Rick Brown sent this letter to the Bureau of Reclamation on November 20, 2019:

PUBLIC SCOPING COMMENT CARD

November 19 2019
Rick Brown, Secretary Green Party of Taos
info@greenpartytaos.org
P.O. Box 329
Taos, New Mexico 87571

I live in Taos County in an area where, like many other parts of the county, everyone is on a private well and does not presently have access to municipal water. I am also on an acequia, and I am a parciante and active user.

I am very concerned about the “Mutual Benefits Projects” (very misnamed in my opinion because they benefit very few people) for several reasons. As I mentioned I am on a private well which I depend on like everyone around me and in other parts of Taos County as well. The “Mutual Benefits Projects” call for drilling several new water supply wells into the deep aquifer which will have very large pumps to draw out a large amount of water. This has the potential to draw down the water table so that we would lose our wells.

We have learned that people like us who drilled their wells in recent years have no legal recourse if we were to lose our well. In the short term this would leave us with no access to running water for drinking, washing, and for our radiant heating system.

If the town were to extend water lines to us, I have reason to believe that our water would be much more expensive. The deep aquifer water is known to be highly mineralized which would require expensive treatment, the cost of which of course would be passed on to us. This would not be just an economic impact but a cultural impact to the area as well because many of the people whose families have been here for generations are struggling to make ends meets as it is, and having to pay higher water bills could be the last straw forcing people to leave. They would most likely be replaced by people moving in who are more affluent and used to a higher cost of living, or property being used as short term rental to tourists which we are already seeing.

And the fact is that we do not need new water supply wells with such a large capacity. The Town of Taos is consistently meeting its current water needs with its existing wells which have much smaller capacity, with the few disruptions we have had due to mechanical problems, not lack of water. If some wells need to be moved due to impacts to the Taos Pueblo land it should be possible to replace them with wells of similar capacity, sited to have a minimum impact to domestic wells.

My other concern is the impact of these wells to the acequias that many of us use to water crops and gardens and which also serve a vital function to recharge the shallow aquifer in the Taos Valley.

The model which is the basis for the Abeyta Settlement predicts that when the “Mutual Benefits Projects” are fully implemented the water table will be lowered to the extent that there will no longer be springs to feed the rivers that come down from the mountains and water our valley and feed our acequias. The Abeyta Settlement has proposed an answer to this which is Mitigation Wells. These are another series of wells into the deep aquifer which would be used to pump water uphill to put into the streams or acequias near the base of the mountains.

There are many problems with this idea. One is that, as noted previously, the deep aquifer water has high concentrations of minerals which would make it unfit to put into streams as-is because the water could be toxic to fish and wildlife that depend on the streams, and would also be detrimental to agricultural use because the minerals could build up in soil over time and damage the fertility of the soil. Treatment would be necessary and likely required for putting this water into streams. The cost of such treatment is not covered under the Abeyta Settlement and would have to be borne by mutual domestic water suppliers or acequia organizations that would be responsible for the wells. Operation and maintenance of the pumps and treatment systems would again be very expensive and this would change the whole character of the acequia system if it could continue to exist at all. This would be a huge cultural impact.

We are mostly small growers, few big operations or people with a lot of money are using the acequias. It is a very simple low-tech system maintained mostly with mattocks and shovels that uses natural gravity flow to bring water from the mountain streams to our fields following historic channels. We don’t have to pay much for water from the acequias, on ours we can earn most of our annual dues by participating in the yearly ditch cleaning. If we had to pay for expensive treated water and maintenance of the pumps and treatment system very few of us could afford to continue using the acequia. Continued agriculture in the Taos Valley would be limited to a few big operations that could afford to pay for the water, if that would be economical. The result would be that more and more former agricultural land would be sold off for residential to newcomers, more descendants of the original families would have to leave, and the community that presently exists around the acequias would be lost. And if there is much less agriculture using irrigation water we would lose the aquifer recharge that we are getting from it. And even our deep aquifer, which is finite, would eventually be drained.

To summarize, I request that the Programmatic Environmental Assessment be comprehensive, to cover the long term cumulative effects of all planned wells, not just the relatively small impacts of each one individually, and include all environmental, economic, and cultural impacts. My recommendation is that the “no action” alternative be chosen, that no federal dollars be appropriated for any part of the “mutual benefit projects” as currently conceived, and that new studies be done to develop ways to meet actual needs under a limited growth scenario that employs conservation first before developing additional water supplies.

Endorsed by the Green Party of Taos County