Middle Rio Grande Regional Water Plan

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Middle Rio Grande Regional Water Plan Comments Last Updated 05/24/2016 Comment Page Paragraph or Section Number Number Number Comment 60 6‐11 Section 5 None of the bullets acknowledge the existence of the Rio Puerco and Rio Jemez sub‐regions that are also a part of the Middle Rio Grande Region 12. Either we should look into updating the Rio Puerco and Rio Jemez plans (Chapter 12 in 2004 RWP) or we should explicitly say that this update excludes those subregions. 61 11‐25 Section 5 Why does Section 5 present all those data items (temp., precip., drought indices, etc.) when Sections 5, 6, 7 direct the use of Administrative Water Supply and Demand only instead of those data? 62 12 5.1.1 It’s inconvenient for the reader to keep three separate documents open so as to see text, tables, and figures. We assume that the final report version will integrated this information into the appropriate sections of the text. 63 13 5.1.1, 8th paragraph Paragraph is incorrect as it stands. Grissino‐Mayer did not indicate recent precipitation to be lower than long term average. In fact, Grissino –Mayer showed the last quarter of the 20th century to be far wetter than the long term average. Grissino‐Mayer said nothing about the future. The 2004 RWP may have noted that after Grissino‐Mayer data, the precipitation was lower than long term average. 64 14‐16 5.1.2 This paragraph mentions potential future impacts of climate change. Yet, it does not provide an approach for how New Mexico should plan for climate change impacts when the technical data is simply the Administrative Water Supply. 65 16 5.2, 2nd Paragraph 66 18 5.3, 1st paragraph The phrase “…but excluding potential compact limitations” places unrealistic constraints and extreme biases on water planning analysis in this draft plan. For the MRG, the RG Compact is one of the major constraints on supply. Ignoring this in this draft planning analyses would imply that the MRG region need not consider or contribute to future compact needs in years of shortage. If this is not true, then this statement and the associated results presented in this draft plan should be extensively revised. Besides providing backup supplies to ABCWUA when surface water cannot be diverted, groundwater at other times provides significant augmenting supplies even when ABCWUA is diverting surface water. 67 18‐19 5.3.2 The section talks about major wellfields in the area, but does not acknowledge the significant aggregate groundwater use by domestic, mutual domestic, and agricultural wells in the region. It is critical that analyses of these uses be included in any final plan for the region. 68 20 5.4 The entire subsection on water quality does not appear to acknowledge tribal water quality standards, which have non‐trivial implications for the region’s handling of water. 69 22 5.4.2, last two We commend the authors on finally acknowledging, albeit superficially, the Rio Puerco and Rio Jemez bullets Subregions. 70 23 5.5, 2nd paragraph In the explanation of Administrative Water Supply here, why is it assumed that the 2010 diversions were “permitted and in compliance with water rights policies”? Our understanding is that many demands/rights were not met in that year due to insufficient water supplies, that there were many diversions lacking permission, and, more critically, that water rights in our region are claimed but are not adjudicated. 71 24‐25 5.3.2 This discussion of “Drought Supply” does not appear to acknowledge the impact of consecutive dry years, nor does it appear to acknowledge the impacts of RG Compact constraints on deployment of water. The final plan should include full analyses of these assessment gaps. 72 27 6.1, last paragraph 73 27 6.2, 2nd paragraph The phrase “depletions have not been quantified” is indicative of a key problem in this draft plan. For a many years the OSE issued depletion reports every five years. Depletions are critically important for the MRG region that is compact constrained. It is of critical importance that OSE resume issuing depletion reports. As we understand, Intel has been “defined” to be located in Sandoval County but not in Rio Rancho. If that is the case, “in” should be changed to “near” on this line of text. Comment Type (Technical or Process) Commenter Steering Committee Comments Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely 74 6.2.1, 4th and 5th paragraph The two paragraphs seem to contradict each other. The increases cited in the fourth paragraph vs. the shrinkages cited in the fifth paragraph need some words of explanation. Technical Water Assembly ‐ Bob Wessely 75 30 6.2.2, 4th paragraph To our read, additional explanation or justification is needed here. The projected sudden jumps are counter‐intuitive. For more than the past decade, a total of 213 homes were built on Mesa del Sol . Then, according to the draft plan, starting this year, building will jump to 150‐200 homes per year. Then in 2018 it will again jump to 600 per year. Separately, the aggregate count is not right. 213+(3*200)+(43*600) is only about 70% of the 37,500 home buildout in 2060 that was promised on Line 4 of the paragraph. Technical Water Assembly ‐ Bob Wessely The steering committee agrees that Intel is not within the Rio Rancho city limits ‐ see also the comments from Rio Rancho regarding Intel Page 8 of 17
Middle Rio Grande Regional Water Plan Comments Last Updated 05/24/2016 Comment Page Paragraph or Section Number Number Number 76 30 6.2.2, 6th paragraph 77 32 6.2.3, 4th paragraph 78 34 6.4, 4th paragraph 79 42 6.5.2, 1st paragraph 80 43 6.5.2, 4th paragraph Comment The text cites 2‐3% annual economic growth. The last bullet on the page (“Forbes…” ) cites 0.2% annual growth. Again, for credibility, there should be some words discussing the mismatch in numbers. Comment Type (Technical or Process) Commenter Steering Committee Comments Technical Water Assembly ‐ Bob Wessely The numbers sound inconsistent on their face. It says 16,000 new homes in 20 years, or 800 homes per year. It says only 100‐200 permanent new jobs (is that each year or total in 20 years?). Regardless, how is it possible to get 16,000 families immigrating to Belen without offering them some employment? It not likely they will all find work outside of Belen, including Albuquerque. Technical Water Assembly ‐ Bob Wessely