U.S. Bureau of Reclamation
c/o EMPSi, 54½ Lincoln St., Santa Fe, NM 87501
To Whom It May Concern:
We in Agua Fria Village stand in solidarity with our downstream sister communities in opposing the pipeline proposal as presented. Under the principles of the acequia culture, we believe in repartmiento, which in this case might translate as: "all for one and one for all."
First off, the U.S. Bureau of Reclamation must immediately change the process from an Environmental Assessment to the more proper Environmental Impact Statement (EIS). An EIS allows for the consultation of specific populations of people whose rights are now being ignored. Additionally, an EIS handles the existing biosphere much more carefully. An EIS would do a much more comprehensive analysis that is required when wastewater is directly entered into a riparian area. [Andrea DLC can phrase this EIS stuff all better here].
We find that the City of Santa Fe's presentations on November 2nd and 3rd, had the wastewater operators and management suspiciously absent from the panel presenting the proposal. It is their product that we are talking about transporting in this pipeline. If they are not willing to face the public, how can we ever trust the quality of that water that is proposed to be put back into the Rio Grandé? In fact, there is an alarming track history of U.S. Environmental Protection Agency (EPA) violations that the City of Santa Fe has incurred, that we will talk about later. If we were a very cynical people, we would say that the City is just trying to get rid of its sewerage problems by dumping them into the Rio Grandé.
We participated in the 2017 planning process with the City of Santa Fe and we don’t know that the 7 different scenarios were vetted with complete information. This particular alternative rose to the top, basically out of nowhere. The Siler Road or Frenchy’s Field Scenario was done with improper cost information. We proposed a Right of Way (ROW) corridor that belongs to Santa Fe County under the Algodones to Baca Street High Power-line that would be free and not part of a $20 million ROW cost along the Santa Fe River, which was included in the City’s proposal. The Agua Fria Village wrote a letter supporting the Siler Road outlet proposal as a way to recharge our wells and maintain our Bosque (biosphere). However, given the horror stories from the Paseo Real Wastewater Plant, we are formally withdrawing that endorsement. Especially after hearing presentations on pharmaceuticals that are retained in the water at the Paseo Real Wastewater Plant, by Patrick Longmire of the N.M. Environment Department.
We are inherently aware of the dire consequences of Climate Change facing New Mexico and the need for the City of Santa Fe to continue the diversification of its water resources. For example, Sarah Moore, of the U.S Army Corps of Engineers, who is helping staff the New Mexico 50 Year Water Plan, spoke about the dire state of affairs: overall moisture will decrease from shifting jet stream patterns (going north of New Mexico), this will result in a loss of trees across ALL high mountain areas, this will increase soil erosion clogging water sources (like the Buckman Direct Diversion). This will occur to a point where the mountains are down to bedrock. Concurrently, there will be an increase in wildfires and more dramatic flood events. Also, wildfire impacted soils are sealed from moisture retention. There will also be an albedo effect on snowpack where it will be just evaporated without tree cover. So this is not our basis for opposing the City’s proposal. We just believe there are better alternatives.
We are in an active Adjudication of Henry Anaya, et. al. versus City of Santa Fe, so I don’t see how this radical approach would be accepted under that litigation. Wouldn’t any out of basin transfer of water be required to be approved by the judge in that case?
Neil Williams, hydrologist and engineer, spoke at the November 2nd presentation and spoke about this point: Los Alamos National Lab’s (LANL) Legacy Nuclear Pollution and other contaminants in White Rock Canyon and Los Alamos Canyon, that are above the Buckman Direct Diversion (BDD) Inlet. A really huge rain event could flow over the top of the check dams and remediation efforts that LANL is doing, and go right into the Rio Grande, and the BDD inlet itself. Therefore, this money would be better spent to extend the pipeline for the BDD above the deadly waste and utilize the San Ildefonso Pueblo easement for the future Aamodt Water Plant.
Paul White, President of the Santa Fe Basin Water Association, says: why isn't the City of Santa Fe proposed pipeline from the Paseo Real Wastewater plant sent direct (through the Purple Pipe) to the Buckman Direct Diversion Inlet where it can get 100% purification and it isn’t silty water to begin with, instead of into the Rio Grande, where there is a possibility of pollution? We are told by Wastewater Plant whistleblowers that the water from the plant will never be suitable for human consumption and this is why it was never considered.
If the goal is to get Return Flow Credits for San Juan-Chama water (which will be increasingly diminishing under Climate Change), why doesn't the City of Santa Fe join the Santa Fe River Traditional Communities Collaborative (SFRTCC) in it's goal for getting Return Flow Credits for the discharge of the Paseo Real Wastewater plant through the Santa Fe River into the Cochiti Lake's Santa Fe River holding dam (that passes through the sand into the Rio Grande), in accordance with the mechanisms set out in House Memorial 103 and Senate Memorial 70 of the 2017 N.M. Legislative Session?
