ultimately by the consumer.  Also, local
 conflicts between agricultural use and use related to lignite
utilization are also conceivable, especially in South Texas.
Ground-water depletion incidental to mining may be of local
importance, but generally should not be of regional concern.

          A more comprehensive evaluation of impacts of future
 lignite utilization on water resources requires further study of
specific water requirements as to quantity and quality for direct
and indirect use,  disaggregated according to source and basin,
and a more specific basin and aquifer analysis in the immediate
vicinity of mine sites.   This is not possible in the present
study.

4.3       Cumulative Effects on Water Quality

          Lignite development will not only impose larger demands
 for rather high-qxiality water, but also may stress existing
quality of surface and ground waters.  The assessment of these
potential effects is hampered by the lack of documentation of
                               104

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RADIAN
•*^_>«^»BB>HVU
  mine-related water quality impacts to date.   Generally,  however,
  direct water quality effects of lignite development may  accrue
  as a result of either introduction of pollutants from mining
  and power generation, or indirectly by consuming assimilative
  capacities or altering flow regimes.  Secondary effects  are re-
  lated to municipal wastewater discharges and domestic uses.

            In general, while water quality effects must continue
  to be addressed at a site-specific level to avoid potential local
  problems, it appears that the long-term deterioration of water
  quality as a result of mining may be of concern only if  a number
  of mines are closely associated and are discharging to the same
  surface and/or subsurface hvdrolo-ic system.

  4.3.1     Water Pollutant Sources and Pathways

            Both mining and lignite-fired power generation have a
  potential to degrade surface and ground water directly by intro-
  ducing a variety of pollutants into the environment.  Most of
  these sources and pathways are similar to those well-known ones
  discussed in numerous recent references (e.g., NA-172, DO-108,
  DO-143, WA-185) and such generic descriptions of impacts will
  not be repeated here.  Rather, the focus of this discussion will
  be on specific features and characteristics of the Texas lignite
  belt and lignite utilization that may affect the extent  to which
  significant impacts occur.

  4.3.1.1   Mining Impacts

            Suspended solids will probably be of most concern for
  surface water quality degradation as a result of mining.  Over-
                                105

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CORPORATION
  burden composed of the Calvert  Bluff  formation  tends  to have
  moderately high intrinsic  credibility,  and  spoil will usually
  require an extensive sedimentation pond system  for adequate in-
  terim  sediment  control.  Effluent limitations of PL 92-500 (Federal
  Water  Pollution Control Act Amendments  of 1972) and the new
  Surface Mining  Reclamation and  Control  Act  (PL  95-87) should
  provide assurance  that the generally good experience with ef-
  fective siltation  control at existing mine  sites will continue.

            Perhaps  of more  concern is nonpoint-source  stream
  siltation  that  results  from hydrographic modifications, es-
  pecially straightening  and channelizing streams on the periphery
  of mined areas.  Unless carefully planned and executed, these
  modifications can  cause large increases in  suspended  sediment
  and bed loads due  to bank  instability and increased velocities
  (EN-102) .

            At most  locations, seepage  into the pit will be rela-
  tively minor, even though  the water table is above the lignite
  to be  mined.  Perhaps 1000 gpm  is an  average or typical order-
  of-magnitude value for  such seepage.  This  low  discharge is due
  to the overall  low permeability of the  Calvert  Bluff  formation
  and Yegua-Jackson  strata.  At some locations, however, mining
  will intersect  fairly extensive sandy zones which  transmit
  considerable quantities of water downdip.   These sandy zones,
  which  usually correspond to fluvial and deltaic distributary
  channels associated with major  depositional systems, occur locally
  throughout the  lignite  belt, and may  necessitate the  use of de-
  watering systems for seepage control.   (Also, surface mining in
  a few  areas of  the lignite belt may intersect the very permeable
  alluvium of major  modern streams, and similarly require seepage
  control.)   Generally, such dewatering systems will involve dis-
  charge of  significant amounts of ground water to rather small
  surface streams.   Discharged shallow  ground water  in  general
                                106

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HAINAN
 will be more highly mineralized than average surface waters, with
 increased concentrations of major cations and anions, especially
 chlorides, sulfates, calcium, and usually iron.  This quality,
 however, may not be very different than the water chemistry
 of low flows.  To minimize surface quality  degradation and
 and water impacts, dewatering products may be used for dust con-
 trol, for reclamation,  if of suitable quality, and even for elec-
 tric power generation,  if properly planned in the plant water
 management sy s t em.

           No induced acidic mine drainage has been noted in either
 surface or subsurface waters in the vicinity of existing mines.
 This may be more a function of low substrate permeability, high-
 quality lignite and good mining techniques than the regional ab-
 sence of acid-forming or toxic material.  Certainly in areas
 where lignite has higher sulfur contents, (viz, South Texas and
 especially the Yegua-Jackson deposits),  possible problems with
 acidic mine waters cannot be ruled out.   Limited observations
 indicate some natural streams draining lignite outcrops have
 rather high iron and sulfate contents, and also (though rarely)
 have yellowish-orange stains along their banks.  Some observed
 mine seepage that has been in prolonged contact with disturbed
 overburden exceeds secondary drinking water standards for chloride
 and especially sulfate, and conceivably some primary inorganic
 standards, although no data on the latter possibility are availa-
 ble.  However,  much Wilcox lignite in East Texas is rather low
 in sulfur (less than 17o) ; and,moreover,  much of the sulfur is
 organically bound rather than in acid-producing pyritic form.
 This suggests that any noticeable problems with acidic drainage
 may not occur for some time, until the lower-quality lignite in
 the humid East Texas area is mined.  It should also be noted
 that even though Wilcox lignite of South Texas has decidedly
 more acid-producing potential,  the aridity of that environment
 may not generally promote formation of acidic drainage, especially
 in view of the limited development projected there.

                               107

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           The production of toxic concentrations of heavy metals
 or  other  substances as a result of mining also has not been
 documented in the  lignite belt.  Some infiltration undoubtedly
 will  encouter zones in the disturbed overburden that are of
 inferior  quality,  and may be degraded, but such strata apparent-
 ly  are not widespread, either areally or stratigraphically.
 However,  such infiltration is difficult to detect and some de-
 graded recharge from existing mined areas may be entering the
 regional  ground water system of the Wilcox aquifer,  Such flow is
 hydraulically possible, where the lignite is hydrologically con-
 nected with the recharge area of a major aquifer zone (see Figure
 4.3-1).   However,  the vertical leakage of degraded water through
 the Calvert Bluff  aquitard to the Simsboro or its equivalent is
 likely to be small in relation to the mass flux through the
 aquifer,so water quality problems due to any undispersed pollu-
 tants are  likely to be of only local, if any, significance.
 Aquifers  associated with the Yegua-Jackson lignites tend to be
 very restricted and so mineralized naturally as to be unsuitable
 for most water supplies;  effects of toxic materials entering
 these small, discontinuous sands are likely to be inconsequential.
 Again, it  is reiterated that nowhere in the lignite belt have
 these hypothetical situations been realized at present.

 4,3,1.2    Impacts of Power Generation

          Operation of lignite-fired power plants may produce
both aqueous and solid waste streams that may degrade water
quality.   Generally though, application of effluent limitations
 in PL 92-500 (the Federal Water Pollution Control Act Amendments
of 1972)  are sufficient to protect surface water quality.
 Furthermore, for many locations in the lignite belt where off-
 stream impoundments are possible, zero-discharge to surface
waters may be obtained under proper water management, except
 during extremely heavy, prolonged rainfall events.
                               108

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RECHARGE AREA
                                  MINED  AREA
                                                                    WATER TABLE
                                                                        AND
                                                               POTENTIOMETRIC SURFACE


                                                                       U/VD
                                                                       CALVERT
                                                                        BLUFF
                                       FIGURE 4.3-1

                            LOCAL GROUND-WATER FLOW RELATIONS
                   AFTER MINING IN CARRIZO-WILCOX AQUIFER (HYPOTHETICAL)

-------
          However,  discharges  to ground water are usually not
 avoided  or  directly controlled.  Leakage from ash and scrubber
 sludge ponds and also cooling  reservoirs eventually will enter
 the regional ground water system or will be discharged to sur-
 face  streams after  residing in the subsurface for some time.
 Generally,  lignite  will generate more ash and scrubber sludge
 than  imported coal, and lignite's utilization may therefore
 require  more surface area dedicated to control of ash and sludge.
 Most  of  these ponds will be located in East and northern Central
 Texas, where ground water use  is likely to increase dramatically
 by the year 2000.

          The ponds will be sites of relatively concentrated
 recharge, which may contain considerably higher major and minor
 constituents than the shallow  ground water.  In particular,
 ash ponds have relatively high pH's and may contain elevated
 concentrations of soluble trace elements as well as major cations •
 and anions.  Cooling reservoirs, on the other hand, even if
 located  directly on the recharge zone, will generally contain
 water of high quality and are  not deleterious; their effect is
 more  hydrodynamic than water quality-related.

          Ash and scrubber sludge ponds are usually integrated
 into  a water management system.  In such systems, all aqueous
 (and volumetrically most solid) wastes are at least temporarily
 stored in ponds,  where the supernatant is discharged as overflow
 to surface streams  or as leakage to the subsurface.   Any con-
tainment pond which discharges to a surface stream without further
 treatment is subject to regulation,  which thus  indirectly controls
 the quality of seepage into ground water.   In addition,  attenuation
of minor, toxic constituents is effectively provided by organoclays
in the subsurface.   Nevertheless, the presence  of large number of
these ponds  within  the recharge zone of an aquifer that is widely
used as a water supply may be a source of concern to overall
                               110

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RADIAN
 water quality, but especially with respect  to secondary criteria
 of the National Incerim Drinking Water Standards,  (e.g.,  chlorides
 and sulfates).  Techniques have been developed for "fixing"  sludge
 and ash to render them less soluble.   Along with the use of  pond
 liners to retard seepage, these should greatly reduce the danger
 of serious ground-water contamination.  Otherwise, intensive
 lignite development could possibly lead to  locally degraded  con-
 ditions, and possibly foreclose the domestic use of ground water.

           The permit requirements pursuant  to the recent Resource
 Conservation and Recovery Act may be a mitigating factor if  fly
 ash is judged to be a hazardous material, as is currently being
 debated.  The permit would require a very detailed hydrogeologic
 investigation and monitoring plan at the ash disposal site before
 disposal would be approved.  Again, however, no ground water
 contamination of any kind by ash disposal ponds has ever been
 demonstrated in the lignite region.

 4.3.2     Alterations to Hydrodynamics

           Altered hydrodynamic conditions in surface and subsur-
 face waters may change the water quality.   Perhaps the most
 important factor in this regard is consumptive use of water.
 The long-term retention of runoff in cooling reservoirs or settling
 ponds is similar to consumptive use in its  effect.  Both of
 these mechanisms decrease the flow that otherwise would be avail-
 able in a drainage basin, and this is especially significant
 during low flow periods.   The decreased flow is associated with
 a decreased assimilative capacity.  In conjunction with the
 addition of pollutants by other mechanisms,  this might result in
 decreased water quality for an indeterminate distance downstream
 of the lignite belt during lower flows.
                                Ill

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          Mining itself may temporarily reverse hydraulic gradients
as a result of widespread seepage into the pit, and may be induced
by dewatering practices.  Also, backfilling of mines with disturbed
material may reduce or increase flow through that area, resulting
in steeper or flatter hydraulic gradients over a large area.  In
the lignite belt, this condition will probably be of only minor
significance to water quality, since the different Leakage induced
from other strata as a result of potentiometric changes is not
likely to be very different on average than that which originally
existed.  Moreover, it seems unlikely that hydrodynamic velocity
changes as a result of lignite utilization would be so drastic
as to affect materially the attenuation potential or natural
geochemical processes governing existing ground water quality.

4.3.3     Secondary Effects on Water Quality

          As long as capacity is available in municipal systems,
the wastewater generated by the increased urban population
accompanying lignite development should not result in changes
in treated effluent quality.  However, the assimilative capacity
of receiving streams may be taxed by the additional pollutant
mass loadings (see also discussion of 4.3.2) which may result
in reduction of dissolved oxygen concentrations to levels dele-
terious to aquatic biota.  Especially in East Texas, numerous
small towns will be the focus for population growth and will be
required to provide expanded sewerage services with existing
systems.  Wastewater treatment facilities may be strained
hydraulically or organically, at least in the short run,  resulting
in a treated effluent quality that is poorer than designed and
probably inadequate to protect in-stream quality of the generally
small receiving streams.  This will be especially true if a number
of communities with such problems discharge to the same stream
system.
                               112

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          Population increases also suggest additional water
pollution from leachates of sanitary landfills, septic tanks,
and from urban runoff, but these incremental impacts are not
considered significant at the regional level of this analysis.

4.3.4     Estimation of Aggregated Effects

          Intensive lignite development will tend to decrease
water quality of surface streams and ground water in the vicinity
of the mine and power plant sites, and downstream of municipal
outfalls.  Direct effects of lignite utilization will tend to
be manifested as increased dissolved solids.  Secondary effects
will probably be reflected in low dissolved oxygen in streams
and increased eutrophication in downstream impoundments.

          Most of these water quality impacts will not be ob-
servable in the near term.  Even in the long term, the extent
to which the impacts are significant will depend largely on the
spatial distribution of the related activities within the
lignite belt, and their relation to other features and activities.
However, impacts on ground water quality may be of more serious
concern than is currently envisioned, owing to the increasing
reliance that must be placed on the ground water resource as a
water supply for all future needs.

4.4       Cumulative Effects of Air Emissions

          This analysis of cumulative air emissions from lignite
development suggests that, despite favorable climatology, sulfur
oxide-related effects may become appreciable by the year 2000
through large-scale, temporary plume interaction.  The significant
adverse impacts, if any, of these cumulative effects have not
been specifically determined.  However,  it should be observed
that the existing rules and regulatory policies, which are designed
                              113

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to protect human health and welfare against deleterious air
quality, apparently will not practically prevent the intensive
development of lignite envisioned in Section 2.4.  In particular,
such intensive development can evidently comply with all applicable
New Source Performance Standards and new guidelines for prevention
of significant air quality deterioration.  The inference is that
substantial adverse impacts to air quality will not occur.
Nevertheless, by the year 2000, any additional development will
probably exacerbate a trend toward regional air quality deteriora-
tion.  Locally, prevailing air quality regulations may effectively
prevent lignite utilization, especially in areas near the lignite
belt.
          The factors which affect the impacts of lignite develop-
ment on the regional air quality are the air quality regulatory
framework, the regional meteorology, and the sources of emissions.
Each of these factors is described in the subsections below.
Virtually no air quality data exist in the rural areas of the
lignite belt, and ambient quality can not be related to existing
emissions.  Existing air quality data are restricted to criteria
pollutants in urban areas surrounding the lignite belt.  Conse-
quently, detailed air dispersion modeling, even though largely
in an uncalibrated mode, is the most accurate, current method
of projecting air quality impacts of existing and future lignite
development.  However, this modeling is not within the scope of
this project, so cumulative effects have been more qualitatively
addressed.

4.4.1     Regulatory Framework

4.4.1.1   Emission Standards

          Texas' emission regulations applicable to existing
lignite-fired sources are much more stringent than current
                                114

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RADIAN
 Federal standards (see Table 4.4-1).   However,  except  for NOX,
 the Federal New Source Performance Standards  (NSPS)  are identical
 to those of Texas,  and also are the same for  either  coal or
 lignite.  Thus, even low sulfur coal  holds no great  advantage
 over lignite.  At this time, no Federal emission regulation for
 NOX exists for lignite-fired sources, while Texas recognizes a
 limitation of 0.7 pounds of N0x per million Btu input.   EPA has
 proposed a NSPS for NOX from lignite-fired units of  0.6 pounds
 per million Btu.  (The EPA N0y NSPS for coal-fired units is 0.7,
                              ^                                 *
 the same as Texas.)

           However,  all of these NSPS1s,  and especially  that  for
 particulates, are expected to be made more stringent by the 1980's.
 At the present time, it is reasonable to believe that  the more
 efficient control technologies applied  to new coal-fired units
 to meet more stringent NSPS will be applied to new lignite-fired
 units as well.  Thus, air quality impacts are expected to be
 equivalent for the  two kinds of plants.   However, the  associated
 impacts on media other than the atmosphere (e.g., water supply,
 water quality, solid waste) may be quantitatively different.

 4.4.1.2   Prevention of Significant Deterioration

           All areas with ambient concentrations lower  than the
 Primary National Ambient Air Quality  Standards (NAAQS)  are sub-
 ject to the Prevention of Significant Deterioration  (PSD) (Section
 127 of the 1977 Amendments).  Under this section, the  EPA regional
 offices, or the state agencies which have been delegated authority,
 must review major new stationary sources in 28 categories, includ-
 ing lignite-fired steam electric units  with heat inputs greater
 than 250 million Btu per hour (about  20 MWe).  for requisite
 approval to obtain  permits to construct.   The current  approach
 to preventing significant deterioration of air quality consists
 of two parts.   First, cumulative increases in ground-level con-
 centration resulting from new sources commencing construction
                                115

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                                                TABLE 4.4-1
                           EMISSION STANDARDS FOR COAL AND LIGNITE-FIRED STEAM
                      ELECTRIC UNITS WITH GREATER THAN 250 MILLION Btu PER HOUR INPUT
                                                                                            i
  Pollutant
Sulfur Dioxide
Total Suspended
Particulates
(TSP)
Nitrogen Oxides
(NOX) for Lignite
Fired Boilers
  Existing Source Performance Standards
(pounds of pollutants per million Btu input)
    Federal*Texas
       5.0
    0.4 - 4.0
3.0
0.3

0.7
                       New Source Performance Standards
                  (pounds of pollutants per million Btu input)
                      Federal	         Texas
1.2
0.1
1.2
0.1

0.7
^eknekron, Incorporated, Environmental Regulations Affecting the Utility Industry in Texas. April 3, 1975
2EPA has proposed a NOX standard for lignite-fired units of  0.6 pound.  The state standard of 0.7
 pound applies to both coal and lignite.

-------
or modification since January 1, 1975, may not exceed the incre-
ments set forth in the Amendments.  These increments are given in
Table 4.4-2.  Second, the sum of baseline air quality plus the
increment theoretically allowable under the law may not exceed the
National Primary or Secondary Ambient Air Quality Standards.   Thus,
the full incremental increase will not be allowed in practice if
it causes violation of the NAAQS.