Subsubsection entitled “Irrigated Agriculture”, Fourth paragraph, Line 7 – It should probably be noted that changes in crop types, etc. may not be as easy as it is made to sound in this draft report. There are business operations and capital costs associated with such changes and soil/irrigation considerations that need to be addressed. To be more symmetric, the plan should include an assessment of changes in chip type to conserve water at electronics manufacturers. Technical Water Assembly ‐ Bob Wessely Please clarify throughout whether three or four counties comprise the MRG planning region. Technical Water Assembly ‐ Bob Wessely It does not seem reasonable to keep ag use constant when future water rights are projected by many as likely to be transferred to urban domestic or industrial use. Adding an assessment of alternative possible futures would be valuable here. 81 44 7, 2nd bullet It’s not obvious that “long term balanced supplies may be in place” when we consider groundwater depletions and climate change impacts to surface supply availability. To make this draft credible, the final should include assessments of how such factor can affect future supplies and demands, including an array of reasonable potential alternatives. 82 44‐45 7 It is essential that this section include a quantitative assessment of the supply “gap”. Now, this section has only broadly qualitative statements, lacking reasonable value for planning needs. 83 44‐45 7 There should be added some acknowledgement of the risk from protracted (vice 1‐2 year) drought, including the degrees of uncertainty related to those projections. 84 general We believe history is not but should be considered in planning for our water. History contains lessons and omens. We cannot avoid realities including physical water availability above and below ground, the Rio Grande Compact, and legally binding senior rights, including those of the pueblos. The lack of adjudication continues to be an obstacle to coherent water management. 85 previously submitted comments 86 previously submitted comments 87 previously submitted comments 88 previously submitted comments 89 previously submitted comments A 2010 tabulation, later submitted to the MRCOG Steering Committee, of the Water Assembly’s perception of key actions or changes that have occurred since the 2004 Regional Water Plan (also includes list of the RWP recommendation titles): http://www.waterassembly.org/Archives/Water%20Assembly%20Documents/MRG‐RWP‐ Update/RWP10w_1e‐Recommendation%20ActionLists%20.pdf A December 17, 2013 list of concerns about the impending regional water planning process, submitted to the ISC Commissioners: http://www.waterassembly.org/Archives/Water%20Assembly%20Documents/MRG‐RWP‐ Update/wa349p‐CommentForISC‐12‐17‐13.pdf A March 3, 2015 presentation to the MRCOG Steering Committee regarding the nature of the 2004 Regional Water Plan and the approach to updating that plan: http://www.waterassembly.org/Archives/Water%20Assembly%20Documents/MRG‐RWP‐ Update/wa104h‐BriefingToRWP‐SC‐IntroductionToThe2004‐RWP.pdf A June 19, 2015 memorandum submitted to the MRCOG Steering Committee expressing some concerns about the RWP update: http://www.waterassembly.org/Archives/Water%20Assembly%20Documents/MRG‐RWP‐ Update/6‐19‐ 15%20emh%20Comments.pdf A June 27, 2015 submission to the MRCOG Steering Committee as an update replacement to an earlier Water Assembly submission. It contains guiding principles for planning, considerations for Regional Water Plan Update, recommended future strategies, technical data, and a summary of the sixteenth water assembly convocation on climate disruption: http://www.waterassembly.org/Archives/Water%20Assembly%20Documents/MRG‐RWP‐ Update/wa428b‐AggregatedUpdate%20SubmissionToMRG‐RWP‐SC.pdf Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Technical Water Assembly ‐ Bob Wessely Process Water Assembly ‐ Bob Wessely Process Water Assembly ‐ Bob Wessely Process Water Assembly ‐ Bob Wessely Process Water Assembly ‐ Bob Wessely Process Water Assembly ‐ Bob Wessely Page 9 of 17
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Middle Rio Grande Regional Water Pl
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Table of Contents Executive Summary
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List of Figures 1-1 Location of Mid
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5-12 Leaking Underground Storage Ta
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MCL MCLG MDWCA MRCOG MRGAA MRGCD MR
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Executive Summary The Middle Rio Gr
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Planning Method For this RWP, water
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appropriations are available in the
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channel aggradation. These changes
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In 2014, the U.S. Environmental Pro
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• Bosque and other riparian habit
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1. Introduction The Middle Rio Gran
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The organization of this update fol
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2.1 The New Mexico Interstate Strea
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2.2.1 Identification of Regional St
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Table 2-1. Steering Committee Membe
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Table 2-2. Middle Rio Grande Region
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Jicarilla Apache Nation Reservation
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Sierra water planning region. Geogr
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Table 3-1. Summary of Demographic a
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4. Legal Issues 4.1 Relevant Water
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In addition to Tri-State, several c
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Socorro, Valencia, Bernalillo, Sand
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Authority’s application sought to
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equires the NMOSE to conduct hydrol
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3. Allow for the declaration of dom
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provided for another review procedu
