Until these fish kills are prevented TPWD will not be stocking Bass or Red Fish in Lake Fairfield.

A TCEQ preliminary decision on the Luminant Generating Company application for continued waste water discharges has been received. TPWD had comment on the original application last November, but TCEQ chose to ignore that comment in their preliminary decision. This preliminary decision permits LGC to continue operating the existing two units plus adding a third later. TPWD feels just operation of the current units without lake nutrient control has resulted in the past fish kills. It is my opinion TCEQ's preliminary decision needs fisherman's comments. I have done so formally, and anticipate this will result in a public hearing where we fisherman can add our input. It is clearly possible to stop these fish kills by controlling the lake nutrient levels, similar power plant lake operations at Calavaras and Braunig have not resulted in fish kills of similar magnitude. My comment has requested LGC must get control of the lake nutrient levels and replace the fish their past practiced have killed. I requested a hearing on a Saturday so we can get there without losing a work day. I can supply PDF files of my comment letter, TPWD comment letter, the TCEQ preliminary decision, and LGC application to all interested. If you want this information send me your email address by PM, please add your phone number if you are willing to be at that comment hearing.

So long as they get control of the nutrients in the lake I am not opposed to even a third unit operation. If the current operating method is not changed and a third unit is brought on line it is my opinion there could be fish kills in the dead of the winter.

bump

A TCEQ hearing request coupled with your comment submissions is needed ASAP. After you have made up your mind you can go to the website link below to add you comment and request hearing participation.
The comment website below collects your full name, address, and phone number, the TCEQ ID number (WQ0001309000), you need to provide why the permit comment is important to you, and asks for your position on that ID number item. Your comment needs be requesting a hearing on TCEQ preliminary decision.
Your reply information will get a notice of a hearing. Your preamble needs to read something like this:
Office of the Chief Clerk (MC 105)
Texas Commission on Environmental Quality
P.O. Box 13087
Austin, Texas 78711-3087

Re: TCEQ Wastewater Discharge Permit Number WQ0001309000 Big Brown Power Company LLC and Luminant Generation Company LLC. Also listed as TPDES Permit No. 00001309000

Four key points to include in your own words if you agree:
1. Calavaras and Braunig, lakes which are much further south and west of Fairfield also serve as power plant cooling and public recreation lakes and have even experienced worse drought conditions without suffering similar decimating fish kills. Presumably having low enough nutrient levels alone is accomplishing this. A qualified biologist would need to name the nutrient and/or oxygen quantity addition needed to offset the natural dissolved oxygen low swing events and prevent killing more fish. The extreme tested experiences at Calavarus and Braunig and the early life of Lake Fairfield all prove power plant lakes need not annually kill most of the aquatic life.
2. Stop the Lake Fairfield fish kills! LGC's current lake composition management system is causing this fish killing problem, therefore LGC needs a waste water permit structured to make and manage the necessary changes. LGC needs to prevent these fish killing low oxygen swings. TPWD believes nutrient addition control will prevent these fish killing DO low swings and suggests a natural treatment method. Another source of low nutrient make up water could also be sought. A more costly lake blow down system or a man-made oxygen addition might also suffice, but would have to be 100% dependable. There may be other methods, but some combination of the above has worked at Calavarus and Braunig and the early life of Lake Fairfield as well.
3. We laymen understand the Diural Dissolved Oxygen (DO) level should be managed to not drop below what TPWD specialist should affirm is the minimum level. LGC together with TPWD needs to decide what the exact minimum required Dissolved Oxygen needs to be. LGC needs to find a solution and afford the changes. Then LGC needs to design and build a dependable system that gets it done. TPWD mentions both 3 mg/l and 5 mg/l DO level in their comment letter.
4. LGC's lack of nutrient control resulted in what TPWD values as $6,200,000 worth of dead fish stock. After the nutrient and/or oxygen addition is under control LGC needs to replace that dead stock in as near a size and count as possible. To restore the Fairfield lake jewel as quickly as practical it needs to be restocked with a significant amount of adult size fish. Aquatic food farms already raise Red Drum, Large Mouth Bass, Catfish, and the various pan fish species that can all be purchased.