          Presently, PSD increments apply to total suspended
particulates (TSP) and sulfur oxides.  But the Administrator
of EPA is required to promulgate regulations for prevention of
significant deterioration from hydrocarbons, carbon monoxide,
photochemical oxidants, and nitrogen oxides within two years of
the enactment of the 1977 Amendments.

          Baseline ambient air concentrations are nominally those
of 1974, according to the Clean Air Act Amendments of 1970.  Con-
sequently, to determine what proportion of the increment is avail-
able for a proposed new source, it is necessary to account for
the contributions of all other major sources brought on line
since January 1, 1975.  In most areas, these contributions must
be calculated by detailed dispersion  modeling.

          In applying PSD, three classes of areas are recognized,
each with different allowable increases of ambient air concen-
trations above the baseline  concentration.  Areas designated
Class I are regions in which virtually any deterioration in air
quality is considered significant, which essentially prohibits
any major new sources within such areas.  The new amendments
specify certain mandatory Class I areas, but none of these fall
on or near the lignite belt.  In Class II areas, air quality
deterioration normally accompanying moderate, well-controlled
growth would be considered insignificant.  All areas within the
United States, except the mandatory Class I areas and areas
                               117

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                                                       TABLE 4.4-2
oo

PREVENTION
OF SIGNIFICANT
MAXIMUM ALLOWABLE INCREASES

CONCENTRATIONS UNDED
THE CLEAN AIR
DETERIORATION :
IN S02 AND TSP
ACT AD1IENDMENT8 OF
Maximum Allowable Incremental

Pollutant
Sulfur Dioxide
(S02)


Total Suspended
Particulates
(TSP)

Averaging Time
Annual Mean
24-Hour2
3-Hour2
Annual Mean
24-Hour2


Class I
2
8
25
5
10

(vig/m3)
Class II
20
91
512
19
37

19771
Increases

Class III
40
182
700
37
75

               1A11 areas are desingated Class II except Mandatory Class I Areas.
               2The 3-hour and 24-hour SC<2 and TSP concentrations may be violated not more
                than once per year.

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BMHAM
 designated Class I tinder previous PSD regulations,  are Class II
 areas.   The states can redesignate Class II areas either Class
 I or,  within limits, Class III.   In Class III areas,  the maximum
 allowable increases are about half the National Primary Ambient
 Air Quality Standards, with the exception that the  24-hour maximum
 allowable increases may be exceeded once a year without contraven-
 ing the standard.

           Cumulative emissions from all new major sources brought
 on line since January 1, 1975, must not exceed the maximum
 allowable increases in the immediate vicinity of the  proposed
 new source, or the applicable increases in adjacent areas within
 the "area of influence" of the proposed new source.  The "area
 of influence", as presently defined by EPA Region VI, is the
 region around a source in which the source alone will not cause
 the maximum allowable increases for a Class I area to be exceeded.
 Two areas of influence for each source exist:  one for SOa  and
 another for TSP.  Within a given area of influence, the increment
 is "used" on a first-in-time, first-in-line approval  basis,  until
 the increment is exhausted, after which no new sources can be
 approved.  Technologically, the last user of an increment generally
 must have more efficient control technologies than the existing
 source(s) within the area, in order to not violate the allowable
 increment.

           The allowable PSD increments for S02 and TSP are
 shown  in Table 4.4-2.  Significantly, the recent Clean Air
 Act Amendments have revised the 24-hour and 3-hour S02 incre-
 ment for Class II areas downward from 100 to 91 yg/m3 and from
 700 to 512 yg/m3, respectively.
                               119

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4.4.2     Dispersion Potential in the Lignite Belt

          The Texas lignite belt in general has few problems with
large-scale poor dispersion conditions.  When problems do occur,
they are usually associated with a strong, stagnant high-pressure
system with light winds.  The mass of high-pressure air tends to
sink, causing it to warm by compression  as it nears ground level.
This results in a temperature inversion characterized by low
mixing depths.  The light surface winds further reduce dispersion
potential.  Poor dispersion conditions of this kind may last for
two or three days.  The eastern half of the lignite belt experiences
the most dispersion problems (relatively few in comparison, for
air stagnation decreases from east to west across the region).
The general dispersion conditions throughout the region are fairly
good, partly because moderate surface winds and good thermal mix-
ing are prevalent much of the time.

          On the average, only about five periods of extended
poor dispersion conditions (conditions requiring the issuance
of an Air Stagnation advisory by the United States Weather
Service) occur during the year.  These Air Stagnation Advisories
are issued mostly over the Southeast Texas region; only the
extreme southeastern sections of the lignite belt are affected.
These stagnation conditions most commonly happen during August,
September, and October, although they can occur during any month
of the year.

          The air pollution potential of the Gulf Region will
not be affected significantly by micrometeorological conditions,
primarily because the terrain is basically flat and uniform.
Tree canopies and other vegetation could diminish wind speeds
and deflect wind directions slightly, but the mixing layer as
a whole will not be affected.  Only low-level dispersion will
be affected by these terrain irregularities.  Normally, power
                               120

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HAINAN
^^^^^•^^ft^^hMA JBM1A4
 plant plumes exist at  much higher elevations  than near-surface,
 terrain-induced turbulence can reach.

           Violations of both the primary and  secondary state
 standards for particulate matter are unusual  in the  Texas  lig-
 nite belt.  Dust storms can raise ambient particulate  levels
 in the spring months to levels which can exceed short-term
 criteria.  However, blowing dust raised by large-scale meteoro-
 logical condiitons is not counted in the air-quality data  base.
 The highest potential for dust storm activity is in  the southern
 and southwestern portions of the lignite belt.   Dry  conditions
 during the early spring and strong westerly frontal  winds  often
 bring dust from the West Texas plains into the region.

 4.4.3     Emission Control Technology

           Both lignite and coal combustion will now  require the
 use of BACT.  At least in the near term, this  means flue-gas
 desulfurization (scrubbers) and some form of  particulate control.
 Texas has established a visibility standard (20 percent opacity),
 in addition to particulate emission rates.  The visibility standard
 usually is the more stringent of the two.  The Texas Air Control
 Board has required one power plant to install fabric filters  in
 addition to conventional electrostatic precipitation (ESP). to
 enable it to meet this standard.

           There may be a number of differences between Texas
 lignite and western or mid-western coal which might  significantly
 affect their S02 and particulate emissions.  The most  apparent
 of these are:
                                121

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             Heating value
             Trace metal content
             Ash content
             Ash resistivity

For a power plant of fixed size, the amount of flue gas generated
by burning lignite should be roughly equal to that generated by
burning coal.  This is true because the air rate is determined
by the desired carbon-burning rate (heat rate), which is approxi-
mately equal for all fuels.   The physical sizes of required sulfur
dioxide scrubbers and fabric filters are determined more by gas
volume than any other single parameter.  We can then conclude
that the size of sulfur dioxide scrubbers and fabric filters
required will not be significantly different if lignite or coal
is used as a fuel.   While the actual scrubber size is generally
independent of the fuel, the scrubber's ancillary equipment
may well not be.  The size of this equipment (pumps, storage
tanks, clarifiers,  filters,  etc.) depends more upon the quantity
of sulfur to be removed.  This quantity will, in all likelihood,
be greater for lignite than for coal, since lignite contains
more sulfur per Btu than most western coals.

          Thus, the magnitude of the solids disposal problem will
be greater for lignite than coal.  Three factors are responsible:

             The amount of sulfur to be scrubbed (on an equal
             power basis) is most likely greater for Texas
             lignite than for coal.

             The amount of ash produced (on an equal power
             basis) will be greater for lignite than for most
             coals.
                               122

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           •  The trace metals composition of lignite may well be
             greater  than for most coals.  This will result in a
             greater  concentration of such objectionable metals
             as mercury and arsenic in the ash/solids to be
             disposed of.

           However,  solid waste transportation may be less of a
problem for those  lignite-fired generating stations which can be
located at the mine-mouth, where at least some of it can be buried
during reclamation.

           While the size of a fabric filter would not seem to
depend as  much on  the choice of fuel, the case for electrostatic
precipitators (ESP's) may be different.  The size of an ESP is
governed by the gas volume and a parameter known as the migration
velocity.  The migration velocity in turn depends upon the par-
ticle size, shape  and electrical resistivity.  Appropriate elec-
trical resistivities  for efficient ESP operation are generally
given as 1010 ohm-cm  to 107 ohm-cm (SO-004).  There is a range of
sulfur content that corresponds to this  "window".  Below this
range, resistivity can tend to increase  to the extent that, for
very low sulfur fuels, some chemical treatment of the flue gas
may be necessary for  efficient ESP operation (SO-005).

           It is also  true that ash resistivity can be correlated
with the content of such metals as sodium and lithium (BI-035).
This too may cause  the resistivity of lignite ash to be inappro-
priately for optimal  ESP operation, and  therefore require utili-
zation of  fabric filters for achieving stringent particulate
emission standards.

           The physical properties and leaching potential of a
mixture of ash and  scrubber sludge has been shown to be a very
strong function of  the site-specific nature of the fuel being
burned.  It is quite possible that a mixture of lignite ash

                              123

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and sulfur sludge would behave differently than a similar
mixture produced with coal ash.  No generalizations can be drawn
without designating specific fuels, however, as to which mixture
might be the most desirable.

          The possible differences between emission controls for
coal and lignite-fired steam stations can then be summarized as
follows.

             The size of ancillary equipment may be larger
             for lignite-fueled plants, although the physical
             size of sulfur scrubbers and fabric filters
             should be about the same.

             The solids disposal problem will be aggravated
             for lignite-fueled plants  inasmuch as the amount
             of material to be disposed of will be larger and
             its objectionable trace metals content may well
             be greater.

             The required amount of suitable land for solids
             disposal will probably be  greater for lignite-
             fueled plants than for coal.

             The size of ESP's required may be larger for
             lignite than for coal (or  chemical treatment
             of the flue gas may be necessary) if extreme
             values of ash resistivity  are encountered.

             Except for size and material handling problems,
             no significant difference  is expected in the
             cost or problems associated with the operation of
             sulfur scrubbers, fabric filters, or electro-
             static precipitatorc.
                               124

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          •  The physical behavior and leachate potential
             of ash/sludge mixtures is extremely dependent
             upon the specific fuel being used; large
             differences can be expected, but no accurate
             generalizations can be drawn until specific
             fuels have been identified.

4.4.4     Impacts on Air Quality By Emissions from Existing
          Sources

          Because of the lack of monitoring data, existing air
quality impacts must be described largely by inference.  Lig-
nite-fired steam electric stations are not expected to have a
significant effect on the carbon monoxide (CO) and nitrogen
oxides (NOX) concentrations in the region or in the urban areas
around the lignite belt, where these pollutants are of more
concern.  Most of these CO and NOX ground-level concentratons
arise from motor vehicles.  Hydrocarbon emissions from the lignite-
fired units will be controlled to very low levels by boiler firing
practices, and are not expected to produce adverse impacts on
ambient air quality.  Consequently, the discussion of air quality
and emissions focuses on S02 and particulates.

          The primary souces of S02 in the lignite region are
lignite-fired steam electric stations and production of oil and
gas.  The emissions from oil and gas production are relatively
small compared to the power plant emissions,  but they generally
have much greater effect on ground level air quality in the
immediate vicinity of well fields, because they are emitted at
low release heights and have low plume buoyancy.   The S02
emissions from the lignite-fired units in operation in 1975
                               125

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(see Figure 2.2-2) were approximately 190,000 tons per year.1
However, because of the large distances between these stations,
their cumulative impact on regional air quality is considered
negligible.

          The air quality impacts of fugitive particulate emissions
from mining and processing the lignite are generally limited
to the vicinity of the mine.  All existing lignite mines are in
East Texas and eastern Central Texas, where the rainfall is
sufficient to limit the periods in which fugitive dusts can arise.

          The existing lignite-fired steam electric stations in
1975 had particulate emissions of about 22,000 tons per year.
The cumulative impact on current regional air quality is again
believed to be negligible.  The relative contribution of the
lignite-fired stations to ambient particulate concentrations
is expected to be much less than for S02.   First, particulate
emissions are typically an order of magnitude less than S02
emissions.  There will also be a large number of other substantial
sources releasing particulates at low levels.  To determine more
accurately the impacts of the lignite stations on particulate air
quality, all point and area sources in the lignite belt would
have to be inventoried and analyzed in detail.
 The SOz and particulate emissions were calculated using the annual
 emission rates of Big Brown and Sandow stations in the 1973 Texas
 Air Control Board Emission Inventory.  The Monticello Units 1 and
 2 were calculated as sliming the units complied with Federal New
 Source Performance Standards (NSPS) and had a heat rate of 10,000
 Btu/lb. and 7070 load factor.  The lignite was assumed to have a
 heating value of 7,135 Btu's per pound.
                               126

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RAMAN
 4.4.5     Cumulative Impacts of Future Lignite Development

 4.4.5.1   Basis of Impact Determination

           In order to place the air quality impacts of future
 lignite development into a temporal perspective,  two time inter-
 vals have been selected:  from the present to 1985, and from
 1985 to 2000.  Because it takes roughly seven years to design
 and build a lignite-fired unit, many of the units that will be
 operating by 1985 have been announced and their locations declared.
 However, little information is available on the size and location
 of lignite units to come on line after 1985, because utilities
 are unwilling to make firm commitments within the present fuel-
 related uncertainties.

           The impacts discussed below are based on new lignite-
 fired steam electric stations consisting of two typical 750 MWe
 units equipped with flue gas desulfurization systems and about
 450-foot stacks.  Each boiler will burn lignite ranging from
 6,500 to 7,500 Btu's per pound, and will have a stack exit tem-
 perature of 165°F.  From an air quality standpoint, this station
 may be considered a reasonable worst case; therefore,  the impact is
 conservative.

           S02 emissions from such a plant will generally produce
 ground-level ambient concentrations that are less than half the
 federal primary and secondary 3-hour and 24-hour standards.  The
 maximum short-term ground-level concentrations near the station
 will occur when the plume is trapped below an inversion.  At
 greater distances from the station, the highest short-term ground-
 level concentrations will occur during persistent temperature
 inversions with steady winds blowing in a line with the sources.
                                127

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          A significant qualifying factor that should be recog-
nized is that the model used to predict downwind concentrations
becomes inaccurate at large distances from the station.  The
Gaussian plume dispersion model presently accepted by EPA be-
comes inaccurate beyond 50 kilometers (31 miles).  The model also
fails to account for decreases in pollutant concentrations asso-
ciated with pollutant transformation and removal processes, such
as dry deposition and chemical transformation.  Finally, there
are insufficient reliable dispersion data to determine both the
horizontal and vertical spread of plumes at these distances from
the source.

          In the southwestern portion of the lignite belt, which
generally contains lower-quality lignite and also has lower
annual rainfall, the potential for fugitive dust is higher.
However,  the mine operators will dampen the haul roads to minimize
the formation of fugitive dust, and use dust-suppression systems
to control the emissions from lignite handling.  The handling of
lignite for mine-mouth steam electric stations typically does
not include processes that heat, wash, or blow air upon the lig-
nite, or involve discrete air emission sources.  At handling
facilities, such as hoppers, silos, stackers, and crushers, dust
suppresion systems dampen the lignite for dust control.  Also,
the dust collection systems are generally used at transfer points
to minimize dust release from lignite handling.

4.4.5.2   Lignite Development to 1985

          A large expansion of lignite-fired steam-electric
generating capacity has begun in Northeast Texas, as is dis-
cussed in Section 2.2.  Not all of the new units, however, are
subject to the PSD review by EPA.  The proposed new units at
the Martin Lake Station (2250 MWe), described in Table 4.4-3,
will need to meet NSPS standards only.
                               128

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                                                       TABLE 4.4-3
PROPOSED LIGNITE-FIRED STEAM ELECTRIC STATIONS NOT REQUIRED
Municipal
Utility System
Texas Utilities
Services, Inc.


OBTAIN
Station Number
and Number
Martin Lake //2
Martin Lake //3
Martin Lake #4

TO
PSD APPROVAL FROM EPA
County
Rusk
Rusk
Rusk

City /Town
Tat urn
Tatum
Tat urn
TOTAL
Capacity
(Mtfe)
750
750
750
2,250
Date On Line
1978
1979
1983

NO

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                                            TABLE 4.4-4
Station/Number

Monticello #3



San Miguel #1
Sandow #4

Gibbons Creek

 #2

Forest Grove
 #1

Twin Oak #1
PROPOSED LIGNITE-FIRED STEAM-ELECTRIC STATIONS WITH KNOWN
SITES AND WHICH
Principal Utility
System
Texas Utilities
Services, Inc.
(TUSI)
South Texas and
Medina Electric
Cooperatives &
Texas Municipal
Power Agency

TUSI
TMPA
TUSI
TUSI
SW Electric
ARE REQUIRED TO OBTAIN PSD
County City/Town
Titus Mt. Pleasant
Atascosa Jourdanton
Atascoas Jourdanton
. Milam Rockdale
Grimes Carlos
Grimes Carlos
Henderson Athens
Robertson Franklin
Robertson Franklin
Marion Longview
APPROVAL
Capacity
(Mtfe)
-750
400
400
545
400
400
400
562
562
660
FORM EPA
Year of
Start-Up
1978
1979
1984
1981
1985
1982
1982
1984
1985
1985
Buffer
Distance
(mi)
15
16

11
16
8
22
13
                  Power Coopera-
                  tive

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                       TABLE 4.4-5
PROJECTED LIGNITE-FIRED STATIONS WITHOUT LOCATION SPECIFIED
Principal
Utility System
Houston Lighting and Power
City Public Service
Board of San Antonio
/
Lower Colorado River
Authority
Capacity
(MWe)
750
375
750
Date On
Line
1982
1983
1985
                          TOTAL    1,875
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          Utilities have proposed an additional 6,954 MWe of lignite.
fired generating capacity, to be operating by 1985.  All of these
units are required to have PSD approval by EPA to obtain permits
to construct.  Presently seven new lignite-fired stations (or
new units), with a total capacity of 5,079 MWe, have announced
plant sites and already have or will apply for PSD review.   These
are listed in Table 4.4-4.  The sites for the remaining 1,875 MWe
proposed to be operating by 1985 nave not been announced; data
on these units are presented in Table 4.4-5.

