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Much of the work that the land development department of Foresite Group, Inc. does is prototypical for larger clients, like CVS/Pharmacies. This means that the clients have a good idea of what they would like their buildings and sites to look like. This allows for most of the sites to move quickly with fewer surprises in the design and permitting stages of projects. However, every once in a while, the site itself offers very unique challenges. This was certainly the case for a CVS within the City of New Bruanfels.

Foresite Group was brought into the CVS/Pharmacy portion of this project from the beginning. We designed the original layout, completed the initial site investigation and due diligence, and drafted an initial estimate of the construction cost. As the project progressed we navigated all levels of permitting and platting through all government agencies: Texas Department of Transportation (TxDOT), Texas Commission of Environmental Quality (TCEQ), Comal County, and the City of New Braunfels. This project was Foresite Group’s first experience with TCEQ, the Texas equivalent of the EPA.

The reason that this site was unique and required coordination with TCEQ is because it is located within the Edwards Aquifer Recharge Zone. Edwards Aquifer is one of the largest aquifers in the world, and it is the main water supply for nearly two million people in South Center Texas. The region that the CVS site is in specifically, the recharge zone, is where nearly 80% of this aquifer’s water enters due to the rock formation’s highly permeable characteristics. Any pollutants in the water are more likely to enter the aquifer and therefore the drinking water of nearly two million people. For these reasons, TCEQ has much more strict water quality regulations than other governing agencies within the state of Texas.


In order to receive a permit to place a building within the Edwards Aquifer Recharge Zone, TCEQ requires a report called a Water Pollution Abetment Plan (WPAP). This plan detailed site and project specifics as well as an accurate assessment of risk items during the construction phases and once the store is open for business. Additionally, a more thorough geotechnical assessment of the site is required. This assessment is used to search for geologically sensitive features, such as potential sink holes or fault lines for example. These features will allow for the stormwater to enter the aquifer even more quickly than normal. Some further items of concern for TCEQ were any pollutants that stormwater might carry away with it, such as a car that is leaking oil or anti-freeze in the parking lot. These chemicals would be swept up by stormwater and could very easily end up within the aquifer. However, pollutants are not always as obvious as run off from vehicles. A major concern for TCEQ is sediment within the stormwater. This seems extremely innocuous, but sediment that enters the aquifer through stormwater will eventually settle out within Edwards Aquifer. Again, this doesn’t seem like a big deal, but when sediment settles out of the water it will reduce the volume of the aquifer and ultimately the amount of water that can be held in the aquifer. In order to mitigate these issues, TCEQ requires an approved water quality device that will remove a minimum of 80% of all total suspended solids (TSS) from the water.

Interestingly enough, the most difficult part of receiving a WPAP approval from TCEQ is not actually the review itself, but rather the initial cursory review to determine if the document is complete enough to be in-taken for a more thorough review. This is not to say that the WPAP that was submitted was not 100% complete, but rather once TCEQ reviewed the site it might be necessary to supply additional information. This process required a professional engineer to be present at the initial submittal to field any and all questions pertaining to the WPAP and what might be missing from it. This process took upwards of 6 hours. The WPAP was accepted on the first attempt (which is rare), and once the document was taken in by TCEQ, the process for receiving their approval went very quickly and smoothly.

With the WPAP reviewed and approved by TCEQ, it was possible to receive a building permit from the City of New Bruanfels. At the same time that TCEQ was reviewing the Water Pollution Abetment Plan, we were coordinating with the City of New Braunfels to resolve any issues or comments that they might have with the proposed CVS. At this point all concerns had been addressed, and therefore all necessary permits had been received to begin construction. However, this site was part of a master development. In other words, the CVS was just one store among multiple stores being built in the same general location. In order to maintain a good relationship with the developer and assist the engineering firm of the adjacent site, we were asked to use some of the contacts that we had fostered within the City of New Braunfels to help get a building permit for the adjacent building, what was to be a Zaxby’s restaurant.

The main item that was outstanding for the Zaxby’s was the fact that a plat had not yet been recorded for the master development. The recording of the plat was already in the works at this time, but in order for this to happen in a timely fashion the reviews conducted by the City of New Braunfels needed to be expedited. This required developing new relationships within the New Braunfels and Comal County and reaching out to these new contacts to make sure that they had everything that they needed for this review process. Finally, after several days of calling and follow-ups with reviewers, the plat made it to Comal County and was recorded the very same day. This fulfilled the only remaining roadblock before the Zaxby’s permit could be released by New Bruanfels. The initial work for this site was submitted to the client in May 2015, and now it is sixteen months later and the CVS is well on its way to being completed, and the Zaxby’s next door is very near to breaking ground.

About Foresite Group

Foresite Group is a multidisciplinary engineering, planning, and consulting firm providing services to public and private sector clients nationwide. Our team’s collaborative process results in creative products and services that help our clients achieve their goals. Our team takes pride in enhancing and developing the cities and communities where we live, work, and raise our families.

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