If you have seen enough information, here or in the attachments and you agree then you need to file your own comments something like the above here: (you will need to fill in the TCEQ number WQ0001309000) and make you desires and requirements known here. http://www10.tceq.state.tx.us/epic/ecmnts/index.cfm?fuseaction=per.p3,

Be sure to put in text in your comment something like this: Barring an acceptable Luminant Generating Company rewrite of this permit application and a subsequent acceptable TCEQ decision I am requesting a contested case hearing near Fairfield with TPWD staff in presence with a meeting period spanning over at least one Saturday so the impacted sportsmen can attend.

Until 10 days ago I thought LGC owned the lake, they do not it is a public water body. LGC is permitted to use it as if it were a once through use, which is fiction in reality.

They recirculate the lake and with the current natural inflow LGC heat discharge from just the current two units evaporates all the natural inflow plus needs more from the Trinity River.

There is TPWD scientist proof what is happening in this lake. Here is part of what TPWD sent to the TCEQ:

�In response to the fish kills, TPWD staff intensified their investigations and water quality monitoring, and began coordinating with TCEQ Surface Water Quality Monitoring (SWQM) staff in Waco, who initiated quarterly monitoring at Fairfield Lake in November 2005. TPWD�s monitoring efforts included special studies on instantaneous and diel dissolved oxygen prior to and during fish kills (technical report:
http://www.tpwd.state.tx.us/publications/pwdpubs/media/pwd_rp_v3400_1565a.pdf). In addition to the recent special studies, TPWD Inland Fisheries routinely surveys the fish community (survey report:
http://www.tpwd.state.tx.us/publications/pwdpubs/lake_survey/pwd_rp_t3200_1290/).

Both fish kill and fishery survey data support that legal size game fish are nearly absent from the fish community and forage species such as bluegill have been impacted as well (Figure 5 - 10). The fishery survey data shows a clear decline in fish abundance and size distribution from 2000 � 2011. The impact has been so great that on September 21, 2011, TPWD suspended fish stockings until water quality improves (news release: http://www.tpwd.state.tx.us/newsmedia/releases/?req=20110921c).

Fairfield Lake and the nearby Trinity River are listed as concerns for high nutrient levels in TCEQ�s 2010 Water Quality Inventory. Both water bodies have phosphorus and chlorophyll-a means that exceed the TCEQ screening levels for nutrient concerns (Tables 2 and 3). The chlorophyll-a values at Fairfield Lake (Figure 11) suggest it is one of the most eutrophic reservoirs in Texas. TPWD and TCEQ data indicate high nutrient levels, in combination with the higher water temperatures from power plant discharges, fuel algal blooms in the reservoir. These algal blooms can produce extreme swings in daily dissolved oxygen concentrations, eventually leading to a drastic drop in dissolved oxygen. Diel dissolved oxygen data collected as part of fish kill investigations in 2009, 2010 and 2011 show extreme daily swings in dissolved oxygen and extended periods when dissolved oxygen is below concentrations supportive of aquatic life (Figure 12). Over time there also appears to be a trend of low dissolved oxygen and fish kills occurring earlier each subsequent year, and daily swings becoming more extreme.�

Found a way to link into the page where we can down load both the TPWD Letter and my comment letter.

The TPWD letter is the the hot link on the bottom of this page, the hot link to
my letter link is above that.

Why dont they install an aireator system like Grapevine Lake. That made a lot of difference in that lake.

Bubblers might be some or all the solution that is needed, especially if they add that third unit. the bubbler might have to be pretty massive by comparision to Grapevine. The nutrient inspired algal bloom is the cause of the low overnight oxygen conditions. Bringing LGC to recognize and deal with this issue is our challenge, if we want Fairfield to ever become the jewel it once was.