          These lignite-fired stations, including both existing
and proposed units, are projected to emit about 550,000 tons of
S02 and 51,000 tons of participates per year.  This approximately
three-fold increase in emissions is not expected to affect
significantly the annual average concentrations of TSP or SOz
in the lignite belt.   Of more concern are possible plume inter-
actions with new stations built in the lignite belt.

          One method of assessing the cumulative short-term air
quality impacts of the future lignite development is to evaluate
whether such development can occur without exceeding applicable
PSD increments for the worst-case conditions.  If this is possible,
potential problems with cumulative air quality impacts from lig-
nite development are not likely to exist.  All of the lignite belt
is designated as a Class II area.  However, the proposed Big
Thicket National Wildlife Preserve may be designated as Class I.
A Class I designation of this wildlife preserve may limit the
size or location of the mine-mouth steam-electric stations in the
East Texas portion of the lignite belt.

          The minimum distance between two lignite-fired stations
that will cause no significant interaction of their plumes to occur
is determined by the short-term S02 concentrations.  (The maximum
annual S02 concentration will be less than the allowable Class II
                                132

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oADIAN
•*^j>BM0HVa4
  increments,  and generally occurs too close  to  the  source  for  it
  to interact  with another.)  The maximum ground-level  concentrations
  of particulates from such stations are everywhere  less  than the
  Class I increment,  and could therefore interact without exceeding
  PSD increments.  The maximum short-term S02 concentrations
  caused by two interacting sources occurs when  the  wind  direction
  is aligned with the sources.   Using this worst-case  configuration,
  the air quality degradation may be modeled  under worst  condition
  assumptions  to define the distance separating  any  two plants  which
  negates the  particular Class  II increment being violated  by the
  interaction  of the two plumes.

            This distance, of course, varies  with  the  sizes of  the
  two stations being considered and with their physical and operat-
  ing characteristics (e.g., stack heights and exit  temperatures).
  For two 1,500 MWe stations with the reasonable worst-case
  characteristics described above, this distance is  about 30 miles
  for the 24-hour increment, and 18 miles for the  3-hour  increment.
  Hence, the 24-hour increment is the more limiting  case.  Under
  these conditions, a separation of 30 miles  is  a  rough guideline
  for insuring that no significant plume interactions  occur.  Since
  modeling limitations prevent making reliable predictions  over
  larger distances, it would be difficult to  justify a greater
  separation.

            It should not be construed that two  power  plants  cannot
  be located closer than 30 miles.  The operating  conditions  ap-
  plicable to  the 30-mile guideline represent the worst case, which
  may occur no more than once per year.  The  PSD regulations  allow
  the increment to be exceeded once per year, which  in effect ignores
  violations caused by such rare meteorological  conditions.  Thus,
  the 30-miles separation is not strictly a practical  restriction
  needed to assure compliance with regulations.  Rather,  it reflects
  the absolute potential for plume interactions.
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           The  30-mile  separation is applicable to two 1,500 MWe
 stations.   To  calculate the distance between such a new unit and
 another unit of different size, this 30-mile distance was linearly
 proportioned to the ratio of the power output of the other unit
 and  the 1,500  MWe output of the new station.  In this manner,
 areas of significant potential plume interaction with a new
 1,500 MWe  plant were defined for those plants with known locations
 (Figure 4.4-1).  To the extent that future lignite utilization
 is located outside these areas around planned units, significant
 plume interaction and  cumulative air quality effects will not
 occur.

           Figure 4.4-1 indicates that a number of locations are
 available  outside these areas for additional 1,500 MWe mine-
mouth stations in the  lignite belt between Milam County, north-
east of Austin, and Van Zandt County, east of Dallas.  For example,
a station  larger than  1,500 MWe could be constructed in Bastrop
County in  the Camp Swift area without plume interaction to a
significant degree.   Also, several more mine-mouth stations
could be located in the northernmost areas, where the lignite
quality is highest.   And mine-mouth stations can be sited almost
anywhere along the southwestern part of the Wilcox trend or on
the Yegua-Jackson trend, except around the San Miguel station.
These available sites  are probably sufficient to accommodate the
unsited capacity planned through 1985.  If these plants can be
sited in the "available" zones and still lie close enough to the
end-use demand centers they are planned to serve, significant
cumulative air quality impacts may be avoided through 1985.

4.4.5.3   Lignite Development to 2000

          Beyond those units on line in 1985, between 7 and 21
more (1,500 MWe) stations are projected to satisfy estimated
electrical power demands in the year 2000  (see Section 2.4).
The SOa emissions from all lignite-fired sources are estimated
to range from 880,000  to 1,500,000 tons per year in the year
                              134

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        POTENTIAL LIGNITE DEPOSITS
        PRINCIPAL LIGNITE  DEPOSITS
        ZONE  OF POSSIBLE PLUME INTERACTION
                      FIGURE  4.4-1
.A  MONTICELLO  *1.2,3
•8  SAN MIGUEL »1,2
 C  SANDOW « 1.2,3.4
 D  GIBBONS CREEK »1,2
TJGNTTE-FIRED POWER PLANTS WITH KNOWN  SITES,  SHOWING
  ZONES OF POSSIBLE SIGNIFICANT PLUME  INTERACTION
                                                                      s
                                                                      SCALE IN MILES
                                                                   0  20    50       100
E FOREST GROVE *1
F BIG BROWN
Q SOUTH  HALLSVILLE
H TWIN OAK «1.2
I MARTIN  LAKE
          * 1.2.3.4.

            02-2082*1

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 2000  for  Che  low and hihg development cases, respectively.  This
 rise  in S02* emissions conceivably may cause a small increase in
 SO2 concentrations measured at urban centers of the lignite belt
 by 2000.  The associated particulate emissions would increase
 to between 95,000 and 150,000 tons per year for the two cases.
 Since this increase in particulate emissions is only one tenth
 that of S02, a large increase in particulate concentrations is
 not expected to occur in any of the urban areas of the lignite
 belt.

           The emission projections as a function of time are
 summarized in Table 4.4-6.

           As seen in Figure 4.4-1, about ten new mine-mouth
 lignite-fired stations may be the maximum number of new station
 sites within the lignite region without risking adverse plume
 interactions.   This condition is not of much concern to the
 lower bound of estimated lignite demand, requiring seven such
 stations.   But clearly, the 21 new station required to accommodate
 the upper bound may not be sited at the mine-mouth without incurring
 a substantial risk of adverse plume interaction unless S02 con-
 trol efficiencies or plant characteristics are greatly modified.
 Indeed, in some areas, the PSD regulation may effectively prevent
 lignite utilization at the mine mouth.  Fuel transportation costs
will increase if lignite is moved far away from its original
 location.   Also, output power penalties associated with increased
 302 control will be economically important.  These factors will
 provide impetus for continued mine-mouth siting, thus increasing
 the risk of some air quality deterioration over much of the
 lignite belt.   The ability of a particular power plant to meet
 PSD regulations at a particular site can only be adequately
 determined with site-specific, detailed air quality dispersion
 modeling.
                                136

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                            TABLE 4.4-6

   ANALYSIS OF S02 AND PARTICULATE EMISSIONS FROM LIGNITE-FIRED

            STEAM ELECTRIC  STATIONS	


                            19751      1985                 200
                                                     Low        High

Installed Lignite-Fired     2,660    "   12,614   "   21,400      42,800
Steam Electric Stations

S02 Emissions               0.19          .55     •   0.88         1.5
(Million Tons Per Year)

Particulate Emissions       0.022        0.051       0.095        0.15
(Million Tons Per Year)
^	^^^

1These 862 particulate emissions were  calculated using annual emissions
 of Big Brown Station and Sandow Station in 1973 Texas Air Control Board
 Emission Inventory.   The emissions  from Monticello Units //I and //2 were
 assumed to comply with federal New  Source Performance Standards and
 have lignite and plant operating  characteristics of prototypical plant.

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4. 5       Changes in Land Use

          Lignite development in Texas will affect land use at
several levels.  There will be direct changes due to the surface
mining, the subsequent reclamation, and the construction of large
power plants.  Also, there will be indirect effects accompanying
population growth.  The actual changes are site-specific, yet
some general statements can be made.

4.5.1     Direct Effects

          Surface mining of lignite will affect land which is
now mostly in agricultural use, timberland, or open range.
Compared to other agricultural land in Texas, its productivity
is low.   Once the mining operations have been completed, the
land will have been reclaimed in accordance with the require-
ments of the new Federal surface mining act.  Experience to date
suggests that these mined lands, properly fertilized and managed,
may actually be more productive agriculturally than before.

          Reclamation in Texas is primarily dependent upon climate,
topography,  soils and overburden, and geohydrology.  Radian has
performed an in-depth analysis (GA-R-242) of the variations in
reclamation potential throughout the Texas lignite belt.  This
study weighted each of these factors in a parametric model.  The
results of that analysis are shown in Figure 4.5-1.

          The Texas lignite belt was subdivided into eleven
regions based upon soil associations proposed by the Soil Con-
servation Service.  The reclamation potential of each region was
estimated.  Four major classifications were possible:

          Class I:  No limitations on reclamation.
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           Class II:  Slight limitations, little management
                      and control required.

           Class III: Moderate limitations, some management
                      and control required.

           Class IV:  Severe limitations, extensive management
                      and control practices required.   Problems
                      may not be solvable with available resources.

 Figure 4.5-1 shows that all the relatively large regions into
 which the lignite belt has been divided are either Class II or
 Class III.  The use of smaller regions would probably have re-
 vealed Class I and Class IV areas.  However, for the present
 effort, these eleven regions give a good idea of reclamation
 potential.

           Within each region in Figure  4.5-1, the limiting
 factor(s) are labeled.  Obviously, lack of water is a major
 factor.  However, much of the area where water is not a problem
 is Class  III.  Thus, reclamation is limited by a wide variety
 of factors .

           In general, Class II regions  are moderately suitable
 for reclamation in cultivated crops, pasture, and forestry.
 Class III areas will be more difficult  to vegetate and the cost
 will be higher.  Thus, reclamation for  productive land in most
 areas of  the Texas lignite belt is feasible, but it will be
 expensive and require thorough planning.

           Power plants will also require  land to be removed  from
 current uses.  However, these plants are  not constrained to  a
 particular geographical location.  In fact, some lignite-fired
 plants will probably be located at some distance from  the  lignite
                                140

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belt  (see Section 4.4).  Hence, the impact of siting on land
quality cannot be adequately addressed.  In general, however,
land  on either side of the lignite belt is more profitable
agriculturally than the lignite belt itself.  Therefore, power
plant sites off the lignite belt will remove better land from
production.  Furthermore, this type of land use change is more
likely to occur near the year 2000, when the value of agricultural
land will be higher because of the loss of prime agricultural
land to urban and industrial uses.

          The actual acreage lost varies from plant to plant.
However, even if 26 new plants are built at 2000 acres each
(including cooling pond), onl^ 5? 000 acres will be lost to cur-
rent use.   Spread out along the entire lignite belt, this does
not represent a great amount of land.

4.5.2     Indirect Effects

          As a result of the economic stimulation related to
lignite development, thousands of families will choose to settle
in nonmetropolitan areas.  Many of these people would probably
be tied economically to metropolitan areas if lignite development
does not increase.  It may be more efficient from a national
perspective to disperse population from metropolitan areas to
small towns in nonmetropolitan areas like the Texas lignite belt.

          As discussed in Section 4.1.5, the cost of services
in nonmetropolitan areas is less than in metropolitan areas.
In addition, there is probably a considerable amount of unfilled
capacity in many nonmetropolitan towns in Texas, where out-
migration has prevailed for decades.  Nonmetropolitan development
may relieve some of the pressures which exist in metropolitan
areas, particularly the suburban sprawl type of land use develop-
ment.
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           In conclusion,  the conversion of agricultural  land  or
 open space near the lignite belt to urban land use (residential,
 commercial, etc.) may be  in the national interest.  At  the local
 level,  it may appear to be an adverse consequence; however, from
 a broader perspective, it will help to save land around cities
 that are already too large geographically.  The environmental
 costs of urban sprawl (RE-118) are great, and nonmetropolitan
 development in Texas, based upon lignite, may help reduce those
 costs.

 4. 6       Cumulative Biological Impacts

 4.6.1     Impacts on Terrestrial Communities

           The terrestrial impacts caused by lignite development  in
 Texas can best be characterized by discussing the types and
 amounts of wildlife habitat affected.  Previous sections have
 hypothetically forecast both upper and lower boundary conditions
 for lignite mining, electric power generation, and secondary
 urban development brought on by lignite development.  These
 scenarios are projected for the years 1985 and 2000.  Assuming
 each lignite mine supplies fuel for a 1500 MWe steam electric
 generating plant which operates at 60 percent capacity, about
 15,000 tons of lignite per day would be consumed.  At 12,500
 tons per acre this would mean about 1.2 acres per day or 438
 acres per year would be mined for each such generating facility.
 This corresponds roughly to 7,100 Btu/lb  lignite with an average
 seam thickness of 6 feet.  Texas lignite  varies typically from
 5,500 to 7,500 Btu/pound and from 2 to 20 feet aggregate thick-
 ness.

           By the year 1985 only those mines  and generating stations
 presently planned could be operational.   This means a maximum of
 9 mine/power plants distributed as shown  in Figure 5.. 1-1.  An
 additional 2000 acres will be used for the power  plant, cooling
 pond, haul roads, coal handling facilities, etc.  By 1985 these

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nine facilities will have used about 18,000 acres for facilities
and could be mining 3,942 acres annually.  Within their 30 year-
life spans they could affect a total of about 136,260 acres.

          By the year 2000, the forecast's upper bound, with all
new power generation using lignite, calls for 30 lignite mines
with associated power plants, or an increase of 21 over the
1985 conditions.  This could mean a maximum of 60.000 acres used
for facilities at an annual mining rate of 13.140 acres.  Within
their 30-year life span these 30 mine/power plants could affect
a total of 454.200 acres of land.   The lower bound, with half
of all new power generation using lignite, calls for a total of
16 mine/power plants by 2000.   These would use 32,000 acres for
facilities, mine 7,000 acres annually and could affect 242,200
acres in their 30-year life span.

          From these calculations it can be deduced that the
Texas lignite belt can look forward to the mining of about 3,940
acres per year by 1985 and between 7,000 and 13,000 acres per
year by 2000.  Also, within the 30-year planned lifetimes of
the mine/power plants, between 242,000 and 454,000 acres of
land could be affected.   Since the majority of the power demand,
available surface water, and best lignite deposits are all
located in the eastern portions of the lignite region, it has
been projected in previous sections that most of the development
will occur generally northeast of the Colorado River.

          Accompanying the direct effects of lignite development
will be indirect effects caused by the creation of a maximum of
97,000 new jobs and significant numbers of new people moving
into the lignite area.  Since people may commute 50 miles or more
to work in the semi-rural areas, the distribution of these new
families and, therefore, the location of the land used by their
houses,  etc., is difficult to predict.  As noted in previous
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RADIAN
 sections,  most of the increased population  is  expected to settle
 in the existing small communities  throughout the  lignite belt.
 thereby causing little disturbance to  the more remote wildlife
 habitats.

           The direct effects of the lignite mine/power plant units
 on the terrestrial wildlife habitats and resources  of the lignite
 region will be minimal when viewed on  an individual basis.  Each
 individual mine plus 1500 MWe power plant will use  about 2000 acres
 of land (possibly  wildlife habitat) during its 30-year life
 span for facilities.  Since mining will be  linear in nature, no
 more than about 1,500 acres should be  disturbed at  any one  time.
 This will include land cleared of vegetation prior  to mining,
 the mine area, and land in the first stages of reclamation  prior
 to the establishement of vegetative cover.   For this reason the
 actual long-term impacts on the wildlife habitat  depend totally
 upon the type of reclamation planned and the speed  at which it
 is effected.   Wildlife habitat is currently fragmented over much
 of the eastern portion of the lignite  region,  as  a  result of 100
 years of farming and ranching.  It is  therefore possible to
 reclaim mined land so that its wildlife carrying capacity will
 be greater than under current conditions.   The wildlife value
 of average native pastures and improved Bermuda grass pastures
 is quite low due to the lack of food and shelter that are usable
 by wildlife.   Few species can live in  a monoculture of Bermuda,
 especially if it is cut or grazed prior to  setting  seeds.
 Bermuda is a good cattle food but a very poor  food  for wildlife.
 By replacing the unpalatable species in the average pasture and
 the Bermuda grass in the improved pastures  with native grasses,
 the wildlife habitat value can be enhanced  considerably.  Many
 species of rodents and seed-eating birds, including the mourning
 dove and bobwhite quail, will live in  the native grasses.   And,
 if brush edges and woodlands are replaced,  while-tailed deer
 will also inhabit the area.   The mining of  large areas of mature
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forests would destroy more valuable wildlife habitat for a longer
period of time than the mining of the same amount of heavily
grazed pasture land.  Assuming, however, that only a minor por-
tion of each mine site contains relatively mature forests (this
is a valid assumption for most of the Texas lignite region), the
cumulative direct impacts of lignite mining and the accompanying
electric power generation would be equal to the sum of the in-
dividual impacts unless some interaction between mines occurred.
The Pineywoods, Post Oak Savannah, and South Texas Plains vegeta-
tion/wildlife habitat regions, under which the lignite is found,
occupy approximatley 15 million acres, 8.5 million acres, and 20
million acres, respectively.  The upper bound of the lignite fore-
cast could affect only about one percent of the total available
habitat over its entire 30-year life span.  Even is this figure
is nearly doubled by assuming that most of the lignite develop-
ment will occur in the 23.5 million acres of the Pineywoods and
Post Oak Savannah regions east of the Colorado River, it is still
a very small percentage.   In actuality, at the upper bound of 30
mine/power plants, only 13,100 acres or 0.056 percent of the
Pineywoods and Post Oak Savannah habitats would be mined annually
by the year 2000.  Using 1,500 acres per mine as the amount of
land cleared at any one time (exclusive of facilities), a total
of 45,000 acres or 0.19 percent of these habitat regions would
be cleared at any point in time.  By simple deduction it can be
seen that even the maximum of 30 mine/power plants could have
little short-term and even less long-term (after reclamation)
effect on the overall terrestrial wildlife habitat and associated
wildlife resources of the Texas lignite region.

