Environmental Aspects of the SysOps Permit

The System Operation (SysOps) Permit has a variety of environmental aspects that allow BRA to utilize the SysOps Permit without impacting environmental flows in the Brazos basin.

In general, the SysOps Permit is subject to the Senate Bill 3 (SB 3) Environmental Flow Standards for the Brazos basin. The Brazos basin Environmental Flow Standards can be found in Section 298.480 of Title 30 of the Texas Administrative Code.

The SysOps Permit contains Environmental Flow Conditions, which are detailed in the Water Management Plan(WMP) and represent how the use of the water authorized by the SysOps Permit is constrained by SB 3 Environmental Flow Standards. These conditions limit SysOps diversions according to the subsistence, base, and pulse flow standards associated with the applicable hydrologic and seasonal conditions at the applicable Measurement Point relative to the diversion location. The Environmental Flow Conditions for the SysOps Permit can be found in Chapter IV of the 2018 Conformed Water Management Plan.

Additionally, the BRA is required submit to Texas Commission on Environmental Quality (TCEQ) an annual Environmental Flows Achievement Report, which demonstrates how BRA’s operations do not impact achievement of Environmental Flow Standards.

BRA has also undertaken a variety of voluntary measurements which seek to benefit downstream environmental flow needs including: (1) a dedication of 6,035 ac-ft of water to the Texas Parks and Wildlife Department (TPWD) for instream uses, (2) continuing minimum flow releases, formally associated with Possum Kingdom Lake’s Federal Energy Regulatory Commission (FERC) license, and (3) voluntary minimum flow releases from Lakes Granbury and Granger to benefit downstream environmental needs.

Additional information about BRA’s other environmental initiatives, not directly related to the SysOps Permit can be found at BRA’s Environmental Services webpage.

Environmental Flows Achievement Reports

As detailed in Chapter IV of the WMP, BRA shall generate and submit to the TCEQ an Environmental Flows Achievement Report once per year. In this Report, BRA will provide, in a format approved by TCEQ’s Executive Director, an assessment of storage and diversions of water under the SysOps Permit and WMP during the previous one-year period, from November 1 to October 31, to demonstrate that BRA’s operations do not impact achievement of the adopted Environmental Flow Standards.

Below are links to the Environmental Flows Achievement Reports submitted to TCEQ from the years 2018 through 2025:

Texas Parks and Wildlife Department (TPWD) Water Dedication

BRA Mainstem System

In 2011, by Memorandum of Understanding with TPWD, BRA agreed to dedicate up to 100,000 acre-feet per year of non-firm water supply (an equivalent of 13,400 acre-feet of firm yield) from the SysOps Permit to the Texas Water Trust, with TPWD acting as trustee for the dedication.

In 2014, the Memorandum of Understanding was amended to affirm that BRA would prepare the water right amendment application necessary to effectuate the dedication in BRA’s first WMP Update. In 2018, BRA received final authorization to utilize the SysOps Permit and Conformed WMP. However, the total permitted amount had been greatly reduced from the original application requested amount. Consequentially, the total amount of firm supply to be dedicated to TPWD was reduced, alike with all other requests for SysOps supplied water, to 6,035 acre-feet per year.

In 2025, BRA and TPWD entered into a Water Dedication Agreement wherein BRA agrees to make available to TPWD, for instream use, 6,035 acre-feet per year, including transportation losses, along the mainstem of the Brazos River downstream of Possum Kingdom Lake to the Gulf.

Under Texas law, TCEQ cannot issue a new water right solely for instream uses, but TCEQ may amend an existing water right to authorize instream flow uses. Within BRA’s 2026 WMP amendment application, BRA is requesting that instream use be added as an authorized purpose to the SysOps Permit and that the dedication be included in all of BRA’s Water Availability Models and BRA’s Water Accounting Plan. Upon approval and final authorization of the 2026 WMP, to accommodate the dedication, BRA will submit minor amendment applications to add instream use as an authorized purpose to BRA’s Possum Kingdom Lake, Granbury Lake, and Whitney Lake water rights. TPWD may only begin accessing the dedicated water after all of these amendment applications have been authorized by the TCEQ.

In addition, BRA and TPWD agreed this contractual dedication would not be placed in the Texas Water Trust. Instead, BRA and TPWD agreed this dedication shall last in perpetuity; however, Basin conditions shall be reevaluated every thirty-five (35) years to determine if the dedication amount should be modified based on changes to BRA’s System.

Minimum Flow Releases

The Possum Kingdom Lake minimum flow releases were developed during the Federal Energy Regulatory Commission (FERC) relicensing of the project in the late 1980s to early 1990s. The BRA’s surrender of this FERC license was effective on March 12, 2014, after hydropower was decommissioned at Possum Kingdom Lake. However, BRA committed in SysOps Permit and 2018 Conformed WMP to continuing the minimum flow requirements that were set out in the FERC license. Details regarding these minimum flow requirements can be found in Chapter IV of the 2018 Conformed Water Management Plan.

Low flow releases are normally maintained at both Lake Granger and Lake Granbury, although no regulatory requirements exist for these releases. At Lake Granbury a mean daily release of up to 25 cfs is used to benefit downstream instream needs. The release from Lake Granger is usually held at about 4 cfs for downstream domestic and livestock water needs as detailed in Chapter IV of the 2018 Conformed Water Management Plan.