That is going to take public input and demands to run that lake properly. Please file comment and hearing request from this:

A TCEQ hearing request coupled with your comment submissions is needed ASAP. After you have made up your mind you can go to the website link below to add you comment and request hearing participation.
The comment website below collects your full name, address, and phone number, the TCEQ ID number (WQ0001309000), you need to provide why the permit comment is important to you, and asks for your position on that ID number item. After If you have seen enough information, here or in the attachments and you agree then you need to file your own comments something like the above here: (you will need to fill in the TCEQ number WQ0001309000) and make you desires and requirements known here. http://www10.tceq.state.tx.us/epic/ecmnts/index.cfm?fuseaction=per.p3,
Your comment needs be requesting a hearing on TCEQ preliminary decision. Be sure to put in text in your comment something like this: Barring an acceptable Luminant Generating Company rewrite of this permit application and a subsequent acceptable TCEQ decision I am requesting a contested case hearing near Fairfield with TPWD staff in presence with a meeting period spanning over at least one Saturday so the impacted sportsmen can attend.
Four key points to include in your own words if you agree:
1. Calavaras and Braunig, lakes which are much further south and west of Fairfield also serve as power plant cooling and public recreation lakes and have even experienced worse drought conditions without suffering similar decimating fish kills. Presumably having low enough nutrient levels alone is accomplishing this. A qualified biologist would need to name the nutrient and/or oxygen quantity addition needed to offset the natural dissolved oxygen low swing events and prevent killing more fish. The extreme tested experiences at Calavarus and Braunig and the early life of Lake Fairfield all prove power plant lakes need not annually kill most of the aquatic life.
2. Stop the Lake Fairfield fish kills! LGC's current lake composition management system is causing this fish killing problem, therefore LGC needs a waste water permit structured to make and manage the necessary changes. LGC needs to prevent these fish killing low oxygen swings. TPWD believes nutrient addition control will prevent these fish killing DO low swings and suggests a natural treatment method. Another source of low nutrient make up water could also be sought. A more costly lake blow down system or a man-made oxygen addition might also suffice, but would have to be 100% dependable. There may be other methods, but some combination of the above has worked at Calavarus and Braunig and the early life of Lake Fairfield as well.
3. We laymen understand the Diural Dissolved Oxygen (DO) level should be managed to not drop below what TPWD specialist should affirm is the minimum level. LGC together with TPWD needs to decide what the exact minimum required Dissolved Oxygen needs to be. LGC needs to find a solution and afford the changes. Then LGC needs to design and build a dependable system that gets it done. TPWD mentions both 3 mg/l and 5 mg/l DO level in their comment letter.
4. LGC's lack of nutrient control resulted in what TPWD values as $6,200,000 worth of dead fish stock. After the nutrient and/or oxygen addition is under control LGC needs to replace that dead stock in as near a size and count as possible. To restore the Fairfield lake jewel as quickly as practical it needs to be restocked with a significant amount of adult size fish. Aquatic food farms already raise Red Drum, Large Mouth Bass, Catfish, and the various pan fish species that can all be purchased.

Until 10 days ago I thought LGC owned the lake, they do not it is a public water body. LGC is permitted to use it as if it were a once through use, which is fiction in reality.

They recirculate the lake and with the current natural inflow LGC heat discharge from just the current two units evaporates all the natural inflow plus needs more from the Trinity River.