          No doubt lignite mining will have some ecological
effects since any further destruction of the already fragmented
wildlife habitats will be detrimental to the existing wildlife
populations.  It is simply doubtful that the direct and indirect
effects of lignite mining and its accompanying development will
cause significant or even measurable changes in the overall
terrestrial wildlife populations of the region.
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           The sensitive areas discussed in Chapter  Three  should
 not be greatly affected.  Most of the sensitive areas  could be
 designated under the Federal Surface Control and Reclamation Act
 of 1977 as unminable.   The areas of riparian woodlands could be
 affected but this will depend upon the location and mining plan
 for each specific mine.

 4.6.2     Impacts on Aquatic Communities

           The aquatic impacts of future lignite development  in
 Texas can be categorized as either water-quality or water-
 quantity related.  These two broad categories sometimes interact
 to cause impacts such as concentration of water-borne  material
 due to evaporation and low flow conditions during droughts.
 Changes in the aquatic biota associated with water-quality  and
 water-quantity changes derived from lignite development are
 difficult to quantify except on the most gross scale.   Previous
 sections of this chapter have generally discussed the  water
 quality and quantity changes expected throughout the Texas  lignite
 region.

           It is beyond the scope of this study to discuss in
 detail all possible site-specific changes in the aquatic biota
 directly and indirectly associated with lignite mining and  power
 generation.  However,  it must be noted that some of the possible
 adverse impacts on the aquatic biota will result from  site-
 specific changes that may not be significant on a regional  level.
 As discussed in previous sections, water quality changes from
 construction, mining,  and increased urban runoff, thermal loading,
 and stack emissions interacting with the surface water, may  cause
 possible minor site-specific changes in the aquatic plant and
 animal populations.  The exact nature and extent of these must
 be analyzed on an individual basis.
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          Cumulatively, the combination of future industrial
and domestic demand, which together may consume a maximum of
about 43,000 acre-feet of water per year, should not significantly
alter the existing water quality of the rivers of Texas.  The
total maximum projected water usage for lignite development will
be only about 1.6 percent of the cumulative average flow of
the rivers possibly affected.   This loss of about 1.6 percent
of the average total flow will not measurably affect the aquatic
biota during average conditions.

          The above comparison does not give an accurate picture
of the possible effects on each river basin.  The individual
basins will vary greatly in the percentage of average flow used
by lignite development by the year 2000.  However, it is impro-
bable that water use associated with lignite development would be
concentrated in one or two river basins.  The effects of lignite-
related water usage on the biota of individual basins is beyond
the scope of this study; rather,  the cumulative effects on the
entire region are discussed in general terms.

          During years of normal river flow, there should be no
significant changes in the overall freshwater aquatic biota
caused by depletion of the flows due to lignite development.
This conclusion is based on the small percentage of the average
flow predicted to be used by lignite development when compared
with the recorded low flows of the various rivers.  Lignite
development will not cause drought condition low flows.  It will,
however, increase the frequency of low flows, as will any con-
sumptive use or natural drought.   During droughts, such as those
experienced in the early 1950's,  the aquatic biota suffer.
However, they survive in various reservoirs, natural springs,
and other areas from which the total basin of each river is re-
populated .   It is unlikely that lignite-related development per
se will cause reductions in water quantity that will destroy
significant populations of aquatic biota in the major rivers.
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 In some of the river basins,  lignite-related water use when  added
 to other water usage may create stressful situations  much more
 often than would occur otherwise.   These synergistic  effects
 may need further clarification in order to ascertain  the possible
 effects of the total water usage in individual river  systems.

           The effects of lignite mining and runoff from  indirect
 development on the aquatic biota of the many small perennial
 streams that will be disturbed are difficult to predict.  As is
 stated in previous sections on water quality, siltation  and
 lowered dissolved oxygen levels in the streams may occur in  some
 areas until adequate control measures can be instigated.  If
 all local, state, and federal regulations are followed,  there
 should be little long-term degradation of the small streams  in
 the lignite region.  The streams directly affected by mining
 will repopulate following reclamation.  They should repopulate
 to conditions somewhat similar to those before mining unless
 the streams are channelized.   Since the biota of these streams
 have generally little significance in the region's overall
 aquatic ecosystem, changes are unlikely to be regionally signifi-
 cant.  These streams are important to wildlife that depend upon
 them for water and for aquatic food organisms; however,  lignite
 development is not expected to obliterate them permanently.
 Lignite development will destroy sections of streams for the
 duration of mining and then replace them during reclamation.
 This should be sufficient to insure their continued use  by
 wildlife as it repopulates the reclaimed mine areas and  areas
 downstream of the affected stream segments.

           The problem of decreased freshwater inflows to Texas'
 highly productive estuaries may be slightly aggravated by
 lignite-related water usage.   The amount and timing of fresh-
 water inflows are thought to be of prime importance to various
 important estuarine animal species.  These inflows are currently
 controlled by the dams on most Texas rivers, except during
 floods.  The relatively small amount of water predicted  to be

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consumed by lignite development should not decrease the fresh-
water inflows to the estuaries enough to significantly affect
the animal populations.  If necessary, water consumption can be
compensated by managing dam releases so that the estuaries
receive the same amounts of water at the proper time.

          The actual significance of the amount of fresh water
that flows into the estuaries and its timing with regard to
its effects on the estuarine biota is presently unclear.  Several
studies of the inflow needs of Texas estuaries are either cur-
rently being conducted or will begin shortly under the auspices
of the U.S. Fish and Wildlife Service.  Past studies of Texas
bays and estuaries have failed to find the answers to the ques-
tions surrounding the freshwater inflow requirements of estuarine
organisms.   These current and future studies should be able to
ascertain the freshwater inflow needs of the estuarine organisms.
They should also provide water management recommendations for
the protection of the estuarine biota.  They will undoubtedly
provide further insight into the possible long-term effects of
lignite related water usage.

          The cumulative effects of thermal loading from lignite-
fired power generating facilities is another possible area of
regulatory concern.  The changes in aquatic systems due to
heated effluents have been studied extensively in Texas for
decades.  Under present regulations and practices, thermal dis-
charges to freshwater bodies have not been shown to have a
significantly adverse effect on the aquatic biota of their
receiving waters.  Of course there are changes; however, they
do not damage the biota of the receiving waters.  In most cases
the heated water accelerates growth in sport fish.  It also tends
to prevent or at least postpone the decline in sport fish popula-
tons usually experienced in Texas lakes after eight to ten
years.  The exact reasons for this are presently being studied
in several Central and East Texas reservoirs.
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           During the hottest period of the year (July - August),
 fish migrate to cooler portions of cooling lakes or ponds.   In
 this way they escape adverse effects from heated effluents  often
 in excess of 40°C.  Most fish in cooling ponds have very broad
 tolerances to temperature fluctuations.   This decreases the
 chances of their being adversely affected.  During the winter
 the fish migrate to the warm discharge area.  Fishing is usually
 excellent in the heated effluent at this time.  Only in cooling
 ponds or lakes where there are no areas to which the fish can
 escape the extremely hot water will adverse impacts be seen.
 For those reasons, thermal effluents have not been a serious
 threat to the freshwater aquatic biota of Texas.
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         CHAPTER FIVE
  MAJOR ISSUES AND PROBLEMS
SURROUNDING LIGNITE DEVELOPMENT
              151

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RADIAN
 5.0       MAJOR ISSUES AND PROBLEMS SURROUNDING LIGNITE
           DEVELOPMENT

           The following discussion attempts to define the main
 areas of controversy surrounding the development of lignite.
 Some uncertainty has arisen lately in the literature over the
 distinction between "problems" and "issues."  In this study,
 "problems" are considered to be the potential adverse impacts
 discussed in Chapter 4.  "Issues" arise over the choice of solu-
 tions to these problems.  This chapter considers ways that pres-
 ent policy patterns create problem-solving difficulties, which
 have not yet been resolved.  In many instances, conflicts be-
 tween national and regional goals create the difficulty.  In
 others there are impediments to changing old policies or imple-
 menting new ones.  All of the issues that have been raised to
 date are not discussed here.  Only issues with a large potential
 influence on the environment or those involving major federal
 policies have been included.

           The issues themselves have been placed in two groups.
 The first group contains issues affecting the scale, location,
 and timing of lignite development.  Some of these do not arise
 directly from environmental considerations, but are included be-
 cause they affect the overall pattern of development.  It is
 this pattern which ultimately determines what the cumulative en-
 vironmental impact will be.  The second group of issues centers
 on problems of mitigating or avoiding those impacts that occur.
 These issues largely center on the adequacy of existing institu-
 tional machinery to handle the expected problems.
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5.1       Issues Affecting the Scale, Location, and Timing of
          Lignite Development

5.1.1     Water Availability

          As was shown in Chapter 4, there is insufficient un-
appropriated water available in Texas to accommodate lignite
development in the southern and central portions of the lignite
belt.  This condition will tend to promote lignite development
in East Texas.  Lignite is also of higher quality in this area
and the climate is most favorable to reclamation.  Since gen-
erally the available "new" water rights are inferior to many
prior rights, power plants, gn ~ 5 f-' cation facilities, and mines
outside East Texas will probably obtain their water needs by
purchase on contract from large reservoirs.   Even contract wa-
ter, however, is in short supply, particularly in the Colorado
and Trinity River basins.  Consequently, lignite interests will
have to purchase other existing water rights.1  Agriculture,
which presently uses an estimated 7270 of the water consumed in
Texas (TE -310) is probably the most readily available source
of water rights through purchase.  Rising costs of contract irri-
gation water (presently between $20 and $30 per acre-foot) will
contribute to the shift of contract water from agricultural to
industrial use, as farmers find themselves unable to compete for
the resource.

          Like many western states, Texas operates on a prior
appropriation water right system, appropriating water for bene-
ficial use on a first-in-time, first-in-right basis.  There is
presently no updated summary of active appropriations.  The
Water Rights Commission is undertaking a massive adjudication
program.  This process may "find" substantial amounts of unused
Utilities have the right to condemn water, but the extent of
 this authority has never been tested (UN-085).
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 water, but will probably not be complete for many years.  In
 addition, the water rights system in Texas has essentially pro-
 moted inefficient water use.  The owner of a water right must
 have actually used the water at some time, but may not always
 continue to use all of the appropriation.  Thus, there may be
 additional supplies of water that are not being used.  At least
 a partial solution to the potential water shortage and its im-
 pact on agriculture could be found if this "found" water could
 be allocated according to a priority system designed to further
 a balanced statewide economy.

           The basis for such a priority system exists, in the
 Wagstaff Act of 1931 (U.C.T.A., Water Law, Section 5.024), which
 sets up a system of dealing with competing demands for the same
 water.  However, these priorities1 are currently applied only
 at first certification of water rights, and then only if there
 is competition.  All appropriations are made on a case-by-case
 basis.  No mechanism exists for continuing evaluation of water
 uses, or for allocating water saved by conservation according to
 a pre-arranged plan.

           State legislation would be required to enforce conser-
 vation and to establish a priority system of allocation.  Sub-
 stantial opposition would be encountered to such an effort; wa-
 ter is regarded as a property right in Texas, and users presently
 acquire title to their appropriation by limitation after three
 years of use (V.T.C.A., Water Code, Section 5.029).

           Another potential means of "finding" more water in
 Texas might be through coordinated management of surface and
  Priorities in appropriation, in decreasing order, are:  domes-
  tic and municipal use, including livestock watering; industrial
  use, including non-hydroelectric power; irrigation; mining;
  hydroelectric power; navigation; recreation and pleasure;
  other uses.
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ground waters, an approach long advocated by the Water Develop-
ment Board  (TE-310).1  As water development increases and its
hydrological impacts become more complex, more and more time is
required for planning.  It is therefore important to begin such
a process quickly.  However, revisions in state law would be
necessary to establish authority for coordinated surface/subsur-
face management.  It is considered doubtful if such legislation
could pass.  According to both popular attitudes and current
legal stance, water in Texas is considered a common-law property
right.  The farmers and ranchers of central and southern Texas
are presently using ground water rapidly enough to deplete long-
term aquifer storage capacity.   This influential group will
oppose initiatives that would cut back their supply.

          Based on existing state water policy alone, the outlook
for systematic, basinwide planning, conservation, and allocation
of water supply appears unpromising.  Countervailing doctrines
are firmly entrenched in state water law and reinforced by prac-
tice.  Current federal efforts to establish an updated, uniform
water policy could conceivably break the impasse by mandating
state legislative reform.  A thorough analysis of the implica-
tions for Texas of the policy options developed by the Water
Resources Council (Federal Register, July 15, 1977, Part VI) is
both premature and outside the scope of this study.  However,
it is clear that their emphasis on modern, hydrologically sound
planning could clear the way at the state level for substantial
improvements in water rights management.  Such policy recommen-
dations, however, will have to overcome strong objections from
the states.  On the other hand, several of the Water Resources
Council policy options could conceivably make matters worse,
 1The three Texas water agencies - Water Rights Commission, Wa-
 ter Development Board, and Water Quality Board  - have been
 merged as of September 1, 1977-  However, their functions will
 remain largely distinct, and no major policy changes accompany
 the merger.
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  depending  on  their  implementation.  Particularly, any attempt to
  condemn water rights  and  reallocate them will need to be coor-
  dinated with  a conservation  program.   Otherwise,  substantial
  economic damage could be  done  in water-short areas by "borrow-
  ing  from Peter to pay Paul."  Water pricing as  a  means to pro-
  mote conservation will almost  certainly contribute to the move-
  ment of water from  agriculture to  industry.

  5.1.2     Consumptive Water  Use

            The ultimate impact  of  the  growth in  water demand  for
  lignite-fired power production will be expressed  as cumulative
  reductions in flow.   As explained  in  Chapter 4, a much more  so-
  phisticated analysis  than was  possible in  this  study would be
  needed to  determine what, in Texas' highly variable, highly
  regulated  river systems ,  this  ultimate reduction  might be.   A
  preliminary analysis  suggests  that depletion sufficient  to ad-
  versely affect freshwater inflow  to Texas' productive bays and
  estuaries  is  not likely to occur  as a result of lignite  develop-
  ment alone.  Lignite will contribute, however,  to a substantial
  total growth  in water demand which can have  local effects on the
  instream flows required to sustain aquatic ecosystems.

            The Texas Water Rights  Commission  advised by  the Water
  Development Board and the Texas Department of Parks and  Wildlife
  can  protect instream flows through its permitting system.  How-
  ever, as is the case with most aspects of  water regulation in
  Texas, everything is  done on a case-by-case basis.   There is
  no basis for  coordinated planning. More  significantly,  it appears
  that much  of  the local impact  on  surface water  flow and  quality
  can  theoretically be controlled by operating existing on-stream
  'Note that the priorities in the old Wagstaff Act include no ex-
   plicit reference to instream flow needs.   Included under "other
   beneficial uses," they rank eighth and last.
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reservoirs.  However, reservoir operation is set by state water
rights which restricts alternatives considerably (TE-310).  Some
sort of reservation for instream flow protection might be requir-
ed.  Considerable study would be necessary before a technically
effective plan could be devised and a strategy proposed for over-
coming legal and institutional constraints.

          Another mode of combatting depletion is to reduce con-
sumptive use.  A major component of the consumptive use of water
arising from lignite-fired power generation derives from cooling.
Most utilities either use off-stream impoundments for evaporative
cooling or build wet cooling towers.  As discussed in Chapter 4,
cooling towers are preferable unlj  in the extreme southern part
of the lignite belt, where evaporation rates are high.  Lakes
and ponds are equivalent or superior to towers in the more humid
central and east parts of the State.

          Because of evaporative losses, towers and ponds may
consume 30 to 100 percent more water than cooling lakes,  depend-
ing on locality.  The staff of the Water Development Board,
charged with conserving the state's resource, considers that
"from an overall water resources management standpoint -- single-
purpose cooling reservoirs should be used only when absolutely
necessary."  Multi-purpose reservoirs would be the method of
choice (HO-389).  From the standpoint of state water management,
cooling towers are the least acceptable mode of using surface
water.

          Substantial impediments to such a strategy exist, how-
ever.  The 316a variance procedure required by the Water Pollu-
tion Control Act Amendments of 1972, (PL 92-500), along with
various practical drawbacks, make reservoir use unattractive.
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           In 1976, the existing EPA guidelines regarding the
 316a variance  were overturned in the Fourth Circuit Court of
 Appeals, on grounds that they did not adequately consider water
 supply.  Draft guidelines are now out, but have not been adopted.
 In the interim, EPA Region VI has received only one application
 for a variance in Texas, and has no firm policy regarding the
 kinds of data required.  The 316a process requires proof that
 the proposed thermal discharge will not cause ecological damage.
 Generally speaking, it is time-consuming and difficult.   The un-
 certainties surrounding its future implementation also act as
 very strong incentives to avoid locations possibly requiring a
 variance.  Multi-purpose reservoirs fall into this category.  In
 addition, the practical difficulties of siting on premium lake-
 shore land, as well as reconciling such locations with demand
 patterns and fuel sources, may be even more important drawbacks.

           Cooling ponds, on the other hand, require no 316a var-
 iance, by statutory definition.  A cooling pond, as opposed to
 a cooling lake, is exempt from 316a, but the distinction is not
 always clear.  An impoundment on a navigable stream which dis-
 charges downstream is clearly a lake according to the law.  And
 an impoundment on a non-navigable portion of a drainage, with no
 discharge, is clearly a pond.  However, intermediate cases abound
 where intermittent streams are involved.  These are addressed in
 a more or less discretionary fashion, according to informal guide-
 lines and policies within the regional EPA office.

           In summary, there is^ substantial incentive for utilities
 to build smaller  headwater cooling ponds or cooling towers, even
 though these technologies are the most detrimental to State and
 Federal water conservation objectives.  The 316a variance proced-
 ure, while a contributing factor , is probably less significant
 than economic considerations in favoring the use of single-purpose
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 cooling reservoirs.  Without 316a,  however,  more cooling lakes,
 with evaporative losses as much as  207o below cooling ponds,
 might be built.

 5.1.3     Water Use Conflicts

           A variety of other conflicts have  arisen over the  de-
 velopment of water for lignite.   These are not issues of such
 statewide significance as those surrounding  appropriations or
 coordinated planning.   However,  they do constitute a potential
 for delay in the overall development picture.

           One such conflict involves the replacement of habitat
 lost by reservoir development with  other lands managed for wild-
 life.  The U.S. Fish and Wildlife Service requires such "mitiga-
 tion"1  before approving dredging permits under Section 404 of the
 Water Pollution Control Act Amendments of 1972.  This policy has
 sparked a controversy in regard to the proposed Choke Canyon Reser-
 voir which has been sent to the Secretary of the Interior for
 resolution.  If the Secretary rules that mitigation should be
 part of this project,  a precedent will be set for other water
 developments.  The major disagreement revolves around the issue
 of who should bear the cost of acquiring and managing the miti-
 gation lands.

