The San Antonio Water System owns and operates the nation's largest recycled water distribution system, which is tied to several major water recycling centers and constructed as a “reuse loop” around almost the entire metropolitan area. In addition to providing recycled
water to commercial and industrial customers, the dual-use system also provides streamflow augmentation and environmental enhancement discharges to the San Antonio River and Salado Creek. If operated as planned, effluents from several facilities would be commingled before discharge to receiving
waters. Since effluent commingling is not allowed under current permits, SAWS began working with state and federal regulatory agencies in 2002 to develop an innovative, first-of-its-kind integrated municipal permit that would be one of the first issued in support of EPA's Watershed-Based Permitting
Policy. It would also support Texas State Water Plan goals for water reuse and provide SAWS with operational flexibility and system redundancy. Initially, state regulators were highly supportive. After four years of negotiations and permit development, the Texas Commission on Environmental
Quality (TCEQ) determined it could not implement EPA's Watershed-Based Permitting Policy because it could potentially lose significant revenues from Water Quality Assessment Fees. SAWS is currently awaiting issuance of standard permit renewals and will renew negotiations on an integrated permit
when these are received. The distribution system will not be operated as a “reuse loop” as planned. The structure of TPDES permits is among the many issues that Texas will have to address if the state intends to support effluent reuse.
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