There is TPWD scientist proof of what is happening in this lake when the fish died. The running comment inputs are found here. The full TPWD to TCEQ letter hot link for the Ross letter hot link on the bottom of this page, is this one Comment - Written the hot link to my Hearing Request is above that. Here is what I think summarizes the most important part of what TPWD sent to the TCEQ:

�In response to the fish kills, TPWD staff intensified their investigations and water quality monitoring, and began coordinating with TCEQ Surface Water Quality Monitoring (SWQM) staff in Waco, who initiated quarterly monitoring at Fairfield Lake in November 2005. TPWD�s monitoring efforts included special studies on instantaneous and diel dissolved oxygen prior to and during fish kills (technical report:
http://www.tpwd.state.tx.us/publications/pwdpubs/media/pwd_rp_v3400_1565a.pdf). In addition to the recent special studies, TPWD Inland Fisheries routinely surveys the fish community (survey report:
http://www.tpwd.state.tx.us/publications/pwdpubs/lake_survey/pwd_rp_t3200_1290/).

Both fish kill and fishery survey data support that legal size game fish are nearly absent from the fish community and forage species such as bluegill have been impacted as well (Figure 5 - 10). The fishery survey data shows a clear decline in fish abundance and size distribution from 2000 � 2011. The impact has been so great that on September 21, 2011, TPWD suspended fish stockings until water quality improves (news release: http://www.tpwd.state.tx.us/newsmedia/releases/?req=20110921c).

Fairfield Lake and the nearby Trinity River are listed as concerns for high nutrient levels in TCEQ�s 2010 Water Quality Inventory. Both water bodies have phosphorus and chlorophyll-a means that exceed the TCEQ screening levels for nutrient concerns (Tables 2 and 3). The chlorophyll-a values at Fairfield Lake (Figure 11) suggest it is one of the most eutrophic reservoirs in Texas. TPWD and TCEQ data indicate high nutrient levels, in combination with the higher water temperatures from power plant discharges, fuel algal blooms in the reservoir. These algal blooms can produce extreme swings in daily dissolved oxygen concentrations, eventually leading to a drastic drop in dissolved oxygen. Diel dissolved oxygen data collected as part of fish kill investigations in 2009, 2010 and 2011 show extreme daily swings in dissolved oxygen and extended periods when dissolved oxygen is below concentrations supportive of aquatic life (Figure 12). Over time there also appears to be a trend of low dissolved oxygen and fish kills occurring earlier

Two days left to file comments here is what you need to know and thoughts for your comment:

A TCEQ hearing request coupled with your comment submissions is needed ASAP. After you have made up your mind you can go to the website link below to add you comment and request hearing participation.
The comment website below collects your full name, address, and phone number, the TCEQ ID number (WQ0001309000), you need to provide why the permit comment is important to you, and asks for your position on that ID number item. Your comment needs be requesting a hearing on TCEQ preliminary decision.
Your reply information will get a notice of a hearing. Your preamble needs to read something like this:
Office of the Chief Clerk (MC 105)
Texas Commission on Environmental Quality
P.O. Box 13087
Austin, Texas 78711-3087

Re: TCEQ Wastewater Discharge Permit Number WQ0001309000 Big Brown Power Company LLC and Luminant Generation Company LLC. Also listed as TPDES Permit No. 00001309000

Four key points to include in your own words if you agree:
1. Calavaras and Braunig, lakes which are much further south and west of Fairfield also serve as power plant cooling and public recreation lakes and have even experienced worse drought conditions without suffering similar decimating fish kills. Presumably having low enough nutrient levels alone is accomplishing this. A qualified biologist would need to name the nutrient and/or oxygen quantity addition needed to offset the natural dissolved oxygen low swing events and prevent killing more fish. The extreme tested experiences at Calavarus and Braunig and the early life of Lake Fairfield all prove power plant lakes need not annually kill most of the aquatic life.
2. Stop the Lake Fairfield fish kills! LGC's current lake composition management system is causing this fish killing problem, therefore LGC needs a waste water permit structured to make and manage the necessary changes. LGC needs to prevent these fish killing low oxygen swings. TPWD believes nutrient addition control will prevent these fish killing DO low swings and suggests a natural treatment method. Another source of low nutrient make up water could also be sought. A more costly lake blow down system or a man-made oxygen addition might also suffice, but would have to be 100% dependable. There may be other methods, but some combination of the above has worked at Calavarus and Braunig and the early life of Lake Fairfield as well.
3. We laymen understand the Diural Dissolved Oxygen (DO) level should be managed to not drop below what TPWD specialist should affirm is the minimum level. LGC together with TPWD needs to decide what the exact minimum required Dissolved Oxygen needs to be. LGC needs to find a solution and afford the changes. Then LGC needs to design and build a dependable system that gets it done. TPWD mentions both 3 mg/l and 5 mg/l DO level in their comment letter.
4. LGC's lack of nutrient control resulted in what TPWD values as $6,200,000 worth of dead fish stock. After the nutrient and/or oxygen addition is under control LGC needs to replace that dead stock in as near a size and count as possible. To restore the Fairfield lake jewel as quickly as practical it needs to be restocked with a significant amount of adult size fish. Aquatic food farms already raise Red Drum, Large Mouth Bass, Catfish, and the various pan fish species that can all be purchased.