           A different kind of conflict has arisen over two pro-
 posed reservoirs underlain by substantial lignite reserves.   One
 of these (Tennessee Colony) can be  relocated, although some lig-
 nite would still be affected.  There is also some concern over
 phasing reservoir construction with planned mining.  In the case
 of the other (Millican) , the Corps  has recommended against con-
 Authority for this policy comes from Section 662 of the Fish
  and Wildlife Coordination Act (P.L. 85-624).
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   IPORATION
  struction,  perhaps  in part because  of  an overall move away from
  the  construction of new reservoirs  (Water Development Board staff,
  pers.  comm.).   Other projects  that  have been  authorized, but not
  yet  budgeted, include a  navigation canal permitting barge traffic
  up the Trinity River to Dallas,  and another reservoir on the
  Navasota River.   Locally,  lignite mining would  interfere with
  these  plans.   It is worth  noting, however, that the provisions
  of the new Federal  Surface Mining Act, PL 95-87 have added to
  the  uncertainty of  mining  in the bed of the Trinity and other
  rivers,  which might be  considered an area unsuitable for mining
  because of the threat of flood.

  5.1.4      Air Quality Maintenance

            The recent passage of  the Clean Air Act Amendments of
  1977 has greatly changed the regulatorv climate in Texas.  The
  policies set  in that law have largely  pre-empted certain deci-
  sions  previously made at the state  level, and much of the pre-
  vious  case-by-case  flexibility will be lost  in  consequence.  The
  net  result of the new Federal policies appears  likely to increase
  the  use of lignite  greatly,  accompanied by a  much more  scattered
  pattern of lignite-related industrial  development than would
  otherwise have taken place.   These  consequences arise primarily
  from changes  in three areas:  New Source Standards of Perfor-
  mance  (Section 109). Prevention  of  Significant  Deterioration
  (Section 127), and  Nonattainment Areas (Section 129)-

  5.1.4.1   New Source Standards of Performance

            The greatest  impact of the new Act  on the Texas lignite
  industry will probably  arise from its  requirement that  all new
  coal or lignite-burning sources  use "best available control
  technology" to reduce emissions. Low-sulfur  Western coal could
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meet previous NSPS without scrubbers, while lignite could not.
Removal of this significant economic advantage makes the cheaper.
local lignite much more attractive relative to imported coal.
BACT now applies to S02 and particulates, but new standards for
NO , hydrocarbons, and carbon monoxide are required under the
Act.  Further study will be needed to determine what differences
these new standards may make in the economics of using lignite
versus Western coal.  As long as both fuels require essentially
similar control hardware or modes of boiler operation, however,
the initial advantage afforded to lignite by the universal re-
quirement for BACT will probably continue.  The Act also affords
the opportunity to regulate other pollutants, such as arsenic
and radionuclides, although it does not specifically require
such regulations.   A study of the relative concentration of such
substances in Texas lignite and other coals, along with the
availability and cost of technologies to control them, might
reveal more significant differences.  If future emission stand-
ards change the relative economics of lignite versus imported
coal, the net environmental impact of lignite development will
be directly affected.

5.1.4.2   Prevention of Significant Deterioration

          One of the major conclusions of the analysis in Section
4.4 is that a potential conflict exists between PSD regulations
and large-scale lignite development.  The development forecast
set out in Chapter 2 stated that as many as thirty (30) 1500 MWe
lignite-fired power plants may be needed by 2000.  The potential
for conflict becomes obvious when an attempt is made to locate
new power plants near the lignite deposits.
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           For analysis, it will be assumed that new facilities
 cannot be closer than 30 miles to another lignite-fired power
 station.  Under the worst atmospheric conditions, no significant
 plume interaction is expected between two worst-case, 1500 MWe
 plants separated by 30 miles or more.  In reality, 1500 MWe plants
 can be constructed much closer without the violation of the PSD
 standard.

           Figure 5.1-1 shows graphically an attempt to locate
 plants as near the lignite deposits as possible without signi-
 ficant plume interaction.  Lettered sites are existing or planned
 lignite-fired plants; the numbered sites are the hypothetical
 locations.  In the southwestern pjrtion of the belt, sites 1 and
 2 appear to present no problems with respect to plume interac-
 tion.  However, due to reclamation costs, scarcity of water, poor
 quality of lignite, and relatively low demand for electricity
 in nearby urban centers, the development of more than two addi-
 tional 1500 MWe plants appears unlikely.

           Continuing to the north, site 3 presents no problems.
 However, that lignite deposit is "potential," and the site can-
 not be depended upon to be economically attractive.  Site 4
 is in the Camp Swift area of Bastrop County.  With the Austin
 and San Antonio markets nearby, it appears to be a good site.
 Site 5 will not present problems with plume interactions and it
 will probably be developed eventually.

           Sites 6 and 7 in northeast Texas are both located off
 the lignite belt a few miles to maximize development in that
 area (near Dallas).  Site 8 will not present plume interaction
 problems.  Sites 9 and 10 represent an attempt to locate as
 many plants as possible in that area without plume interaction.
 However, both are located on "potential" deposits and cannot
 be counted on with a high degree of confidence.
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                                                                                     SCALE IN MILES
                                                                                 0   20    50       100
                    POTENTIAL  LIGNITE  DEPOSITS
                    PRINCIPAL LIGNITE DEPOSITS
                    ZONE  OF POSSIBLE  PLUME INTERACTION
                                  FIGURE 5.1-1
E rOREST  GROVE »1
F BIG BROWN
A MONTICELLO  « 1.2.3
B SAN MIGUEL '1.2
C SANDOW • 1.2.3.4     Q  SOUTH HALLSVILLE
D GIBBONS CREEK »1.2  H  TWIN OAK  * 1.2
                        HYPOTHETICAL DISTRIBUTION  OF   1 TO 1O ARE  HYPOTHETICAL
EXTSTTNO-  P-LANMEP.  AND  FUTURE LT CNITE - FT REO LTMITS AT THE  MINE-MOUTH
I  MARTIN  LAKF
          I 1.2.3.4.

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CORPORATION
           In this simple allocation exercise, only ten plants
 were located.  More could probably be fit in along the lignite
 belt with more accurate mapping.  However, some of the locations
 are not in the best areas for energy development when reclama-
 tion and demand are considered.

           Obviously, more plants can be practically located near
 the lignite deposits by either utilizing technology changes dis-
 cussed earlier or by increasing the degree of cumulative air
 quality impacts.  Another way to allocate more plants is to
 assume that the lignite will not have to be utilized at the
 mines.  Thirty miles is as far as lignite can be economically
 moved under current conditions.  However, this may change as
 energy becomes more scarce.

           If transportation becomes less of a constraint, plants
 will probably be constructed away from the lignite belt in areas
 where no significant plume interaction can be expected.  This
 may also place the power plants nearer the major consuming areas
 in southeast Texas (Houston to Beaumont) and along a line from
 Sherman to San Antonio.  However, they may eventually cause
 problems  with air quality in these metropolitan areas.

           In summary, the concerns raised and resolutions considered
 in this allocation exercise are not a forecast of certainties.
 However, these potential problems and conflicts do indicate that
 cumulative air quality inpacts accompanying intensive lignite
 utilization cannot be dismissed as improbable.  Any policy changes
 which affect the context in which such problems are generated or
 conflicts resolved may have a direct bearing on the likelihood
 of air quality degradation.  The changes in the PSD standard
 of the 1977 Amendments is an excellent example of such a policy
 initiative.
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          Eventually, it may be considered desirable to redesig-
nate parts of the lignite belt Class III, thus increasing the
number of plants which can be sited economically.  Some delay
between the need and the actual redesignation may be expected
because of the complexities of the process.  A study of the
effect of redesignating various parts of the lignite belt, in
different time frames, could provide valuable information for
planning.

          The option also exists to redesignate certain areas
Class I, which could further complicate the siting problem.
Areas near the lignite belt for which a Class I designation
might be appropriate include.

          The Big Thicket
          The several National Wildlife Refuges along
          the Gulf Coast
          The Upper Guadalupe  River, proposed for in-
          clusion in the National Wild and Scenic River System

Additional study of the impacts such redesignations might have
on siting in the adjacent Class II areas would also be a useful
planning input.   The new Amendments require the administrator of
all Federally managed lands to inventory them and make recommen-
dations concerning redesignation to Congress, after consultation
with the state.   A necessary part of this analysis will be an ex-
amination of its impacts on siting.

5.1.4.3   New Sources in Nonattainment Areas

          Virtually the entire industrialized portion of the
Texas Gulf Coast is designated as a nonattainment area for TSP
and photochemical oxidants, but not for S02.  Consequently, the
very strict provisions for siting new sources contained in the
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 Amendments will not prove very restrictive for new combustion
 sources.  However, lignite gasifiers, and the industries using
 synthesis gas as feed, contribute to hydrocarbon and hence to
 oxidant  levels through emissions and fugitive losses.  Such
 facilities can only be sited  in these nonattainment areas  (NAA's)
 if a  sufficient reduction in  hydrocarbon and oxidant emissions
 occurs through other measures to compensate for the new sources
 contributions.  The net  result must be  "reasonable further pro-
 gress" toward meeting the deadline for  compliance,1 as deter-
 mined by the Administrator of EPA.

           In the Gulf Coast NAA's, excessive oxidant and CO levels
 arise from two principal sources:  petroleum and petrochemical in-
 dustries and vehicular emissions.  Thus, one way to preserve the
 option to site new sources there is to  institute controls  on
 traffic  and emissions from vehicles.  To the extent that "reason-
 able  further progress" cannot be made in this way, emission re-
 ductions offsetting those of  proposed new sources will have to
 come  from industry.  Fugitive losses -  a large part of industrial
 hydrocarbon emissions contributing to oxidant formation -  are
 very  costly and difficult to  control.   Thus it seems possible
 that  some new sources would be located  outside the coastal NAA's,
 in the inland Class II regions.

           The trend toward shifting from methane-based feedstocks
 to synthesis gas may enhance  the likelihood of at  least some sec-
 ondary industry locating near gasification plants built in the
 lignite  belt.  Further study  of industry economics would be
  *The  latest  date  for  attaining  NAAQS  for photochemical  oxidants,
  according to  the new law,  is December  1987.   Commercial  gasi-^
  fication plants  in Texas may begin operating by the mid  eighties
  (See Section  5.1.5).
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necessary to support more than a speculation.  However, there is
substantial current interest in lignite gasification for feed-
stock use.  If a corresponding shift takes place in process de-
sign to use the gasified lignite, new plants may be needed which
would be difficult to site in the NAA's.  These might be economi-
cally built, in some cases, near the feedstock source.  If such
a trend were to materialize, it could exacerbate the problem of
complying with PSD on siting power plants in the lignite belt.
It would also bring with it economic and social impacts, and
contribute to regional water quality and quantity problems.  Be-
cause of this potential, a more rigorous investigation is strong-
ly suggested.

5.1.4.4   Federal/State Conflicts

          The Texas Air Control Board is empowered by law to
adopt and enforce its own regulations,  including new source per-
formance standards.  New sources must obtain a construction per-
mit from TACB,  before construction can begin.  Permit criteria
include prevention of significant deterioration, maintaining
Federal and state standards, and land use considerations.  (Texas
Air Control Board Regulation VI.)  However,  the Board is permitted
a good deal of flexibility in applying its rules and regulations.

          The Texas Clean Air Act of 1967 (Tex. Rev. Civ. Stat.
Ann. art.4477-5 § 3.10(a), 1967) states that:

          a rule or regulation or any amendment thereof
          adopted by the TACB may differ in its terms
          and provisions as between particular conditions,
          as between particular sources and as between
          particular areas of the state.  In adopting
          rules and regulations the Board shall give
          due recognition to the fact that the quantity
          or characteristics of air contaminants or the
          duration of their presence in the atmosphere
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            which may cause  a need for air control  in  one
            area of the state may not  cause need for air
            control in another area of the state, and  the
            Board shall take into consideration  in  this
            connection all factors found by it to be proper
            and just,  including topography and prevailing
            wind directions  and velocities, and  the fact
            that a rule or regulation  and the degrees  of
            conformance therewith which may be proper  for
            an essentially residential area of the  state
            may not be proper for either a highly developed
            industrial area or a relatively unpopulated
            area of the state.
            The Act also requires TACB to consider the  "character
  and degree of injury to,  or interference with the health  and
  physical property of the  people" in setting "reasonable"  emission
  levels.   Technical practicability,  cost of emission control,  and
  the source's social and economic value must also be considered.
  Variances are available where economic hardship might otherwise
  result.

            TACB has always tried to  avoid restricting  industrial
  growth,  but requires it to conform  to an overall goal of  pro-
  tecting  the "normal health, general welfare and physical  property
  of the people."  A hallmark of this approach has been flexibil-
  ity -  the ability to balance economic and environmental needs
  on a case-by-case basis.

            The new Clean Air Act Amendments of 1977 will pre-empt
  much of  this flexibility.  The revised NSPS, with their require-
  ment for BACT, remove the option of regulating primarily  on the
  basis  of resulting ambient concentrations.  The Federal emphasis
  on emission control also  restricts  dispersion-based strategies
  such as  tall stacks.   Operating at  reduced capacity is similarly
  limited.  Some flexibility remains  in the provision for using
  site-specific information in PSD permit applications, and the
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use of innovative control technology.  However, the old approach
of tailoring control to circumstance is no longer possible.  In
particular, "economic reasonableness" may no longer be used as
a criterion for determing the choice of control technology.

          The new amendments also expand and cement the Federal
role in enforcement.  The TACB has in the past expressed the
view that EPA has assumed primary regulatory responsibility,
through the NAAQS, which rightly belongs with the state (TACB,
1975a, as cited by WH-124) .   The new Adtnendments add to this the
revised New Source Performance Standards, PSD increments and
provide for standards and increments for pollutants not now so
regulated.  Especially contra"}' t^ the state view is the quan-
titative definition of "significant deterioration" by Federal
statute for the entire Nation.  TACB has stated (TACB, 1975a
as cited by WH-124) that since the NAAQS already protect health
and welfare, criteria for "significance" may safely be left to
the states.  A proper role for EPA would rather be restricted to
areas with an obvious national perspective:  NSPS, new vehicle
emission standards, ambient air quality and standards for hazar-
dous substances.  Responsibility for air quality control should
rest with the states, in the view of TACB.

          Finally, it is widely felt in Texas that zoning the
state with respect to PSD will restrict economic growth and im-
pose unwanted land use controls.  Federal policies regarding
both PSD and permitting on non-attainment areas are seen as
"growth or no-growth" issues.  The results of this study do
not indicate quite such a basic conflict, but it is clear that
these Federal policies can have widespread secondary impacts.
At least some new industrial activity will tend to be forced
out of NAA's, where economic considerations would normally
place it.  But PSD will add to the cost of buildings elsewhere -
and perhaps restrict the choice of site.  Already, PSD increments
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   IPORATIOM
 near some major industrial centers are almost fully taken up.
 Thus, while growth is still possible, it will cost more; this
 will have some degree of impact on the state's economy.

           Another kind of secondary impact arises from the ten-
 dency of PSD to scatter industrial development rather than per-
 mitting it to cluster.  Thus, the local social and economic im-
 pacts of growth in rural areas are multiplied.  Supplying public
 services in an increased number of growth communities is a state
 and local burden, which this Federal policy tends to increase.
 Land-use impacts, as well as less tangible influences on life-
 style, are also spread more widely by PSD policy.

 5.1.5     Issues Related to Lignite Gasification

           Texas and Louisiana use more natural gas in industry
 than any other states.  Thus the Federal government's efforts to
 shift fuel use from gas and oil to coal can have disproportionately
 large impacts on the Gulf Coast.

 5.1.5.1   Factors Influencing the Development of Lignite
           Gasification

           Synthetic gas from coal or lignite appears likely to
 play an important role in this transition.  Gasification can pro-
 duce two kinds of product, used in different ways.  A low- or
 medium-Btu fuel gas can be used to generate process steam or
 heat, or to generate power.   A medium-Btu gas, enriched in hydro-
 gen and carbon monoxide, can also be made.  This "synthesis gas"
 can be used as a feedstock for petrochemical products.   It
 is particularly well suited for making ammonia and methanol,
 now produced from natural gas.   These two products alone made
 up 25% of the capacity of the Texas chemical industry in 1975.
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          As discussed in Chapter Two, large users of natural gas
as a boiler fuel will probably find it most eponomical to switch
to direct combustion of coal or lignite.  The cost of adding a
gasification step outweighs the benefits of continuing to use
existing gas-fired equipment.  Peaking units are an exception.
Combined-cycle applications and co-generation also appear prom-
ising.  However, gas of less than 300 Btu's per cubic foot cannot
be burned in existing boilers without modifying them.  Similarly,
process and equipment modifications are needed if methane is
replaced by a H2/CO synthesis gas as a feedstock, except for the
manufacture of ammonia and methanol.

          Until recently,  the cost of these changes and perceived
uncertainties in capital supply appeared to limit gasification's
future (WH-124).   Lack of experience with using gasified coal
or lignite in petrochemical processes was a further technological
drawback.   However, recent State and Federal policy changes have
now made the natural gas availability picture uncertain enough
to override these problems.

          A number of pilot studies are underway, and commercial
projects are also being seriously planned.  Texas A&M's Center
for Energy and Mineral Resources,  with funding from several large
chemical producers, is studying Nazi coal conversion processes.
During the war, processes were developed to convert German brown
coal into a large number of products.  Texas lignite closely re-
sembles brown coal, and could possibly be used in these pro-
cesses.  An ERDA-funded pilot study in Cedar Bayou, near Houston,
is investigating markets for synthesis gas from lignite.  In
addition,  a large oil company is investigating a medium-Btu lig-
nite gasification plant near Longview to ship synthesis gas to
the coast.   The Texas Governor's Energy Advisory Council has
adopted a formal policy favoring "federal support for synthetic
fuels development and prototype demonstration in the form of loan
guarantees . .  .".
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          The major factors behind this trend are uncertainties
of supply and proposed economic penalties for continued use of
natural gas in industry.  Price controls have a strong influence
on gas supply.  The consensus of economists and energy special-
ists is that price controls hold back production (FI-139;
MC-325)-   It is thought that price ceilings do not reflect
actual replacement costs.  Consequently, reserve addition rates
will fail to arrest declines in production.  The result will be
continued shortages and higher prices, making gasification more
competitive.  Even without price controls, the heavy economic
penalties proposed for continued use of natural gas favor the use
of gasified coal or lignite.  These tax penalties do not dis-
tinguish between flexible  (fuel) and non-flexible (feedstock)
uses of gas.  Thus gasification has become attractive to a broad
spectrum of users.

