There is a high probability that, by discharging nutrient-rich effluent into a narrow, shallow creek and cove where it cannot be properly diluted and dispersed, the City of Granbury’s proposed sewer plant discharge will launch another Golden Algae fish kill. Rucker Creek was one of the many problematic coves in previous Golden Algae fish kills. During the 2011-2012 fish kill, where over 250,000 fish died in the Brazos River, hundreds of dead fish rotted along the banks of Rucker Creek; only the buzzards went outside.

• The health risks to humans, pets, wild fowl and animals as well aquatic life are well-documented, as summarized in the attached excerpts from the 2019 Congressional Research Service report. 
• The negative economic impact of another Golden Algae fish kill, for the City of Granbury and the entire region, will be significant, should the City of Granbury choose to assume these risks and pursue the current permit. Resulting costs (as per Congressional Research Service Report) may include:

1. Loss of tourism
2. Contamination of drinking water requiring expensive water treatment or alternate water sources
3. taste problems in farmed and wild-caught fish (making them inedible)
4. Loss of fishing income
5. Clean-up costs

• Risks of related litigation are also likely, particularly those pertaining to the negative impacts on the public health interest and public welfare.