Comal County to apply for $30M Clean Water SRF loan to protect recharge lands after hours of public support

The Comal County Commissioners Court voted Oct. 23 to move forward with an application to the Texas Water Development Board’s Clean Water State Revolving Fund (CWSRF) for a county Water Quality Protection Lands program, a step county staff and dozens of public speakers had urged.

Staff told the court that the Water Development Board invited Comal County to submit a full application for a $30,000,000 loan with up to $4,500,000 in principal forgiveness to acquire key parcels overlaying the Edwards and Trinity aquifer recharge zones. "The 1st thing that needs to be done is an intent to apply. It needs to be submitted by November 3," staff said, and described the full application deadline and the complexity of the required materials.

The court voted to: (a) authorize submittal of the intent to apply, (b) approve a professional services agreement with Moriarty & Associates LLC to prepare the full application (fee of $45,000), and (c) approve a budget amendment to fund the application work if the court proceeds. The motion carried after robust public comment and discussion of implementation.

Dozens of residents, conservation groups and municipal leaders urged the court to apply, citing drought risk, regional growth pressures, and the limited time window to conserve land. "The state's loan terms are extremely generous," Ryan Spencer of COMO Conservation told the court, noting the $4.5 million forgiveness amount and the county's top ranking on the project's priority list. Roxanna Dean of Comal Conservation said the county's proposal "ranked number 2 on the project priority list." Several landowners described wells drying up and urged swift action. Supporters argued that the loan could be leveraged with private and philanthropic funds to stretch county dollars.

Opponents and skeptical commenters cautioned that measurable recharge benefits are difficult to guarantee and raised concerns about long‑term costs to taxpayers. One commenter, reading a submission from Larry Hall of the GCT Groundwater Conservation District, warned that documented recharge results are limited and that county costs and maintenance would be ongoing.

Commissioners debated technical and fiscal questions: staff estimated a repayment cost a little below 3% and about $1.3 million per year at current assumptions, with up to $4.5 million in forgiveness; commissioners also noted implementation, rule‑making, and selection risks. Staff said the county could return an offer of funding after the Water Development Board issues a final funding determination late in the year. The court approved the motions to pursue the application and fund the application preparation work.