Before the Interstate Stream Commissioners
Citizen Action New Mexico
Comments on the Gila River Diversion Plan EIS Funding
June 17, 2020
Commissioner Mark Sanchez, Chair: This email address is being protected from spambots. You need JavaScript enabled to view it.
Commissioner Aron Balok: This email address is being protected from spambots. You need JavaScript enabled to view it.
Commissioner Bidtah Becker: This email address is being protected from spambots. You need JavaScript enabled to view it.
Commissioner Greg Carrasco: This email address is being protected from spambots. You need JavaScript enabled to view it.
Commissioner Paula Garcia: This email address is being protected from spambots. You need JavaScript enabled to view it.
Commissioner Mike Hamman: This email address is being protected from spambots. You need JavaScript enabled to view it.
Commissioner Stacy Timmons: This email address is being protected from spambots. You need JavaScript enabled to view it.
Commissioner Tanya Trujillo: This email address is being protected from spambots. You need JavaScript enabled to view it.
Citizen Action New Mexico (CANM) is a 501 (c)(3) project of the New Mexico Community Fund. CANM joins with the many legislators, environmental organizations and citizens to oppose the plans for diversion of the Gila River for irrigation purposes.
The Interstate Stream Commission is urged to vote NO on continued funding for the NEPA process for the Gila Diversion project that is an ill-conceived plan and boondoggle waste of taxpayer dollars. The Gila R.should be included for protection under the Wild and Scenic Rivers Act.The Bureau of Reclamation Draft Environmental Impact Statement is grossly deficient for many reasons. The DEIS would dam the last free flowing river in New Mexico and one of the remaining integral rivers in the United States. CANM supports the No Action Alternative.
The failure to hold direct in-person public hearings on the DEIS is fundamentally unfair and in violation of the National Environmental Policy Act. The DEIS should be postponed until any actual in-person public meetings can be held. Webinars are an abomination as a communication substitute. Shoving through a comment period and project approval during the Covid-19 infection that has been controversial and opposed for thirty years is outrageous.
The Gila R. represents invaluable and unique biological resources that should be protected, maintained and remain for generations to come. The continuing public threat of infection and death from Covid-19 places a greater need for and emphasis on preservation of rapidly diminishing open space that offers one of the safer recreational opportunities for the public.
The Gila R. should not be developed with diversion dams. The singular use for the water from the Gila R. would be for agricultural and irrigation use and to benefit the world’s largest copper mining company.
The DEIS poorly balances economic consequences of drying up the river against the many the economic and environmental valuesoffered. The Gila R. presents unique, diverse social, ecological, wildlife, recreational, educational, anthropologic and cultural opportunities that should be preserved to endure for present and future generations.
The drying of the river from climate change and sole reliance on snowpack will prove to lessen reliable provision of water for farming and lead to another dam standing high, dry and useless after spending hundreds of millions of dollars.
The Gila R. is already endangered by climatic change induced drought. Only one sentence in the DEIS Executive Summary (ES)barely mentions the serious challenge for southwest climate change with no relationship to the factor of climate change for the Gila R. The DEIS ES is incredibly deficient and ignores any analysis of climate change for the period the diversion dam will supposedly operate (ES-10):
“Access to water storage would support the continued presence of farming and provide resilience to climate change.”
Contrary to that statement the DEIS at 2-12 describes that for the next 30 to 50 years the following impacts are expected by climate analyses:
- Lower overall water supply
- Higher variability in extreme conditions of floods and droughts
- Higher uncertainty in projecting monsoon contributions to water supply
The Gila River is projected to have an average annual decrease in flow of 6 percent to 8 percent, while the San Francisco River is projected to have an average annual decrease of 11 percent. Future projections also indicate shifting of the spring snowmelt earlier in the year, which would affect the overall AWSA diversion timeframe. Annual extreme rainfall events are projected to increase in intensity due to higher temperatures, which can lead to increased flood events. That said, there is considerable uncertainty in the Global Climate Models projections, particularly in projecting monsoon contributions to water supply, and there are known deficiencies in the capability of these models to replicate certain historical aspects.
The impacts on land use from the diversion dam are unacceptable and poorly described by the DEIS. The net effect however would be the loss of more open space and conversion of that land to industrial and agricultural use (ES-9):
“Installation and operation of project components would result in direct, moderate long-term impacts by converting land use types from open space to industrial and agricultural use.”
Additional plans by the Forest Service would result in more reservoirs and additional open space loss.
- (ES-10)“Flow reductions from implementation of the NM Unit would affect fish and other wildlife, indirectly affecting recreation that depends on wildlife.”
- increased disturbance, potentially affecting regulating services associated with riparian/wetland habitat;
- long-term changes in instream water quantity or quality occur canadversely long-term cultural services that depend on instream water, such as recreation;
“Flow reductions from implementation of the NM Unit would affect fish and other wildlife, indirectly affecting recreation that depends on wildlife.” (ES-9) The economic value to New Mexico for the cultural values of the Gila R. are not set forth by the DEIS as they relate to the provision of jobs from activities such as tourism, wildlife watching, hunting and fishing As can also be seen in the graph below, there are substantial participants, significant expenditures and economic impact, jobs, salaries and wages, state and local taxes generated by those activities in New Mexico that rely on open space and an intact environment to participate:
Environmental Justice issues are skimmed over lightly by the DEIS. There are clear impacts that will be present due to loss of habitat such as diminished recreational opportunities and water quality such increased water salinity and adverse impact on fish. The impacts are simply waived away by statements of “no disproportionate Impacts” that avoids discussion just indicating that there are impacts that everyone would sharewithout giving specific description. That sort of analysis is remote from an EJ analysis.
Public Health Impacts are potentially substantial. Public exposure to Mosquito borne diseases (malaria, yellow fever, West Nile Virus, Zika, Encephalitis) can increase from standing water at reservoir sites.Potential for embankment failures and increased flood risks are poorly described. Agricultural runoff can be replete with numerous pesticides, herbicides, salts and metals that can adversely affect water quality, insects and animals.
Table 3-19 lists many endangered species in the proposed plan area. The effect of hydrological alteration will be adverse. Loss of habitat and availability of water, including habitat fragmentation, habitat conversion, water flow regime changes, soil erosion and compaction, and increased human presence and disturbancewill adversely affect them all.
Table 3-1.“Impacting Factors Associated with Past, Present, and Reasonably Foreseeable Future Actions” strongly indicates the need for a Programmatic Environmental Impact Statement (PEIS) since the sum effect of all such impacts is unknown and offers potential for severe adverse environmental impacts. Included impacts are from well construction, road construction, open pit copper mining, increased open grazing, Double E Ranch Habitat effects, pumping facilities and pipelines, groundwater pumping stations and water transmission pipelines, access roads, power lines, and related infrastructure, potential conflicts with state, regional and local water use demands and plans.
The prospects for successful mitigation are minimal for the many numerous impacts of the plan for any alternative except no action. The following statement from the DEIS is a good example of cultural imperialism:
- Given the project location, anticipated site density, and concerns of Native American tribes, mitigation of adverse effects on historic properties would be a costly and time-consuming endeavor for all action alternatives.
Nowadays it seems if there is any open space, roadless area or river left in New Mexico it is being considered for corporate profit development. The Gila R. should be respected for its long-term values and be free of the diversion plan.
Respectfully submitted,
David B. McCoy, J.D., Executive Director
Citizen Action New Mexico
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