Dear Board of Directors of the LSGCD,
I respectfully disagree with the Lone Star GCD stated position regarding subsidence.
Subsidence should be a determining metric. As it currently stands, the proposed metric of limiting subsidence to an average 1 foot maximum as of the year 2080 is too much subsidence for many low lying structures.
Documented environmental impacts of subsidence include flooding, sinkholes, and aquifer depletion. Subsidence of 1 foot will result in repeated flooding of homes and cars, and cracking foundations and streets.
Insurance companies set home and car insurance rates based on risks. Higher rates for using surface water are much less than the costs of increased insurance rates and the cost of repairs due to flooding damage. If risks of flooding and cracked foundations from subsidence are assessed as too high, private insurance companies will withdraw from the local market. This will affect people's access to mortgages, home prices will fall, and the property tax rate will likely need to rise to offset lost tax revenues due to lower home valuations.
FEMA is not an alternative to private insurance in this case if private insurers were to withdraw. LSGCD should note that FEMA does not cover damage from land subsidence. Per FEMA official policy:
"11. Section V. Exclusions, C. Coverage has been clarified to pay for losses from land subsidence under certain circumstances. Subsidence of land along a lake shore or similar body of water which results from the erosion or undermining of the shoreline caused by waves or currents of water exceeding cyclical levels that result in a flood continues to be covered. All other land subsidence is now excluded."
As my former insurance company USAA told me that they would not have insured me for hurricane damage if I had purchased 10 miles closer to the coast, I am fairly certain that they would not insure me if I had a more measurable and predictable risk such as that from subsidence due to ground water extraction. It is fairly straight forward to model subsidence impacts in a watershed.
From a simple pocket book perspective, it is much less costly to use surface water and reduce subsidence rates, than to pay higher insurance rates and property tax, have my home value decline, and likely have to pay for flooding repairs. My street in The Woodlands has not flooded, and I would like to keep it that way.
Please reconsider your stated position, and take our pocketbooks and long term economics into account.