If you have seen enough information, here or in the attachments and you agree then you need to file your own comments something like the above here: (you will need to fill in the TCEQ number WQ0001309000) and make you desires and requirements known here. http://www10.tceq.state.tx.us/epic/ecmnts/index.cfm?fuseaction=per.p3,

Be sure to put in text in your comment something like this: Barring an acceptable Luminant Generating Company rewrite of this permit application and a subsequent acceptable TCEQ decision I am requesting a contested case hearing near Fairfield with TPWD staff in presence with a meeting period spanning over at least one Saturday so the impacted sportsmen can attend.

Until 10 days ago I thought LGC owned the lake, they do not it is a public water body. LGC is permitted to use it as if it were a once through use, which is fiction in reality.

They recirculate the lake and with the current natural inflow LGC heat discharge from just the current two units evaporates all the natural inflow plus needs more from the Trinity River.

There is TPWD scientist proof what is happening in this lake. Here is part of what TPWD sent to the TCEQ:

�In response to the fish kills, TPWD staff intensified their investigations and water quality monitoring, and began coordinating with TCEQ Surface Water Quality Monitoring (SWQM) staff in Waco, who initiated quarterly monitoring at Fairfield Lake in November 2005. TPWD�s monitoring efforts included special studies on instantaneous and diel dissolved oxygen prior to and during fish kills (technical report:
http://www.tpwd.state.tx.us/publications/pwdpubs/media/pwd_rp_v3400_1565a.pdf). In addition to the recent special studies, TPWD Inland Fisheries routinely surveys the fish community (survey report:
http://www.tpwd.state.tx.us/publications/pwdpubs/lake_survey/pwd_rp_t3200_1290/).

Both fish kill and fishery survey data support that legal size game fish are nearly absent from the fish community and forage species such as bluegill have been impacted as well (Figure 5 - 10). The fishery survey data shows a clear decline in fish abundance and size distribution from 2000 � 2011. The impact has been so great that on September 21, 2011, TPWD suspended fish stockings until water quality improves (news release: http://www.tpwd.state.tx.us/newsmedia/releases/?req=20110921c).

Fairfield Lake and the nearby Trinity River are listed as concerns for high nutrient levels in TCEQ�s 2010 Water Quality Inventory. Both water bodies have phosphorus and chlorophyll-a means that exceed the TCEQ screening levels for nutrient concerns (Tables 2 and 3). The chlorophyll-a values at Fairfield Lake (Figure 11) suggest it is one of the most eutrophic reservoirs in Texas. TPWD and TCEQ data indicate high nutrient levels, in combination with the higher water temperatures from power plant discharges, fuel algal blooms in the reservoir. These algal blooms can produce extreme swings in daily dissolved oxygen concentrations, eventually leading to a drastic drop in dissolved oxygen. Diel dissolved oxygen data collected as part of fish kill investigations in 2009, 2010 and 2011 show extreme daily swings in dissolved oxygen and extended periods when dissolved oxygen is below concentrations supportive of aquatic life (Figure 12). Over time there also appears to be a trend of low dissolved oxygen and fish kills occurring earlier each subsequent year, and daily swings becoming more extreme.�

My addendum comment filed for ways to eliminate the massive Lake Fairfield Fish Kills

I looked into when we know LGC was publicly informed of TPWD fish kill findings. As a result I filed the attached addendum to my TCEQ comments this evening.