NOTE: The whole N.M. Office of State Engineer's determination made by attorney (not a hydrologist) D.L. Saunders in the late 1970's was that the water in the Santa Fe River never made it to the Rio Grande and the water simply evaporated. This has since been disproven by actual hydrologists studying the water flow in the sands of the riverbed (Professor Stacey Timmons, N.M. Institute of Mining and Technology).
If we look at the “History of the Springs” along the Santa Fe River, former State Historian and professor Hilario Romero has documented some 33 springs along the historic 47 mile course of the River. This information coming from the historic journals of Spanish explorers and settlers as they watered their horses. Currently, only six of these regularly flow. With all six with diminished flows. The recharge of these springs and of people’s wells is very important and this proposal jeopardizes that. La Cienega Creek flowed year-round from the Springs probably for the last 400 years as documented by La Cienega residents.
The Rio Grande is the lifeblood of most of New Mexico, and the thought that full effluent dumps, as have occurred in June 2021 and before, would devastate that water is sort of horrifying. No public agency should enable this. The Paseo Real Wastewater Plant does not filter out pharmaceuticals, and there are no plans to do so, so dumping it in the Rio Grande is not helpful to downstream users or wildlife. Studies in other parts of the country have shown where the sexes of amphibians are changed by living in water with too many pharmaceuticals.
The “Artificial Wetlands” on the City of Santa Fe’s Airport and State Land Office lands, below the Paseo Real Wastewater Plant need to be reworked before any such Pipeline proposal is acted on. There are wetland applications proposed by Erin English of Biohabits, that describe natural environment that filter wastewater. So now that we have “Habitat” established by both the historic flows and the City’s flow of water and the possible 50% of water flow (and it has endangered species in it like the N.M. Willow Flycatcher), a whole new Management Plan must be established by Federal law. Where is this being considered?
QUESTION TO THE BOR: Is this water from the Paseo Real Wastewater Plant safe to put back into the Rio Grande?
BACKGROUND: A City of Santa Fe whistleblower alerted the U.S. Environmental Protection Agency in Dallas (Anthony Loston; [email protected]) to do a surprise inspection in June 2021 and a number violations were found that resulted in citations and two follow-up inspections were done that resulted in two more citations. To date a response has not been made to my knowledge and the corrective action was never disclosed to the public.
SPECIFICS: Excessive Sanitary Sewer Overflows (SSO), the sand filters (tertiary treatment) often blow out or are bypassed which leaves large amount of suspended sediment in effluent prior to Ultra Violet (UV) disinfection. The suspended particles mean that the water won’t meet discharge limits, as bacteria are shielded from UV light by particulate. Delays in construction projects caused detention times in aeration basins to be too low, which causes excessive foaming. This means ammonia in Wastewater can’t be stabilized, leading to exceedances in discharges. The headworks are close to failing. Debris is making it into plant and causing problems with equipment and throughout process. Fats, oils and greases aren’t being well regulated in City, so it’s making it to the plant & wreaking havoc. There are electrical code violations throughout plant. Waste Water (WW) Director Mike Dozier is never on site, which violates EPA rules for operators. He had ~2 years experience in WW before Shannon Jones promoted him.
WW Collections has 4 employees remaining, out of 19 FTEs on the books. This means they can’t clean lines or do maintenance with this few people, so we have excessive Sanitary Sewer Overflows (SSO). Dozier & Jones are pushing staff not to report SSO’s to EPA within the mandatory 24 hour period as required by Federal law.
Look at an aerial of the Waste Water plant and see five different types of lagoon structures, I mean to the City of Santa Fe’s credit, they have tried every approach to fix the problems that have spanned across decades. But there is now a sense of complete “hopelessness” that has set into the City Staff and officials. They often say the only way to change this is to build a new $350 million dollar wastewater plant. But they know the cost to the City would bankrupt it and the EPA approvals would take a minimum of three years. Frankly, this BOR Application is the very easy way out. Just Do It and then beg forgiveness later when pollution occurs in the Rio Grande.
The following actions of the BOR are necessary under the City of Santa Fe’s Environmental Assessment Application:
1. Change it to an Environmental Impact Statement.
2. Explore more alternatives to the application, such as: moving the BDD Outlet above the Legacy Nuclear Waste; or using the Pipeline to filter the water direct into the BDD Outlet.
3. Give citizens more opportunities for input.
Thank you for your attention to these comments.
William H. Mee, President of:
County-Designated Community Organization of the Traditional Historic Community of Agua Fria Village
Agua Fria Village Association
Acequia Agua Fria
Agua Fria Wellowners' Association
Source : https://www.santafenewmexican.com/opinion/my_view/city-is-not-keeping-annexation-promises/article_ebd3cbc0-4265-11ec-9ed4-b37ea8ee6910.html1932