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Comal County moves to apply for $30M Clean Water SRF loan to buy and protect recharge-zone lands; public debate highlights benefits and uncertainties

October 23, 2025 | Comal County, Texas


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Comal County moves to apply for $30M Clean Water SRF loan to buy and protect recharge-zone lands; public debate highlights benefits and uncertainties
Comal County Commissioners on Oct. 23 authorized staff to submit an intent to apply to the Texas Water Development Board (TWDB) for a Clean Water State Revolving Fund (SRF) loan to support a proposed Comal County Water Quality Protection Lands Program. The court also approved contracting with Moriarty & Associates LLC to prepare the county’s full application and approved a line-item transfer to pay the consultant’s fee.

County staff told the court that the TWDB invited Comal County to submit a full application for a program previously advanced by the county and ranked No. 2 on the TWDB project priority list. The invitation cited a potential $30,000,000 loan with as much as $4,500,000 in principal forgiveness. Staff said the TWDB requires an intent to apply by Nov. 3 and the full application by Dec. 4. The county’s consulting proposal to prepare the full application was listed at $45,000; Moriarty previously prepared the initial program information form for a fee of $4,500 and has worked with the county since 2021.

The commissioners voted to: a) submit the intent to apply and authorize the county judge to sign, b) enter a letter agreement with Moriarty & Associates LLC for preparation of the full application, and c) transfer funds to pay the consultant fee from contingency/professional services. Commissioner Crownover moved the consolidated action; Commissioner Leacock seconded; the motions were approved by voice vote.

Public comment was lengthy and largely in favor of applying. Dozens of residents, landowners, conservation groups and municipal officials urged the court to seize the TWDB offer as a rare opportunity to fund land acquisitions or conservation easements in key recharge and watershed areas. Speakers and organizations in support included Lyndon Sisk (resident), Roxanna Dean (president, COMO Conservation board), Ryan Spencer (executive director, COMO Conservation), Marjessica Brown (Great Springs Project), Lisa Swint (mayor of Garden Ridge), Connie Krause (landowner), and a number of landowners and nonprofit conservation representatives who described local conservation needs, heritage ranches, and water-security concerns. Many speakers emphasized that conservation projects leverage outside funds and protect springs, rivers and regional water supplies.

Not all public comments were unqualified. A commenter identified in the record as Larry Hull raised technical and fiscal concerns, urging the court to seek verifiable data showing that land purchase and conservation easements will produce measurable recharge benefits. He argued that recharge rates in the Trinity Aquifer are variable and that land acquisition alone does not guarantee additional aquifer recharge; he recommended careful selection, additional technical work, and clearer return-on-investment measures before committing public funds. County staff and supporters, including Commissioner Webb, acknowledged those uncertainties but said the TWDB process includes technical screening and that the county needs to act now to access generous loan terms made available by the state.

County staff noted the program’s history: Moriarty prepared the initial project information form in 2021 and the county has continued to submit PIFs annually. The staff presentation recalled earlier local actions, including a strategic plan and parks/open-space plan, and said Moriarty’s scope for the full application would include significant work to compile documentation the TWDB requires.

Commissioner Webb gave a lengthy overview of the county’s long-term development trends and fiscal constraints, describing the SRF offer as a defensive measure to protect priority lands against rapid development. Webb estimated a county repayment obligation in the order of about $1.3 million per year under current assumptions (staff noted interest-rate sensitivities and that actual cost estimates may change), and said the county must draft implementable rules before accepting funds. Webb also framed the vote as a step in a multi-stage process: submittal of the intent, full application, TWDB letter of funding determination, and a future public decision on whether to accept funding and enter acquisition or easement transactions.

Supporters in the public record stressed that TWDB’s loan terms include principal forgiveness and that federal, state and private partners often match SRF loans to finance conservation projects; several speakers said $30 million could be leveraged with other funds to protect considerably more acreage than the loan amount alone would suggest.

The court’s action at the Oct. 23 meeting authorizes the county to pursue the next steps required by TWDB. If the application advances, the county will return to commissioners with a funding determination and proposed implementation plan, at which point the court would vote again on whether to accept the loan and on specific property acquisitions or easements.

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