          The shift from gas as a fuel for new boilers is already
under way, due largely to rising costs.  This economic trend is
reinforced by policies of the Texas Public Utilities Commission,
and the Texas Railroad Commission.  New boilers are prohibited
from using natural gas, and overall gas use as a boiler fuel
must decline 10% by 1981, and 257. by 1985.  However, 70% of
the gas presently consumed in Texas is used in boilers, which
will eventually have to be phased out.

          Under both Federal and state gas curtailment schedules,
industrial and utility boiler fuel users are in the lowest prior-
ity (i.e., first to be curtailed in periods of supply shortage).
Other industrial uses are the next lowest priority with essential
residential and small commercial users being the highest priority.
As curtailments on both systems increase, it is likely that this
mechanism alone will force fuel conversion and provide incentives
for gasification.
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          Continuing shortfalls of gas supply are expected to lead
to a greater degree of Federal end-use allocation.  Gas supplies
allocated to high-priority residential users outside the Gulf
Coast can only come from gas-dependent industry in the producer
states.  Since 70% of the gas consumed in Texas is burned in boil-
ers, the economic penalties of such a policy are likely to be very
high.  The essence of the State-Federal conflict over how to
manage the shortage lies in the concept of allocation by user
type versus allocation by pricing.  The Federal view generally
favors allocation by priority on a nationwide scale.  Texas policy-
makers would rather have a system that relies on the market
mechanism to set supply and demand with a curtailment schedule
based on priorities for periodic shortages only.

          A factor which could constrain the actual development
of a gasification industry is Federal and State clean air policy.
Many of the industrial users identified as comprising the most
probable demand for gasified coal or lignite are located along
the Gulf Coast, in areas presently exceeding National Ambient Air
Quality Standards for hydrocarbons and particulates.  Gasifiers
emit hydrocarbons both as process emissions and as fugitive losses,
and consequently would probably come under the tradeoff policy.
Thus, it may prove impractical to site gasification plants near
demand centers.  Further study would show whether this limitation
would curtail opportunities for co-generation or other multiple
applications.  However, burning coal or lignite in a non-attain-
ment area for particulates may not be possible.  Clean air policy
thus ha.~ a countering influence:  gasified coal or lignite emits
few particulates.  In sum, it appears likely that both the lo-
catiTi of gasifiers, and the demand for them to supply clean fuels,
wil' be strongly affected by Federal air quality policies.
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 5.1.5.2   Probable Future of Gasification in Texas

           The combination of factors outlined above appears likely,
 if unchanged, to bring about commercial gasification in Texas by
 the mid-19801s.  The principal markets for synthetic gas appear
 likely to be:

              Peaking capacity in large generating systems
              (if not exempted from tax penalties, or cur-
              tailment)

              Process steam and heat serving groups of small-
              capacity industrial users

              New petrochemical plants designed to use
              H2/CO feedstock

           Industrial parks might form a special category of users.
 Especially where manmade particulate levels are high, or in areas
 where PSD increments are nearly used up, gas may be the only feasi-
 ble fuel.  Certain areas adjacent to the industrialized parts of
 the Gulf Coast may fall into this category.  Use of a clean-burn-
 ing synthetic medium-Btu gas, which could be piped cost-effectively
 as far as 150 miles, might allow more industries to locate close
 together.  Industrial parks present opportunities for more effi-
 cient cooperative energy use, which would thus be preserved.

           As discussed in Chapter Two, Texas lignite has characteris-
 tics which will probably allow it to compete favorably with bitumi-
 nous coal as gasifier feed.   Deep-basin lignites can probably only
 be developed economically by in situ gasification.  However, at
 least the first gasifiers built in the State are likely to be
 more conventional above-ground facilities.
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 5.1.6     Issues Related to Mining

          Issues related to mining ultimately express themselves
 in terms of the relative proportion of Texas' solid fuel needs
which will be met by lignite, as opposed to imported coal.  In
 turn, this balance turns on relative cost and timely availability.
 Two kinds of issues may be identified:  those affecting the owner-
 ship of surface-mineable coal and lignite, and those arising from
 the permitting procedure required by new Surface Mining Control
 and Reclamation Act of 1977 (PL 95-87).  Especially in the latter
 set of issues, there are substantial uncertainties which may emerge
 as "sleeper" issues in the near-term future.

 5.1.6.1   Assignment of Ownership

          Wherever surface and mineral rights are held separately,
 there is controversy over the assignment of rights to surface-
mineable mineral deposits.   In Texas, rights to lignite have been
 thought to be held by owners of "oil, gas, and other minerals"
 leases.  Mineral rights are historically dominant over surface
 rights, and the Texas Constitution has been construed as support-
 ing this position.1  Many such leases, however, predate the era
 of widespread surface mining, giving rise to ambiguity as to the
 actual intent of the parties involved.

          Texas lacks a consistent legislative policy on this
 question, and all disputes must presently be settled in the
 courts.  Rulings in relevant cases have gone both ways -- in
 favor of the holder of the surface and of the owner of the min-
 eral rights.   Considerable contradiction is apparent between the
 specific reasoning used in these rulings.  In general, however,
 Southwestern Law J., 1976, as cited in WH-124.
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the courts have tended to favor the party with the fewest alter-
natives.  Thus, surface owners have been successful where the de-
veloper of the mineral estate could employ other "reasonable"
means of exploiting it.  Where no other options were available,
mineral developers have tended to prevail.  Surface mining pre-
sents special difficulties.  At least during the mining opera-
tion itself, the mineral owner may have no alternative means of
extraction.  At the same time, the surface owner has no alterna-
tive method to use his rights.

          Three recent decisions1 have been based on the theory
that the surface owner, in severing the mineral estate, could
not have intended strip mining as a means of development.  The
courts see surface mining as effectively precluding surface use.
Opponents of this reasoning claim that the surface is reclaim-
able.  Therefore, the surface owner can justly claim only com-
pensation for a fair market rental for the affected land for the
time it is disturbed, and for any loss in its value after reclama-
tion is complete.

          These three cases constitute a strong trend toward
assigning surface mineable lignite to the surface estate in le-
gal instruments where no specific mention of it is made.  How-
ever, they do not establish a clear policy.  Section 510(b) (6)
of the Federal Surface Mining Act (PL 95-87) requires that sur-
face-subsurface relationships be determined by state law.  The
Act further specifies that "nothing in this Act shall be con-
strued to authorize the regulatory authority to adjudicate prop-
erty rights disputes."  Under these circumstances, it will likely
be the policy of the Texas Railroad Commission -- when authorized
to administer the new law — to refer disputes regarding permit
applications made on the basis of "oil, gas and other mineral"
1 Acker v. Guinn; Williford v. Spies; Reed v. Wylie.
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leases to the courts for adjudication.  If such disputes are
common, the timely availability of lignite could be threatened
(Texas Railroad Commission Staff, personal communication).

          There has been some concern over the potential for
lease renegotiation which might arise from this situation%  On
a large scale, such a round of new lease agreements could re-
sult in increased prices for lignite, affecting its already some-
what tenuous market position.  Should coal companies holding
mineral rights decide to protect their interests by re-uniting
the severed estates, the most favorable route would be through
purchase of surface rights.  Otherwise the same disputes crop
up again over the question of royalties.  The surface owner would
then be in a position to hold out for a high price, reflecting
the value of the lignite.  This could result in costly delays
and possibly injure the market position of lignite.  The lignite
industry in Texas is already marginal in some respects, and pro-
ducers have elected to take the stand that lignite goes with a
lease for "oil, gas and other minerals."  If the only way a sur-
face owner can contest a mineral leaseholder's right to surface
mine is to go to court over a permit application, there is little
likelihood that large-scale lease renegotiation will take place.
The extent of split property ownership in Texas is not now known.
It would be useful to determine both the number of such cases and
the proportion of them that will need to be renewed within 10 to
20 years.

5.1.6.2   Obtaining a Mining Permit Under PL 95-87

          The first issue arising over the new federal permitting
process is whether the state will qualify to administer the pro-
gram prior to the 18-month deadline written into the law.   The
Texas legislature meets every two years; its next session begins
in January of 1979.   In anticipation of federal legislation,
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 however, it passed a reclamation law in 1975 which was expressly
 designed to permit the state to assume jurisdiction over the
 federal program then under consideration.  The state law expressly
 grants authority to the Texas Railroad Commission (RRC) "on pas-
 sage of any federal surface mining legislation. .  .  to take the
 steps necessary to establish the exclusive jurisdiction of this
 state over the regulation of surface mining and reclamation op-
 erations ..." including making recommendations for remedial
 legislation.

           Despite the conceptual similarity of the state and fed-
 eral laws, some specific differences exist which will have to bz
 resolved before the RRC can propose an acceptable state program.
 Most differences can be handled through administrative action,
 but additional state legislation may be needed to establish:

           A requirement for revocation of a permit if
           mining has not commenced within three years

           RRC authority to require permit revisions during
           the permit period

           A conflict of interest clause forbidding RRC
           employees from having a financial interest in
           coal or lignite mining

           Provisions for citizen suits to require enforce-
           ment

           Requirements for a public hearing within ten
           months of receipt of a petition for  designation
           of lands unsuitable for surface mining, and a
           decision within six months thereafter.  (UN-092)
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          If additional legislation is required, it will have to
be passed in a special session of the legislature if no federal
pre-emption of lignite mining is desired.  Otherwise, the atate
must take over a federal program that is already in place, which
may give rise to administrative and even regulatory inconsisten-
cies.

          There are several controversial aspects of the Surface
Mining Act related to the issuance of permits which may affect
Texas lignite.   In general, reclamation of surface mined land
appears to be feasible throughout the state.   However,  land may
be designated as unsuitable for surface mining if mining could
"result in a substantial loss or reduction of long-range produc-
tivity of water supply, [including] aquifers  and aquifer recharge
areas."  As is discussed in Section 4.3 above, the lignite in
Texas is related to a complex aquifer system, and mining could alter
the local hydrological conditions.  Whether these effects are con-
strued as falling under the criteria set forth in the Act has yet
to be determined.  Much of the ground water in the affected aquifer
is either not suitable for use or is used only to water livestock.
Furthermore, the aquifer is not continuous, much of the water being
held in discontinuous large sand lenses.  These factors will have
to be taken into consideration in determining whether there is
reason to designate any of the Texas lignite belt unsuitable.

          Clarification of the concept of "aquifer" meant by the
Act  is also needed before permits can be issued.  In East Texas,
ground water is plentiful and often lies near the surface in small,
unimportant perched bodies which would be impossible to restore.
Defining these as "aquifers" in the sense of the Act could restrict
permitting of substantial amounts of lignite.
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RADIAN
           Natural hazards may also serve as reason to designate
 an area unsuitable for mining.  Included among these are areas
 subject to frequent flooding which could be construed to apply
 to parts of the broad Trinity and Brazos River floodplains under-
 lain by lingite.  These streams, however, are regulated by a number
 of dams which prevent heavy flooding.

           Large quantities of lignite are also associated with
 the poorly documented Wilcox-Carrizo sands aquifer system.  Even
 if not designated unsuitable, there is generally insufficent hydro-
 logical information available from a state or federal agency, as
 required in Section 507  (b) (11), to make  a rigorous assessment of
 the hydrologic  consequences of mining.   In addition, the geohydro-
 logic setting is so complex that  it is not amenable to accurate
 analysis within the current state of the art.  Finally, there is
 a possibility that in some areas  it will not be possible to re-
 store the original recharge characteristics after mining, as re-
 quired in Section 515(b)(10).

 5.1.6.3   Other Potential Issues  Arising from PL 95-87

           PL 95-87 contains several provisions with potentially
 wide-ranging consequences,  although  they are not among  the more
 obviously controversial  aspects of the  law.  The following discus-
 sion of these "sleepers"  is conjectural  and intended merely  to
 point out possibilities.

           Section 503 calls for coordination between the  regulatory
 authority and any other  agencies  regulating any aspect  of the pro-
 posed operation.  This provision  encourages coordinated planning
 in many areas where none  now  exists.  A more  comprehensive approach
 could come  about, particularly  in the area of water  quality  plan-
 ning under  Sections 208  and 303 of the  Water Pollution Control  Act
 Amendments.  Also, the combined provisions of Titles V and VI of
 PL  95-87 can be read  as  effectively  charging  the  state to develop
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 a land use  planning policy  for all areas affected by surface mining
 for  coal  or non-coal minerals.  This requirement would surely in-
 volve  a coordinated planning effort with agencies responsible for
 other  aspects  of  the environment.

          A  second potentially powerful provision of the Act, also
represented  in Texas law, is the provision that any person may pe-
tition to have an area designated unsuitable for mining.   In addition
to a maximum 16-month review process,  the regulatory authority
must prepare a detailed statement of its findings.   Various inter-
est groups could use this provision as an effective delaying tac-
tic,  in addition to the many legitimate petitioners who may come
forward.  Full exploitation of the technicalities of the EIS pro-
cedure have resulted in the cancellation and delay of controver-
sial projects.  If used in a similar manner, this right to peti-
tion, coupled with that of Section 520 providing for citizen suits
to compel agency compliance with the Act,  could conceivably oper-
ate against other State  and Federal energy  policies requiring
rapid conversion to coal.

          Finally, the regulations ultimately promulgated by the
Department of the Interior could have an unspecified effect both
on cost and timely availability of coal and lignite.  Current in-
formation suggests that the draft regulations will be very detailed
and will extend to the nation as a whole many requirements developed
in states where it may often be difficult to prove that surface
mining will be environmentally acceptable.   Such a trend will hurt
the competitive position of coal or lignite produced in states
where there are few existing environmental problems .

5.1.6.4   Effects on the Competition Between Lignite and
          Imported Coal

          Several aspects of PL 95-87 appear to be more likely to
adversely affect the cost and reliability of supply of imported
coal than of Texas lignite.   Of particular importance is the pro-

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vision in Section 510 that federal coal may not be leased without
the permission of surface owners.  It is generally believed, even
among the drafters of the Act, that this provision makes it possi-
ble for surface owners to force coal companies to buy them out
at a price reflecting the value of the mineral.  This, in turn,  is
expected to drive up the cost of coal.  In Texas, the only major
federally-owned lignite supply is that underlying Camp Swift, and
its surface is also in federal ownership.

          The process of designating areas unsuitable for mining
is far more likely to induce delays and uncertainties in the West
and Appalachia than in Texas.  Many areas are legitimately ques-
tionable with respect to permanent revegetation.  In addition,
strip mining national forest lands may be permitted only if the
Secretary of the Interior finds that mining will not be incompat-
ible with a range of loosely defined values (Section 522(e)(2)).
Cultural and archaeological values may also conflict with mining
in other areas, e.g., Four Corners.  In Texas, there appear to be
relatively few insurmountable environmental problems--aside from
ambiguities regarding the interpretation of subsurface hydrolog-
ical impacts--as well as very little public opposition to strip
mining to date.

          Specific provisions in Section 515 may be expected to
increase the cost of producing coal in the steep Appalachian re-
gion, and in the prime farmlands of Illinois and the midwest.
Again, Texas has no steep sloping coal lands, and lignite gener-
ally lies outside the prime farming areas.
          It would require a much more thoroughgoing, quantitative
analysis than the scope of this study permits to estimate the po-
tential balance between the factors described above.  Many will
only become clear with experience.  However, it seems probable
that the more obvious inequities and impediments to timely develop-
m- r.t of coal and lignite will be resolved early, in view of the
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national commitment to increasing our reliance on domestic coal.
Thus, it appears that in the short term -- roughly two to four
years -- lignite could be favored over imported coal in Texas.
Any improvement in its market position is likely to come about
because of temporary uncertainties in the cost and reliability
of imported coals.  However, there is a vast amount of coal com-
pared to the quantities which may be temporarily tied up while
the provisions of PL 95-87 are worked out.  It will probably not
take long for production to move out into areas free of major
impediment.  Ultimately,  therefore, it will probably be the regu-
lations themselves which determine the long-term effect of the
Act upon the amount of lignite mined in Texas.

 5.1.7     Capital  Availability

           Since energy development is extremely costly,  an impor-
 tant question concerns potential sources  of capital.   Two major
 questions  must be answered:  (1) will the money be available?
 (2)  where  will it  come from?

           The answer  to  the first question is "yes."   According
 to several financial  analysts (CA-440 and GR-350),  the initial
 capital to finance construction of major  facilities will be avail-
 able through banks.   Hence, no government aid is likely to be
 needed.  However,  the banks that have the amount of capital re-
 quired are not located in Texas.  Thus,  the answer to the second
 question is "from outside Texas."

           Texas law has  not favored the growth of very large
 banks.   Only recently with the growth of bank holding companies
 have some  Texas banks become  large enough to finance  extremely
 large projects.   Therefore, most front-end money for  large pro-
 jects will probably have to come from money-center banks such as
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Continental Illinois, City Bank of New York, Chase Manhattan,
and Bank of America.

          In the long run, the backing for these large projects
will come from bonds which will be purchased by major long-term
investors such as institutional investors, mutual funds, insur-
ance companies, labor unions, universities, and the institutional
sources.

          The overall outlook with respect to capital avail-
ability in 1977 is very good.  In the early 1970's the outlook
was not as favorable mainly because utility companies were not
being allowed to pass increased costs on to consumers.  The
current feeling is that utilities are being dealt with fairly
by state utility commissions and are, therefore, good investments
An important caveat  is that  the continued  bright prospects for
utility companies are dependent upon the attitudes of utility
regulatory commissions.
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5.2       Issues Surrounding  Impact Mitigation

5.2.1     Water Quality

          Even though amendments to the Federal Water Pollution
Control Act are presently being considered in Congress, mining
and utility industry representatives in Texas claim  that there
will be no major problems in  complying with existing 1977  and
1983 point-source discharge requirements.