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Source: NMOSE, 2014a and 2014c La J
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4.1.3 Federal Water Laws The law of
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As discussed above, the three party
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existing, and future uses). No adju
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• Gather information on domestic
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plan recognizes that water is easil
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• Protect groundwater by preventi
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not adequately consider all of the
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4.2.2 Water Quality Laws 4.2.2.1 Fe
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National Priorities List (NPL). 42
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• The Jicarilla Apache Nation Cod
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• Water users seeking to obtain w
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• The Federal Emergency Managemen
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water balance in the Middle Rio Gra
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Table 5-1. Middle Rio Grande Climat
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Sources: 1. WRCC, 2014 2. NWS, 2005
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Jemez Springs Temperature (°F) 90
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Jemez Springs Precipitation (inches
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drought monitoring systems, and it
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Climate Division 5 14 12 10 8 6 4 2
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expected. To assess climate trends
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Rio Chama La Jara JEMEZ RIVER NEAR
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Table 5-4a. USGS Stream Gage Statio
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Table 5-4a. USGS Stream Gage Statio
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Table 5-4b. USGS Stream Gage Annual
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Table 5-5. USGS Stream Gage Average
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1,200,000 1,000,000 Jemez River nea
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Rio Grande at Albuquerque, NM 2,000
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Table 5-6. Reservoirs and Lakes (gr
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Table 5-7. Dams with Dam Safety Def
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Tsj Southern Rocky Mountain Colorad
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In order to evaluate changes in wat
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5,025 5,020 351852106344901 Aquifer
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Source: NMED, 2014a and 2014c Note:
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Table 5-8. Total Maximum Daily Load
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Table 5-9. Municipal and Industrial
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Table 5-10. Groundwater Discharge P
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Table 5-11. Superfund Sites in the
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Table 5-12. Leaking Underground Sto
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Table 5-13. Landfills in the Middle
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Runoff, flooding, and debris flows
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• The minimum annual yield for ke
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Table 6-1. Total Withdrawals in the
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P:\_NM15-203\RWPs_2016\12_MRG\Figur
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• Riparian evapotranspiration: So
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The Arrowhead Center at NMSU analyz
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• The continued presence of Sandi
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to 669,727 acres. Also, during that
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For this regional water plan update
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Table 6-4. 2010 Water Withdrawals f
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Table 6-4 2010 Water Withdrawals fo
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Page 194 and 195: • Consumptive use occurs when wat
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Page 198 and 199: demand in this sector. The amount o
Page 200 and 201: 6.5.2 Middle Rio Grande Projected W
Page 202 and 203: Table 6-5 Projected Water Demand, 2
Page 204 and 205: Within Bernalillo County, the high
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Page 208 and 209: • Priority for Continued Implemen
Page 210 and 211: When the 2004 RWP was developed the
Page 212 and 213: Table 8-2. Key Collaborative Progra
Page 214 and 215: Table 8-2. Key Collaborative Progra
Page 216 and 217: Bartolino, James R. and James C. Co
Page 218 and 219: Hawley, J.W. 1986. Physiographic pr
Page 220 and 221: The Middle Rio Grande-Albuquerque R
Page 222 and 223: New Mexico Environment Department (
Page 224 and 225: S.S. Papadopulos & Associates, Inc.
Page 226 and 227: U.S. Geological Survey (USGS). 2014
Page 228 and 229: Middle Rio Grande Region 12 RWP Mas
Page 230 and 231: Riley Middle Rio Grande Region 12 R
Page 232 and 233: Appendix 2-B Summary of Comments on
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Page 250 and 251: Appendix 6-A List of Individuals In
Page 252 and 253: Appendix 6-B Projected Population G
Page 254 and 255: Appendix 8-A Review of 2004 Strateg
Page 256 and 257: Appendix 8-A. Steering Committee Re
Page 280: Planning Region Middle Rio Grande M
Page 284: Regional Water Planning Update Proj
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Regional Water Planning Update Infr
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Regional Water Planning Update Infr
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Planning Region Middle Rio Grande M
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Middle Rio Grande Regional Water Plan

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