The City of Brackettville lies west of San Antonio, Texas, and just across the Mexican border. The population is 1,688, with all but 369 listed as a minority population. In 1992, Brackettville entered into an operating agreement with the Fort Clark Municipal Utility District (MUD) to construct a regional wastewater facility that would serve Brackettville and neighboring Fort Clark. The new wastewater facility featured a system that utilized oxidation ponds. Those ponds would discharge into the Las Moras Creek, which ran alongside the oxidation ponds. The original arrangement included an Operations and Maintenance Agreement making each entity responsible for 50% of the operations and maintenance costs. However, any major plant improvements would be based on flow volume for each entity.
In 2017, the Texas Commission of Environmental Quality (TCEQ) sent a Notice of Violation to the regional facility. TCEQ had determined that the current effluent being discharged from the plant and its oxidation ponds wasn’t meeting state discharge requirements. The system was informed that it would either have to upgrade the effluent from its ponds or provide a no-discharge system. The two cities agreed that Brackettville would apply to the US Department of Agriculture – Rural Development (USDA-RD) for a loan and grant under the USDA Colonias Funding. Brackettville requested a Preliminary Engineering Report from its engineer for the wastewater plant upgrades. It also wanted the document to address major issues with the city’s sewer collection and distribution system, production, and storage, all of which also had notices of violation from TCEQ.
The estimates surprised officials with Fort Clark MUD. The estimated project cost for just the wastewater treatment plant improvements came to about $1 million, but the added projects thrown in by Brackettville ballooned that estimate to more than $5 million. The majority of the total project cost of $5.54 million is being financed by a USDA-RD loan of $3.10 million and a USDA- RD grant of $2.41 million. But the loan meant Fort Clark MUD would be paying back much more than they anticipated. Fort Clark’s general manager and the Fort Clark MUD board balked at the plan and were prepared to pull out of the project entirely. But a lack of agreement would mean the shared wastewater system would continue to violate state regulations, which could lead to even more headaches.
Communities Unlimited (CU), the southern RCAP, was called in for assistance. Cesario Vela, Community Environmental Management Specialist with CU, began working with Brackettville and Fort Clark MUD to smooth out the issues that threatened the projects. He explained that based on the original Operations and Maintenance agreement, both entities would be responsible for the costs of the regional facility’s improvements. However, Brackettville would be the one responsible for their collection, distribution, production and storage improvements. Vela then initiated a rate analysis for both Brackettville and Fort Clark MUD, as required by the USDA Letter of Conditions. He used the prorated loan and grant disbursements for each entity and the loan repayment for each entity in determining what they would owe and what their utility rates would need to be to cover operational costs and loan repayment. Vela traveled to both locations to explain the results of the rate analysis, and he was able to calm the concerns of Fort Clark officials. Both parties then agreed to move forward with the project.
Communities Unlimited continued to work with the utility district to meet the Letter of Conditions. While this was going on, a USDA-RD representative contacted Communities Unlimited to do a site evaluation of Brackettville’s water and wastewater infrastructure. The federal agency wanted to decide whether the systems had the health and safety issues that would justify the USDA-RD funding. Communities Unlimited conducted the site evaluation and found that Brackettville’s systems actually had several potential health hazards. Many of the water lines in Brackettville were more than 50 years old and made of cast iron. Those pipes were tuberculated, meaning they had rusted and corroded inside, and several of the old lead joints for the pipes were leaking. The water system’s storage tanks also needed painting to prevent further decay. The pipe tuberculation made the system susceptible to bacteria creation and water-borne illnesses. The deteriorating lead joints threatened to leach lead into the water system. Also, many of the water valves had been paved over throughout the years, so they couldn’t be located or accessed. That meant city workers were making repairs to water breaks without shutting off the water at the valves first. With some of the water mains too close to sewer lines, the water line breaks created the possibility of cross-contamination. The city’s storage and booster pumping station facilities also were found to be providing the minimum pressure allowed. With all of the issues found, revisions needed to be made to the rate study.
A second analysis took place, and Communities Unlimited worked with officials from both cities and USDA to determine what rates would be needed to cover repairs for both Brackettville and Fort Clark MUD. Once the rate analysis was complete, the adjusted rates were taken to the entities for passage from their governing bodies. The tricky part was getting the higher rates through the Brackettville City Council. However, the rates were approved as presented by Communities Unlimited, and they took effect in October 2019. With a major part of the Letter of Conditions met, Vela continued to gather the information and paperwork necessary for the rest of the Letter of Conditions. Over the next several months, Communities Unlimited completed a variety of tasks, including gathering financial documents, conducting a Technical Managerial and Financial (TMF) assessment and providing photos, financial audits and reports.
Communities Unlimited also created an emergency response plan for the regional facility. The plan not only included information for the facility but also created set policies for customers who needed to contact the facility in emergency situations. The entities received word that all the conditions had been met, and they were able to move forward with the project in 2020. Bidding took place and has been accepted for the wastewater project for the entities’ regional utility.
Bids for Brackettville’s water project are on hold while a few remaining details are worked out. Once those are complete, construction can begin for both projects.