          As discussed above  in Chapter 4, however,  large-scale
lignite development can potentially result in local  effects  on
ground water quality.  Secondary community growth  can also gener-
ate additional pollutants both from point sources  (primarily mun-
icipal sewage treatment effluents) and from area runoff.   Strip-
mined areas will generally be large—on the order  of 20,000  acres
or more—and can also potentially add contaminants through runoff.
Institutional means of regulating these effects are  less clear-cut
than those governing point source discharges and some regulatory
gaps exist.

          Presently, authority over ground water quality in  Texas
is fragmented, with no comprehensive program of protection.  Impacts
of in situ processes (primarily solution mining of uranium,  but
also including lignite gasification) are being transferred from the
Water Quality Board to the Railroad Commission.  The Department
of Health Resources, through  its regulation of municipal solid waste
disposal, also has a responsibility to protect ground water  from
contamination.  The Water Development Board regulates oil  well dril-
ling and casing and protects  ground water from contamination through
these activities.  A more comprehensive program could develop under
the mandate of the Federal Safe Drinking Water Act.  Funding to im-
plement the Act has been received by the Department  of Health Resources,
but no allotments have yet been made.  A comprenensive program of
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 ground water quality protection would entail overcoming some of
 the  same public attitudes that hamper coordinated management of
 ground and  surface water supply.  Especially where land use or
 pumpage are regarded as contributing factors subject to regulation,
 opposition  on the basis of property rights is likely to arise.  For
 this reason, any major legislative initiative designed to integrate
 all  aspects of ground water quality protection and to fill the
 existing regulatory gaps is unlikely in the near future.

          The planning requirements of the Federal Water Pollution
 Control Act Amendments of 1972 include mandates for basinwide
 plans for waste discharges, including effluent limitations and to-
 tal maximum daily pollutant loads  (Section 303).  Areawide waste
 treatment management plans are also called for, including non-
 point, mine-related and construction sources (Section 208).  These
 planning processes potentially provide a framework for forward-
 looking, coordinated planning for  the control of point- and non-
 point sources of pollutants.  EPA  emphasis on decreasing waste-
water treatment plant discharge loads, however, has tended to
 eclipse these longer-range objectives.

          Most of Texas is a non-designated area with respect to
 208 planning and falls under the jurisdiction of the state's
river authorities, which are also responsible for 303 basin plan-
ning.  Non-point sources have for the most part been ignored in
this highly dispersed planning framework.  Emphasis has been
placed on developing a system for case-by-case wasteload alloca-
tions, based on the existing inventory of discharges.   Forecasting
is not part of this process; instead, the allocation is updated
yearly.   Expected changes in water quantity, as they may affect
the assimilative capacity of receiving streams,  have not been
included in the planning process.   Thus,  there is presently no
attempt to plan systematically for simultaneous changes in waste
loading and assimilative capacity,  nor is there sufficient funding
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available for a comprehensive approach to this problem, based on
forecasting.  Such a program might allow more effective distribu-
tion of industrial and other growth, so as to use existing assimi-
lative capacity more efficiently.  Under the present case-by-case
approach, much of this opportunity is likely to be foregone.

5.2.2     Growth Management

5.2.2.1   Planning for Increased Service Demand

          For those communities expecting to grow rapidly because
of lignite, planning can make the difference between successfully
meeting increased service demands or falling short of the needs.
For such services as sewer, water, streets, police  and fire
protection, the total lead time between recognizing the need
and having the service available is typically three to four
years (UN-092).   Thus, after the need is recognized, it must
first be quantified.  Then a strategy for obtaining funds and
implementing the needed measures must be devised.

          There is a great variety of federal and state assistance
available to fast-growing communities,  especially those affected
by energy development.  Local governments, however, must initiate
the planning process.   The state provides technical assistance
through a variety of agencies to communities facing growth pro-
blems.   This assistance often takes the form of helping local
governments to organize themselves to be better able to utilize
federal program.   Loans or grants are available from many federal
sources,  often overlapping each other in terms of the need ad-
dressed.   Devising an optimal planning strategy involves examining
this various array of resources and choosing a combination best
suited to the individual community's needs.  Then the necessary
steps in applying for and receiving aid from the federal and
state governments must be defined and coordinated.
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          The process of planning for lignite-related growth can
become exceedingly complex, and require a degree of familiarity
with state and federal bureaucracies not always found in munici-
pal governments.  Simple unawareness of the resources available
will hamper the process for some small communities.  Added to
this are a number of other impediments often met with in small
communities in Texas and other states.

          First, the amount of planning lead time a community has
to work with is to a large degree determined by information sup-
plied by industry.  There is a growing tendency, especially in the
power industry, to inform community leaders early of planned acti-
vities.  Solid advance information, three to four years before
the need for additional municipal services, can serve a valuable
time in a planning process often filled with unavoidable adminis-
trative delays.

          Even when a community knows of its needs in advance,
however, citizens and leaders may strongly oppose seeking help
from other levels of government.  Small communities often wish to
avoid what they view as entanglement in immense big-government
bureaucracies.  More importantly, they may feel that the agencies
assisting them will attempt to take away local powers of decision.
Thus the larger federal agencies with money to spend may be viewed
more as a threat than a resource.

          The regional Councils of Government (COG's) appear pre-
sently to offer the most acceptable form of assistance to local
governments.  Being made up of these same, small bodies, they are
often viewed as an extension of local government, rather than as
an outside force.   The COG's are sensitive to their members'
interests, and in parts of Texas' lignite belt have already furnished
substantial help.   In general, however, their effectiveness is
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RADIAN
 hampered by lack of funds and small staffs.   They also lack im-
 plementation powers and can provide only information and advice.
 A study of ways to strengthen their role, as a way of opening
 channels to big-government aid programs, could yield useful re-
 sults .

 5.2.2.2   Financing

           A recent study by the University of Texas (UN-092) sug-
 gests that the additional operating expenses of expanding com-
 munities could be met without special measures.  Intergovernmental
 transfers of funds would often be needed, because taxes might not
 be equitably distributed among those entities actually serving the
 increased population.  Some increase in local taxes, such as a
 city sales tax, may also be needed.

           Capital expenses, however, involve special problems that
 may need novel solutions.  The fundamental problem local governments
 face is the fact that the need for services develops faster than
 the tax base.   This lag period may last five to eight years (UN-
 092).  This is especially true for projects with large construction
 forces and long building schedules.  Front-end money must be obtained
 to build needed facilities.

           Bonding is one way of ra5.sing capital for needed expansion.
 However, local communities may have difficulty in issuing bonds.
 In particular, their tax base may not be large enough to secure
 substantial bond issues.  Some states, such as Wyoming, include
 a state bonding authority which interposes itself between the local
 government and the capital market.  With a larger tax base behind
 it, this bonding authority is often able to obtain bonding more
 readily and at lower cost than the local governments could have
 done.  Texas has no such general authority, but a similar function
 is performed by the Texas Water Development Fund and Water Quality
 Funds.  Both issue state bonds to provide funds to local govern-
 ments for water distribution and treatment works.
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          Front-end financing may also be assisted by industry.
Some large industrial developers may provide certain facilities,
such as mobile housing parks, at their own expense.  However,
these instances are not usual, and are generally limited to
activities which are in themselves sound investments.  Industry
money to finance such services as sewer and water may be obtained
through a system of tax prepayment,  followed .by tax credit later
on.  This kind of system provides funds when needed, but has the
disadvantage of reducing later revenues.   At present, Texas has
no such system.  Industries can also help communities by guarantee-
ing bond issues.  The Securities Exchange Commission, however,
requires such guarantees to be carried as corporate liabilities.
Some companies might not be able to carry such as additional
financial burden.

          The tax picture developing as a result of lignite de-
velopment could become quite complex in some areas.  This is
particularly true if the projects are built close to county
boundaries.  Tax monies may not go to the counties furnishing
the bulk of the services required.  In these cases, counties
receiving added revenues may not be willing to make adjustments
in favor of neighboring counties.  Sometimes, special purpose
districts are called for.  By special districting, the tax base
supporting a particular service, such as hospital care, can be
"defined" on the basis of potential use of the service.

          In Texas, special problems arise when the entity de-
veloping a large power project is a municipal power authority
or river basin authority.  These bodies cannot be taxed, yet
their new projects add to the burden of local governments.
Citizens object strongly, not only to the added load on local
services, but to the fact that other communities experience large
tax benefits from other power projects.  Possible solutions to the
problem include a "gross proceeds" tax, proposed in the last
session of the Texas Legislature.   The Texas Municipal Power
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 Agency is presently looking into ways to provide services in
 lieu of taxes.  Such services might include solid waste manage-
 ment, recreation, road improvements,  fire protection,  and health
 care (UN-092).

 5.2.2.3   Land Use Planning

           Key growth factors affecting land use will be the
 availability of housing and highway transportation.  Sprawl pro-
 blems are most likely in areas where these facilities  are in-
 adequate and must be expanded.  A second factor contributing to
 sprawl or disconnected urban growth is the availability of funds
 to build new municipal sewer and water systems.  Many  communities
 now have sewage treatment systems which do not now meet EPA
 standards, or which will not carry added loads due to  growth.
 Public funding for all of these communities is simply  not avail-
 able, and many of the smaller ones may experience difficulty in
 issuing bonds.  Where these services cannot be provided by local
 governments, developers may build self-contained housing tracts
 using package treatment systems.  These may be located well away
 from existing towns, adding to highway traffic pressure, school
 transportation demand, and other local service demands.  Com-
 munities may be unable to influence their location,  timing or
 size.  More importantly, unless developers understand  the need
 for lead time, local governments may not be informed of planned
 developments in time to provide needed services.  The  land-use
 impacts of lignite development can almost certainly be lessened
 or controlled by some form of collective goal-setting.  This
 could be accomplished either by local governments or voluntarily
 by developers.  In Texas, however, opposition to land-use planning
 is strong and of long standing.  Property owners view  planning
 as a threat to their freedom to profit from using their land as
 they choose.  A few larger communities, such as Austin, have
 instituted a municipal plan, and smaller towns near large cities
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and becoming interested in planning.  There is little actual en-
forcement power in these plans as yet, however.

          Texas has not yet experienced large-scale lignite
development.  Its residents are now largely in favor of growth,
because of its obvious and and substantial economic benefits.
The lignite lies generally in a region in which these benefits
are particularly needed.  However, experience in other states,
such as Wyoming, suggests that after development gets under way,
public opinion may shift.  In these cases, the early comments
of citizens often reflect a very incomplete picture of the future
Expectations are high, and there is no basis of experience with
probable growth-related impacts.  This gap becomes suddenly and
clearly apparent when the impacts begin to be felt.

          Thus, information appears to be a key factor that can
moderate these "surprises".  Information regarding what to ex-
pect must be communicated to the people who stand to be affected.
Equally important, developers, industries, and service-providing
agencies need to know the values of the people themselves.  The
aesthetic impacts of a power plant, for example, may be more
important to local residents, than its emissions.  A mechanism
to promote smooth, two-way transfer of this kind of information
is needed.  Operating effectively, it could save a great deal
of future dissatisfaction.  At the most, it could avoid divisive
local "backlash" that would slow needed energy development and
hamper planning.
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5.3       Camp Swift;  A Case Study of Federally Owned
          Texas Lignite

          The bulk of the Texas lignite resource will be de-
veloped by private industry on privately owned land.  A signifi-
cant exception is lignite at Camp Swift, a large abandoned World
War II military training reservation located some 30 miles east
of Austin.  Strippable lignite reserves on this federally owned
property are estimated in excess of 100 million tons or enough
to supply a 750 MWe unit for at least 20 years.  Most of the
available resource lies within some 4,000 acres of the 11,740
acre tract.

          By virtue of a provision in the Federal Coal Leasing
Act Amendments of 1976 (P.L. 94-377), coal and lignite on U.S.
military property can be leased to publicly, owned utilities.
This measure was specifically designed to benefit several publicly
owned Central Texas utilities hard hit by some of the highest
priced and least dependable fuel supplies in the nation.  Under
the provision of P.L. 94-377, the Secretary of the Interior can
execute coal leases with the consent of the Department of Defense.

          The Lower Colorado River Authority (LCRA) has applied
for a leasing permit under the Act.  The municipally owned util-
ities of Austin and San Antonio may join with LCRA in the develop-
ment of the Camp Swift lignite.

          Despite recent changes in Federal coal leasing policy,
officials with the Department of Interior state that they are
"actively processing" the LCRA application and that they foresee
no delays in the original schedule which called for leasing in
 Personal communication with LCRA staff.
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1979.  Although an environmental impact statement will be re-
quired prior to any development of the Camp Swift reserves,
some preliminary area environmental assessments have been con-
ducted.  These are reflected in the following general comments
regarding impacts resulting from the development of Camp Swift
lignite.

          For the publicly owned utilities likely to be involved,
Camp Swift offers several positive features.  The size of the
property and the extent of the resource is large enough to mine
as a single unit thus avoiding the need to acquire many addi-
tional parcels of land.  Competition for the leases is limited
by law to publicly owned utilities and, by the economics of lig-
nite transportation, to nearby facilities.  A third advantage
deals with a situation discussed in Section 5.1.6, the legal
conflicts over assignment of surface mined lignite.  Since all
of the property has single surface and mineral right owner, Camp
Swift lignite development will not be impeded by this problem.

          Finally, it should be noted that LCRA and the city-
owned utilities of Austin and San Antonio enjoy a variety of op-
tions for using the Camp Swift lignite.  The LCRA and the City
of Austin are jointly constructing a coal-fired power plant 40
miles southeast of Camp Swift.  The two 550 MWe units of Fayette
Power Plant are scheduled for completion in 1979 and 1980.  To
maximize the flexibility of fuel supplies, both units will be
built to burn either western coal or Texas lignite.  The Camp
Swift reserve, with existing rail connections to the Fayette
Power Plant, is the logical source for Texas lignite.

          A second option is the conversion of the gas-fired
boilers on the 600 MWe LCRA Gideon Power Plant located a few
miles south of Camp Swift on Lake Bastrop.  LCRA is performing
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 engineering studies to determine the feasibility of boiler con-
 version to lignite.  Other options include the construction of a
 new plant near the Camp Swift reserves or, less likely, the ship-
 ment of lignite to facilities near Austin or San Antonio.

           The new Surface Mining Control and Reclamation Act of
 1977 (P.L. 95-87) introduces some new requirements for obtaining
 rights to Camp Swift lignite and a permit to mine it, but they
 do not place the area at a disadvantage relative to other in-
 state or out-of-state sources.  In particular, the Secretary of
 Interior is required to inventory all Federal lands to determine
 what areas may be unsuitable for mining.  Permitting under the
 Act may continue, however, during this review.

           There appear to be no natural impediments to successful
 reclamation at Camp Swift.  The overburden above the lignite is
 generally low in sand, and this may require selective replacement
 of overburden to create the best possible texture for plant growth.
 Overlying soils, based on their classification by the Soil Con-
 servation Service, are expected to be only moderately suitable,
 or poorly suited to use in reclamation.  Thus stockpiling and re-
 placing topsoil might not be cost effective in comparison to se-
 lective overburden placement (PA-190).  Under Section 515 (b)(5)
 of the surface mining act, the requirement for replacing topsoil
 may be waived if subsurface strata can be shown to provide a more
 effective plant growth medium.

           The new law does preclude new coal mining operations
 which "will adversely affect any publicly owned park"  (Section
 522(b)).  Camp Swift is roughly seven miles from the closer of
 two states parks.  It does not appear at this point, however, that
 mining at Camp Swift would interfere with their use or aesthetic
 enj oyment.
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          In general, the socio-economic impacts of developing
a mine at Camp Swift would be similar to those arising from a
similar operation anywhere in the central portion of the lignite
belt.  An exception, however, arises in the matter of taxation.
At present, Camp Swift, as a federal property, is a non-taxable
entity -- as is LCRA and other publicly owned utilities.  This
poses the problem that local governments may be subject to in-
creased demands for services without an increased tax base to
meet these demands.  However, the same act which permits the
leasing of Camp Swift lignite also provides that the Federal
government must share half of its coal royalty revenues with
the affected states for use by local governments in coping with
social and economic impacts resulting from federal coal develop-
ment.  (The minimum Federal royalty share is 12.5 percent of
the value of the resource.)  Therefore, it appears that there
is a mechanism to mitigate impacts through assistance to local
governments in the Camp Swift vicinity.

          No ecological impacts of significance outside of the
mined area are likely to result.  The landscape is already
patchy from prior clearing and disturbance, and the additional
disturbance of mining will probably not occasion any changes that
have not already occurred.  Some loblolly pines occur on the Camp
Swift property, but the bulk of the so-called "Lost Pines" occur
on the sandier soils of the Carrizo outcrops, rather than on the
soils of the Calvert Bluff Formation, where mining will take place.

          Studies conducted during the summer of 1977 by the Texas
Bureau of Economic Geology and not yet released indicate that the
mining of Camp Swift lignite can be accomplished without adversely
affecting surface or subsurface water resources.  However, applicants
seeking permits under the new surface mining act must demonstrate that
no material damage will occur to hydrologic systems outside the
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immediate mining areas after reclamation (Section 510(b)(3).  Since
much of the Camp Swift lignite lies below the water table, as is
the case in much of the lignite belt, final regulatons issued
pursuant to this provision conceivably may limit development of
deeper seams.

          Recognizing the uncertainty regarding hydrological im-
pacts, the outlook for lignite development at Camp Swift appears
generally positive.  If a reclamation plan can be designed to
mitigate any possible hydrological impacts, mining at Camp Swift
appears to pose no major environmental problems.

5.4       Summary Evaluation

          Perhaps the most significant conclusion of this study
is that the problems Texas must solve to develop its lignite are
largely institutional rather than environmental.  This makes
Texas -- and by extension, the overall Gulf Coast region — unique
in comparison to the Nation's other energy-producing regions.
Of course, there will be potentially adverse impacts on the en-
vironment, but it presently appears that most of them can be
successfully mitigated.  No insurmountable drawbacks arising
from the nature of the environment itself have been found.  How-
ever, there will probably be problems in implementing available
solutions.  These are mainly "people problems," arising from
the region's particular goals and governmental style, which con-
flict with those of the Federal government.  Thus environmental
planning and management in the Gulf Coast Resource Region will be
largely a political undertaking rather than a technological one.

