After months of work by a multi-division team of employees, Texas Parks and Wildlife Department has put its official comments on record in a letter to the Texas Water Development Board concerning recently completed regional water plans. “Our bottom line comment is that the plans fall short of achieving the stated goals of the 1997 water bill: to plan for future water needs of the state while protecting natural resources,” said Tom Harvey of TPW communications divison. “TPW said the 16 regional water planning districts focused mainly on the first part of that goal, while largely ignoring the second part.” TPW did offer some credit where it was due, praising the districts for defining water needs and identifying water development strategies to meet them. Below are summaries of key concerns with the regional water plans. ‘ The plans do not protect all recognized beneficial uses of water, including environmental uses such as instream flows. ‘ Few planning districts participated in efforts to bring all state and federal resource agencies together in special “clearing house” workshops, even though every effort was made to facilitate their use. As a result, some regional plans may not meet state and federal regulatory requirements. ‘ The plans do not contain appropriate conservation measures, such as low per capita use goals (120-150 MDG) for municipalities. It is unacceptable and unrealistic for Texans to continue to waste water. ‘ The plans should clarify Drought of Record conditions, such as timing for when measures would take effect. It is also not realistic to assume 100 percent of demand should be met during a record drought. ‘ The plans do not adequately describe natural resources. Readily available data such as criteria for designation of ecologically unique stream segments, the TPW Wildlife Diversity Program database, etc., were largely ignored. ‘ Existing water supplies, the most economically and environmentally responsible alternatives, should be used fully and efficiently before considering new supplies. Instead, many plans amount to a wish list of new development projects. ‘ Only Region H (Houston area) recommended unique ecological river and stream segments. Most others said they were unclear on the private property and tax roll implications here, even though the water bill neither states nor implies property rights limitations.