I hope LGC can prepare and operate an acceptable key parameter measuring and control system such that TPWD can agree with a defined particular physical or biochemical parameters for the necessary water quality. So as soon as practical TPWD feels comfortable resuming Lake Fairfield fish stocking and not have to wait several years of no fish kills as a practical demonstration that habitat conditions are suitable to resume fish stocking.

Addendum to my prior comments:
1. TPWD had been communicating publicly about the cause of these recurring Lake Fairfield kills for years. TPWD issued press releases in 2009, 2010, and 2011 links provided below publically describe TPWD findings for the Lake Fairfield kills. These releases provide a lot of background information, history of fish kills, facts and numbers about fish kills, explanations of things like low dissolved oxygen and Trinity River make-up water and the nutrients in river water makeup.
http://www.tpwd.state.tx.us/newsmedia/re...earch=Fairfield, http://www.tpwd.state.tx.us/newsmedia/re...earch=Fairfield, http://www.tpwd.state.tx.us/newsmedia/re...arch=Fairfield.)
Of particular note and quoting with Bolding and Italics where content is thought to be significant from the 2009 TPWD press release:

�Anglers fishing the lake the morning of September 13th noticed the dead fish and notified the TPWD 24-hour Communication Center at (512) 389-4848. Unlike previous kills, notification was received early enough that TPWD personnel were able to get to the scene while fish were still dying. This allowed them to collect fish that were stressed but not yet dead and take water samples in several areas of the kill.

Main locations of dead fish were along the shoreline of a cove immediately northwest of the dam to the spillway and in the cove south of the dam, but also extending up the shoreline to mid-reservoir. The fish appeared to have died no earlier than Saturday, September 12th.

TPWD personnel returned to the lake on Monday the 14th and Tuesday the 15th to collect water samples and conduct a thorough investigation and enumeration of the kill. Water quality field data were measured both in and out of the area where dead fish were observed. Dead fish were distributed along approximately 10 miles of shoreline. A series of detailed counts were conducted along approximately 0.75 miles of that shoreline to allow estimation of the total kill.

Water quality datasondes (electronic data gathering devices) were deployed in the northwest and south coves where the main kills occurred. These datasondes were able to collect temperature and oxygen concentration every 30 minutes for the following 14 days.

Water quality field data collected on Sunday the 13th indicated extensive areas of lower than normal oxygen and abundant phytoplankton (chlorophyll a) in the areas where the fish kill occurred. Using information on oxygen concentration from the datasondes, water quality data collected the day of the kill, and information on sunlight level from a local weather site, TPWD biologists began to piece together a theory on the cause or causes of the kill.
Normally photosynthesis (oxygen production) by phytoplankton during daylight hours increases oxygen concentration enough to compensate for respiration (oxygen use) by those same phytoplankton as well as bacterial decomposition at night. However, during periods of cloudy weather sunlight (measured as solar radiation) is reduced; oxygen consumption remains high but oxygen production is greatly reduced. When cloudy weather lasts for several days and oxygen concentration falls below the minimum level to support aquatic life, fish begin to die.

A good rule of thumb is at oxygen concentrations below 5 milligrams per liter (5 mg/L) many species become stressed, and at concentrations below 3 mg/L most species can die from oxygen deprivation. These concentrations are also known as the daily mean and minimum dissolved oxygen criteria for high aquatic life use in the Texas Surface Water Quality Standards. Although oxygen levels may stay above the minimum level during the day, it only takes a few minutes below the minimum at night to be fatal to fish.

