
EAHCP
STEWARD
News from the Edwards Aquifer Habitat Conservation Plan
Got the Memo
EAHCP permit renewal team working toward completion of key memos this year




From left to right - Christa Kunkel and Ed Oborny with BIO-WEST / Lucas Bare and Lily Sweikert with ICF Consulting.
2025 could be named “the year of the memo” for the Edwards Aquifer Habitat Conservation Plan. And for anyone involved in the preparation of the EAHCP permit renewal application needing approval before 2028, you’ve definitely gotten the memo about proposed changes being considered for this all-important draft document which will be formally written in 2026.
“In fact, there are three very significant memos relating to key components of the 2028 permit [renewal HCP] draft we should talk about,” said Lily Sweikert, Deputy EAHCP Project Manager with the consulting firm ICF. “In May of this year, the team completed a Conservation Measures Memo.
While most of the proposed changes to the conservation strategies were agreed upon by stakeholders, committees and the EAHCP Implementing Committee, there are still a few items to wrap up there. In July, we completed the Take Assessment Memo, which outlines some changes in how we gauge effects on endangered species [that] the program is designed to protect. That part of the plan is particularly important because take assessments are needed to show how effective the conservation measures really are.”
Sweikert explained the process for initiating a memo includes gathering pertinent data based on information obtained through various levels of discussions with stakeholders and the public. A draft document is then prepared for critical review by the EAHCP team, experts in the subject matter and ultimately the permittees. The final memos will form the basis for the formal chapters in the permit renewal application. And, as is the case with all EAHCP processes, there will be more opportunities for comments on the draft chapters.
The Monitoring and Adaptive Management Framework Memo is the most recent document under consideration.
“We have just received comments from stakeholders on the Monitoring and Adaptive Management Memo and we’re in the process of including those comments into a second draft [of the memo],” said Lucas Bare, ICF’s project manager the EAHCP permit renewal. “The team is proposing changes in how endangered species habitats are monitored and how the adaptive management system is implemented. All of those updates are based on lessons learned as the EAHCP team has fulfilled program requirements over the past decade. At the time of the writing of the current (2013) plan, there were many details that couldn't be known just because [the authors] were at the beginning of something new for the Edwards Aquifer region.”
Bare pointed out that some forward thinking went into the development of the adaptive management process to provide for species protections over a long period of time. Adaptive management essentially gives the EAHCP a way to adjust conservation measures as things are learned from targeted applied research and monitoring. That type of flexibility will be needed even more as the new permit is proposed to have a 30-year term, which is twice as long as the current one.
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“Constant learning and adapting to that new knowledge is key to everything we do,” noted Ed Oborny, a principal for the EAHCP contractor, BIO-WEST. “One of the best examples of that has occurred in recent years as we’ve seen extremely low flows in the Comal Springs and San Marcos Springs. All of the information we gathered about how the endangered species endured during this intense drought period will be put to use in the update of the adaptive management and habitat monitoring processes we implement in the future.”
In Oborny’s account about information gathering on species protections, he related that the team is proposing to change the current method of species take assessment to one that focuses on analyzing habitat conditions. He also mentioned that there will be additional evaluation on how recreation activities at various springflow levels impact endangered species habitat. Higher springflows produce deeper waters and so people swimming and floating in the rivers have less contact with endangered species habitats. Yet, recreational impacts, albeit less, still occur. Lower springflows produce the opposite effect on water depth and thus often result in greater impacts from people in the river.
“One important step forward, many people expressed interest in, is vegetation mapping of all types of plants in approximately 10 miles of river associated with endangered species habitat,” Oborny said. “The current permit requires mapping of these areas of the Comal and San Marcos rivers every five years. In the next permit [term], we are anticipating that mapping will occur every spring. That enhanced vegetation mapping program will work hand-in-hand with the new take assessment recommendations, since those assessments will be based on the health of species habitats.”
“Developing a habitat conservation plan is a difficult process,” Sweikert concluded. “The Edwards Aquifer HCP is even more of a challenge given the ecosystem’s complexities, the large geographical area it covers, and the corresponding number of permittees needed for implementing the program. The bottom line for success still has to be in balancing the comprehensive nature of protecting endangered species and habitats while still allowing human interaction such as pumping from the Edwards Aquifer to provide water for cities and aquatic recreation in the spring-fed rivers.”
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The USFWS is responsible for implementing the Endangered Species Act across the country. Since there are endangered species living in the Edwards Aquifer ecosystem and there are multiple users of the Edwards Aquifer, the region has two options. Either significantly change their use to avoid impacts to those species or request an Incidental Take Permit (ITP) to be allowed to impact those species by continuing to withdraw water from the aquifer over time. The first ITP was issued in 2013 and will be effective until March, 2028. The ITP renewal application will be submitted well in advance of the existing ITP’s expiration date, to allow the USFWS to review the application and conduct its own National Environmental Policy Act (NEPA) process. Having an ITP also means that, as long as the permittees are following the federally approved HCP, the USFWS cannot require additional conservation for the covered species during the permit’s lifetime.
To learn more about the EAHCP permit renewal process visit: https://www.eahcprenewal.org/
EAHCP Steward Podcast
We are now counting down months instead of years for a final draft of the EAHCP Incidental Take Permit Application Renewal. So we thought we should check in with the project management team on how the draft application is coming along, and also to discuss some changes being recommended for the new permit. Our guests include Lucas Bare and Lily Sweikert from ICF Consulting and Ed Oborny with BIO-WEST. Here’s the update from Lucas, Lily and Ed.

Upcoming EAHCP Meetings
EAHCP Implementing, Stakeholder, and Science Committee Meeting
When: Thursday, December 18, 2025
Time: 10:00 AM
Where: Edwards Aquifer Authority
Previous Meeting Documents and Videos
Implementing Committee October 9, 2025 Agenda
Implementing Committee October 9, 2025 Meeting Recording
Science Committee September 10, 2025 Agenda
Science Committee September 10, 2025 Meeting Recording
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Implementing Committee August 7, 2025 Agenda
Implementing Committee August 7, 2025 Meeting Recording
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2025 EAHCP Committee Calendar

Follow the Progress of the ITP Renewal Process Online
The current Edwards Aquifer Recovery Implementation Program Incidental Take Permit (ITP) expires March 31, 2028. The Edwards Aquifer Authority Board approved a contract in April 2022 to perform technical services to plan for a permit renewal. The permit renewal of the Edwards Aquifer Habitat Conservation Plan is a four phase process. You can keep up with all of the ITP progress by bookmarking the website at: www.eahcprenewal.org.