          Compared with the Western states, Appalachia, and the
Midwest, the environment of the Gulf Coast appears very well
suited for surface mining and industrial development.  First,
its climate, topography, geology, and soils generally favor
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CORPORATION
  reclamation;  there  appear  to  be  no  areas  in  Texas where success
  is  truly questionable.   Also,  there is  presently no  reason  to
  expect  a problem with  acid mine  drainage.  Some impacts on  ground
  water systems are likely but  Gulf Coast lignites are not  them-
  selves  aquifers.  Therefore,  these  impacts are  likely  to  be on
  a small scale,  and  much less  difficult  to mitigate than in  large
  parts of the  West.   Conflicts over  water  use are forecast,  but
  the economic  tradeoffs involved  are far less basic than those
  faced by the  Western states.   The boom-town  syndrome already
  developing in parts of the west  is  much subdued in Texas  and the
  Gulf Coast.   In this region,  the resource is not isolated from
  large population and trade centers.  Also, the  extensive  areas
  of  natural vegetation  and  prime  wildlife  habitat threatened by
  surface mining and  land use changes are not  found in the  Texas
  lignite belt.   Similarly,  prime  farmlands lie generally outside
  the lignite belt, as contrasted  with the  Midwest.  Finally, the
  Gulf Coast lignite  region  has none  of the topographic  and cli-
  matic conditions which cause  concern over air pollution in  other
  regions.   Thus,  the Gulf Coast,  of  all  the coal-producing regions
  of  the  Nation,  offers  the  fewest natural  impediments to develop-
  ing its resource.

            The institutional and  political problems faced  by the
  Gulf Coast also have a regional  flavor  distinct from areas  with
  different attitudes and histories.

            The most  pervasive  influence  involved in these  problems
  arises  from the region's attitudes  about  resource use.  Texas
  and the Gulf  Coast  have evolved  a governmental  style that reflects
  conditions of resource abundance and exploitation.   But those
  conditions have changed pervasively and suddenly.  Like the
  rest of the Nation,  the Gulf  Coast  must make the transition
  into a  future constrained  by  higher energy costs and increased
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 need to protect the environment.   A successful transition,  how-
 ever, must recognize the need to deal with the existing cultural
 and institutional structure.   Evolution is indicated,  rather
 than surgery.

           Federal energy and environmental policies place much
 more emphasis on centralized management of common resources than
 currently exists in Texas,  due to popular attitudes.  The cri-
 teria used in these policies  are National, and often conflict
 with the actual situation in the region and state.   In addition
 to incurring environmental and financial burdens as a result of
 this conflict,  the region has had much of its problem-solving
 flexibility pre-empted by federal authority.   First by setting
 uniform goals throughout the  Nation,  and second by specifying
 required means  to meet them,  the  federal approach reduces the
 region's ability to tailor  its own solutions.   This tends to
 produce more uniform progress toward  national goals, but the
 progress may be sub-optimal.   From the standpoint of these  na-
 tional goals, however, some form of standard approach may be
 necessary to keep them from being lost among the interests  of
 the different regions.

           An aspect of the  federal approach,  which seems not to
 have been directly intended,  is de facto land-use and economic
 planning.   Taken together,  the provisions of the federal clean
 air law, surface mining control,  and  clean water law have a
 strongly restrictive effect on land use and industrial siting.
 Other laws also contribute  to the effect.  States,  in complying
 with the environmental planning provisions of all of these  fed-
 eral statutes,  are effectively required to make broad-based
 plans for future industrial siting and land use.  Most impor-
 tant , the planning criteria provided  by these laws are primarily
 oriented toward environmental control, and largely do not recog-
 nize region-specific economic factors.  It is these factors, how-
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ever, which are the driving force behind growth and land-use
changes.  To a degree, then, regions are faced with a national
planning requirement which arises incidentally from environmental
policy.  With such indirect origin, it is not surprising that
this planning "policy" conflicts strongly with any potential
regional efforts to plan comprehensively.

          To sum up, then, the major "environmental" problems
facing the Gulf Coast resource region will likely be institution-
al.  These are founded in strong national-regional conflicts,
and in state-level policies which have developed under conditions
of resource abundance.  To make the transition into the future,
policies at all levels affecting this region need to find a com-
mon basis.  Ideally, this basis will allow for regional perspec-
tives needed to find the best solutions  to the region's special
problems.  It will also recognize the fact that rising energy
costs and increasing environmental stress now require an in-
creased degree of cooperative problem-solving and planning.

          The complexities of the existing net of Federal and
state policies are great and extend beyond lignite to encompass
all energy resources.  Nowhere is the national-regional conflict
over energy and environmental values more fundamentally developed
than in the Gulf Coast resource region.  Consequently, a major
policy analysis study of this area, along the lines of EPA's In-
tegrated Technology Assessment program, would amply repay the
effort.  Unlike other resource regions,  such a study would not
run the risk of merely reiterating environmental problems based
on unchangeable natural conditions.  A study of the Gulf Coast
will provide information about situations that can be changed,
and provide the framework for effective  federal-state coopera-
tion that can reap real benefits in the  short term.  In addition,
means of resolving national-regional conflicts which develop
from this analysis may be applied in other regions as well.  Be-
cause the potential utility of such a study is so great, and be-
cause this significant energy resource region is not yet repre-
sented in rhe ITA program, it should be  seriousl> considered.
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 CHAPTER SIX



RESEARCH NEEDS
        201

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6.0       RESEARCH NEEDS

          This study was undertaken solely to outline the major
environmental aspects of lignite development in Texas,  based on
knowledge already available within Radian Corporation.   It has
accordingly identified those areas where problems and issues
arise, but at a very generalized level.   To turn these observa-
tions into a useful framework for state and federal planning
will require further in-depth research.   The following recommen-
dations for further study fall into four categories:

             Forecasting
             Baseline data and impact prediction
             Developing national/regional problem-solving strategies
             Developing state-level problem-solving strategies

          These recommendations do not exhaust all areas where
more knowledge would be useful.  Rather, they are intended to
point out major directions and focal points for planning addi-
tional work.  Emphasis has been placed on the kind of study neces-
sary to resolve policy and regulatory issues.  A single package
could be made of all of these recommendations in the form of a
regional technology assessment.  As discussed in Chapter Five,  this
approach has many advantages and is highly recommended.  However,
it is felt that additional work in any one of these areas would
be useful by itself.

6.1       Forecasting

          The lignite use forecast used in this study is very rud-
imentary.   It consists of a very broad envelope, rather than a
set of more realistic scenarios.  When Congress passes national
energy policy legislation, it should be possible to construct
a series of scenarios reflecting the basic directions of this
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RADIAN
 very important piece of legislation.   These should compare possible
 implementation strategies not yet decided upon.   They should also
 display the consequences of exercising the state's role in imple-
 menting these policies.

           A significant  flaw in the present forecast is its fail-
 ure to include industrial demand.   This component could be added
 through the use of economic forecasts  made by the Texas Water
 Development Board, as well as OBERS projections.   The newly up-
 dated Texas Input-Output Economic Model,  available at Radian,  can
 be used to trace the economic effects  of different energy policy
 options as they determine lignite demand.

           A finer geographic perspective is also  needed.   Split-
 ting the forecast into river basin increments would increase its
 value for planning.   The development scenarios could also be keyed
 to the distribution and  quality of lignite within the basins.

           Finally, if the study is to  be extended across  the Gulf
 Coast resource region as a whole,  a better definition of the en-
 tire resource is needed.  This may prove difficult, since little
 drilling has been done in Louisiana, Arkansas, Alabama, and Mis-
 sissippi.   The last two  states have bituminous coal as well as
 lignite,  which makes their potential development  pattern more
 complex.

 6.2       Baseline Data  and Impact Analysis

           Every topic discussed in Chapters Three and Four will  bene-
 fit from a more thorough investigation.   Expanding to a regional
 scope will require extensive data-gathering.  Socioeconomic data
 needs are particularly pressing.  A much more exhaustive inven-
 tory of existing conditions and resources must be made before the
 extent and scale of growth management  needs can be assessed.
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Also, further effort is needed to identify ecologically sensitive
areas.  Since most of the land affected by Gulf Coast lignite de-
velopment is privately owned, a backlog of exploration and inven-
tory similar to that in the western states does not exist.   Use
of remote sensing imagery, consultation with local researchers
and wildlife managers, and some field reconnaissance are recom-
mended methods.

          Even in Texas, where geological exploration has been
extensive, not enough is known about ground water to identify
possible problems connected with mining.  The Surface Mining Con-
trol and Reclamation Act of 1977 requires determination of prob-
able hydrologic consequences as a condition for obtaining a min-
ing permit (Section 507(b)(ll)).  This information is the respon-
sibility of an "appropriate Federal or State agency."  Thus, the
need for further ground water hydrological study is immediate.

          A first step in pinning down this area would be an in-
depth survey of existing information.  Then problem zones could
be identified where more data must be gathered.  Existing mine
operations could also be studied with respect to their effect
on ground water movement.  Ground water quality impacts, such as
contamination from leached metals, long-term chloride and sulfate
buildup, and progressive acidification of buried pyrite-containing
overburden, should also be studied.  Both laboratory tests and
field observations could be employed.

          The potential for in-stream flow depletion also needs
further definition.  Models are being developed to help predict
the effects of water use on estuarine inflow, and relate them to
biotic needs.  These should be used as a means of comparing and
evaluating the effects of various state and federal-level policy
options for managing water use and supply.  In particular, the
potential to mitigate flow depletion impacts by controlled reser-
voir releases should be investigated.

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            While  there  appear  to be no major drawbacks to land
  reclamation,  much more specific information is needed.  To date,
  both the geographic  extent of mining and range of reclamation
  techniques has been  limited to some of the most favorable areas
  of Central and East  Texas.  More  information is needed about over-
  burden,  climate,  and potential land use options in South and East
  Texas.   In particular,  options exist for greatly improving wild-
  life habitat  through reclamation, at least in some areas.  If
  this opportunity is  to be exploited, appropriate techniques must
  be developed.  Comparative costs  of reclaiming land for various
  purposes should  be developed  and  keyed to intra-regional differ-
  ences.   The availability of plant materials, especially native
  species,  should  also be investigated.

  6.3       Developing National-Regional Problem Solving Strategies

            A basic method of comparing and evaluating the effects
  of federal policies  at the regional level is economic analysis.
  State and regional input-output models, or other analytical tools,
  can be used to generate quantitative predictions useful in plan-
  ning for a variety of  impacts.  Topics which could--and should--
  be evaluated  in  this way include:

            •   Alternative lignite  demand forecasts (reflecting
               national  energy  policy)

               Competition between  users for scarce water
               supplies  (under  various national water policy
               options)

               Secondary impacts of federal clean air policy,
               related to regional  lignite and coal development
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          Economic modeling could also be used to evaluate poli-
cies at the state level, not directly concerned with determining
the regional implications of federal decisions.  Among these more
local issues are water allocation to reduce inequities in distri-
bution.  Secondary impacts in other economic sectors could also
arise because of changes in labor availability and wage competi-
tion.  These would also bear investigation with an economic model.

          In Chapter Five, the point was made that a number of Fed-
eral environmental laws, taken together, constitute a very broad
mandate for land use planning and economic growth management.  An
in-depth analysis of this problem would doubtless bring to light
a number of difficulties that might otherwise not be foreseen.
Early recognition of what this planning mandate may mean at the
regional level can provide the basis for federal-state cooperation
to develop a workable strategy.  The following topics should be
investigated:

          •  What specific requirements are contained in the
             applicable Federal laws?

             What does the composite picture look like?  What
             relationships or conflicts exist between the sep-
             arate planning mandates?

          •  What additional factors, specific to the region,
             need to be included to avoid inequities and
             provide a realistic basis for actual problem-
             solving?

             What will the planning process cost the states?
             The Federal Government?
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          A major commitment to improving efficiency of energy
use has been made by the present administration.   The effect of
the transition from oil and gas to coal and lignite on energy
efficiency is therefore a topic of immediate interest.  It is
also one where substantial national-regional conflict could be
avoided by a thorough, analysis of the implications of federal
policy.  The relationships of different federal policies to each
other should also be considered.  It is the net effect of all
of these policies which will ultimately define the context for
regional efforts at energy management.   The forthcoming national
energy legislation, clean air policy, and national water policy
options will probably be the major factors to study.  In addi-
tion to projecting regional options as  early as possible, it will
be useful to study opportunities for energy conservation.  Exist-
ing drawbacks and impediments to conservation, co-generation, and
other forms of cooperative energy use through the transition per-
iod should be identified.  Promising approaches should be recom-
mended for support.

6.4       Developing State-Level Problem-Solying Strategies

          Among the most pressing lignite-related problems which
must be solved at the state level is that of water supply.  Sev-
eral options have been described in Chapter 5.  Comparative analy-
sis of their effectiveness, economic and environmental costs
would be a useful tool in planning—and obtaining support—for
future action.   The Texas Department of Water Resources has made
extensive investigations of such options as joint ground- and sur-
face-water management.  Other topics worth investigation are:

             Land use conflicts with respect to reservoir
             construction
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             Legal and regulatory options for state governments
             to promote water conservation and protect instream
             flows

             Possible state responses to national water policy-
             making

          States must also deal with the impacts of lignite de-
velopment on land use, as it affects non-point source water pollu-
tion.  For example, the scanty availability of funds for building
new sewage treatment systems in many growth communities appears
likely to promote scattered residential and commercial develop-
ment.  An investigation of the extent of such impacts, which fall
under the planning provisions of the Federal Water Pollution Con-
trol Act Amendments, would provide a basis for planning control
strategies.  An estimate of the appropriate timeframe available
for such planning, as well as its cost, would also be useful.

          Growth management is itself a critical need.  Not only
will it be necessary to define the extent of the problem, there
is a great need to identify all the many sources of state and
federal assistance available to affected communities.  Potential
problems could be broken out by areas—such as sewage treatment,
schools, water supply, and roads.  These could then be discussed
in terms of the entities responsible and the resources available
to them to deal with them.  An estimate of the time required and
the probability of success for obtaining assistance from various
quarters would be a valuable aid.  A "manual" based on this in-
vestigation would be of use both to communities and to industries
seeking to help communities cope with growth.  Since massive "boom
town" expansion is not envisioned, this effort could allow signi-
ficant numbers of communities to avoid the adverse effects which
can accompany unplanned, moderate growth.
                              208

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RADIAN
           A major deficiency of this study is the absence of air
 quality modeling studies.   Modeling can be used first to calculate
 ambient conditions in rural areas.   This will help determine the
 availability of PSD increments.   Using this baseline, it would be
 of interest to calculate the effect on allowable plant spacing
 of various PSD classification options.   In particular, the impact
 of re-zoning appropriate areas Class I and of re-zoning portions
 of the lignite region Class III needs to be assessed.  Modeling
 should be used to calculate, rather than estimate, the distances
 at which plume interactions could occur.   Also related to clean
 air policy would be an investigation of the potential for regula-
 tion of "new11 pollutants,  especially trace metals, to alter the
 relative economics of lignite versus imported coal.

           Finally, the impact of the problem of assigning strip-
 pable lignite to the surface or the mineral estate warrants fur-
 ther study.   First, the extent of such severed ownership should
 be determined.   This information is not presently available ex-
 cept in individual county  records.   Then, the proportion of such
 leases should be determined which expire or come up for renewal
 within the timeframe in which a mine built before 1985 could be
 expected to operate.   This information should provide a basis
 for evaluating the potential for a rise in lignite cost through
 lease renegotiation.
                               209

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BIBLIOGRAPHY
    210

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RADIAN
                          BIBLIOGRAPHY

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RADIAN
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RADIAN
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  MC-325    McKie, James W., "The Effects of the Proposals for
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                                213

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RADIAN
 ME-189    Meinig,  D.W. ,  Imperial  Texas, Austin,  Texas, University
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                               214

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                               215

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RADIAN
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                                             I
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                               217

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                                TECHNICAL REPORT DATA
                          (Please read Inunctions on the reverse before completing)
1. REPORT NO.
 EPA-600/7-78-003
     2.
                                 3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Environmental Overview of Texas Lignite
   Development
                                 5. REPORT DATE
                                 January 1978
                                 6. PERFORMING ORGANIZATION CODE
7.AUTHORS D.Harner, K.Holland, S.James, J.Lacy,
and J. Norton
                                 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Radian Corporation
8500 Shoal Creek Boulevard
Austin, Texas  78766
                                 10. PROGRAM ELEMENT NO.

                                 EHE624A
                                 11. CONTRACT/GRANT NO.

                                 68-02-2608, W.A. 6
12. SPONSORING AGENCY NAME AND ADDRESS
 EPA, Office of Research and Development
 Industrial Environmental Research Laboratory
 Research Triangle Park, NC  27711
                                 13. TYPE OF REPORT AND PERIOD COVERED
                                 Task Final; 3-11/77	
                                 14. SPONSORING AGENCY CODE
                                  EPA/600/13
15. SUPPLEMENTARY NOTES ffiRL-RTP

541-2815.
             officer is Roger P. Hansen, Mail Drop 63,  919/
16. ABSTRACT
           The report gives results of an investigation of possible effects of the devel-
opment of Texas lignite, forecast to the year 2000 and based on a 10- to 20-fold
increase of lignite utilization over 1976 levels. Lignite, a low-grade coal, is projec-
ted to provide an energy resource estimated to exceed proven oil and gas reserves of
the State of Texas.  Development of this resource will induce some major ecological,
social, and economic effects throughout the entire Gulf Coast region.  Secondary
attention is given to effects in the other Gulf Coast states. Particular attention is paid
to possible sociocultural impacts of development to largely rural communities, air
and water quality problems, land use and reclamation practices, and plant siting pro-
cedures to lessen adverse  effects of mine-mouth energy conversion facilities (lignite
is unsuitable for long distance transport). Recommendations are offered for improved
state/Federal standard setting, improved forecasting and data collection, and for a
regional technology assessment of lignite development in the Gulf Coast states of
Arkansas, Louisiana, Alabama, Mississippi, and Texas.
17.
                              KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
                                           b.lDENTIFIERS/OPEN ENDED TERMS
                                             c.  COSATI Field/Croup
 Pollution
 Lignite
 Energy
 Ecology
 Sociology
 Economic Analysis
Land Use
Reclamation
Plant Location
Pollution Control
Stationary Sources
Texas
Gulf Coast States
13B
21D,08G

06F
05K
05C
05A
18. DISTRIBUTION STATEMENT

 Unlimited
                     19. SECURITY CLASS (This Report I
                     Unclassified
                        21. NO. OF PAGES
                          235
                     20. SECURITY CLASS (TMspage)
                     Unclassified
                                             22. PRICE
EPA Form 2220-1 (9-73)

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