Cloudy weather in the Fairfield area began on Thursday, September 10th. By Saturday the 12th solar radiation was only 1/3 of the normal for that time of year, and fish began dying before dawn on the 13th. By the time KAST personnel deployed the datasondes on the afternoon of the 14th the sun had begun to break through the clouds, and oxygen levels had begun to temporarily climb back above 5 mg/L.

This reprieve was short-lived; cloud cover reduced solar radiation on the 15th, 16th and 17th and oxygen concentrations remained below the minimum level. By the 18th the weather pattern had improved and oxygen production in the north cove remained above the minimum level. Oxygen production in the south cove lagged several days behind due to its higher phytoplankton level, but by Sunday the 20th abundant sunshine was once again allowing phytoplankton to produce high levels of oxygen in both areas. Another short period of cloudy weather from the 22nd to the 25th reduced oxygen concentration again but was of short enough duration that no substantial fish kill occurred.

By combining oxygen data from the datasondes with solar radiation data from the weather station, TPWD biologists now had the critical information needed to understand the complex dynamics of the repeated kills at Lake Fairfield.

In September, water temperature and bacterial activity are still high but day length has been getting shorter incrementally since the summer solstice on June 21 (the date in the Northern Hemisphere when daylight hours are longest relative to dark). Extremely high phytoplankton levels due to high nutrient levels produce sufficient oxygen during sunny days to compensate for lack of production at night; however, when early fall cool fronts and cloudy weather limit solar radiation, oxygen levels drop rapidly and fish may die.
��extracted paragraph that quantifies the fish killed counts �

Water samples and tissue samples from live but stressed fish collected during the day of the kill have not shown the presence of any toxicant that could be responsible for the kill.�
2. Further I am glad to learn that TPWD�s Mr. Melinchuk November 11, 2011 letter included a carbon copy to Luminant�s manager Ms. Shawn Glacken. Therefore GLC was again informed of TPWD�s fish kill cause conclusions. Hence there can be hope GLC has been working on a permit revision solution since receiving TPWD�s re-enforcement of their massive fish kill cause findings.

3. While there were known prior meetings and phone discussions between and LGC and/or TXU staffs with the TPWD staff preceding the 2009 fish kill; it possible from just publicly available information to minimally date when TPWD informed the power company that oxygen depletion was the symptom that caused the Lake Fairfield massive late summer fish kills. Hence by using the TPWD letter table 1 the stock values lost in 2010 and 2011 occurred after GLC was publicly minimally informed, and amounts to a value no less than slightly over $4.4 million plus the TPWD multiple years investigation costs. To my knowledge the 2004 to current TPWD investigation cost remains un-valued by TPWD. The restocking of the lake with adult size fish LGC should be supplying should minimally include $4.4Million plus the cost of all the TPWD fish kill investigations. A responsible corporate citizen would have already restocked the lake with the aquatic life lost after October 2009 and paid TPWD for the value LGC derived for those investigations.

4. For filing a permit application failing to accurately inform:

a. TCEQ that there were periods of significant fish mortality events, and clearly stating there were none and,
b. for somehow not having any water quality tests results from samples taken during these fish killing periods, and
c. with the common knowledge of GLC had to haul away multiple dumpsters or truck loads of dead fish mass �suspended solids� but submitting an permit application claiming no such events beyond 70% of normal ever occurred since the 2007 renewal.
d. Then I feel it is appropriate that a TCEQ fine LGC for all post October 2009 press release fish kills for a fine value amount sufficient to offset:
i. All the all investigation expenses cost TPWD had to divert diverted from the sportsman�s license and use fees to investigate for fish kill causes for all the 2004 to present massive fish kill years, and deliver that conclusion to LGC, plus
ii. The expense TCEQ has to afford to hear these comments on LGC�s false permit application statements, and then reconsider any amended permit application again.