Rio Grande - Outstanding National Resource Waters

Comment From: Brian Long

6/13/22 @ 1:41 PM

I am a long term resident of Northern NM (since 1975)and have been doing wildlife research here for many years. One of my projects is studying the Pacific marten in the Rio Hondo watershed.

I have witnessed the ongoing destruction of marten habitat he...↓

Another species of concern is the American dipper which spends its entire life close to and in fast flowing rivers and streams. It is totally dependent on water-living invertebrates, fish, and insects, which it forages for underwater. The water must be clean for these insects & fish to thrive. I suspect that the decline in the number of historic nesting sites being used in recent years is most likely attributed to poor water quality due to development and faulty sewage treatment. This must be addressed and corrected, and this designation will hopefully help with corrective measures that will benefit us all. Thank you - Brian Long

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Comment From: Emily Sadow

6/13/22 @ 6:55 AM

The rivers of New Mexico are facing unprecedented pressure from ski areas, population growth, new development, climate change, and extreme drought, among other issues. They need all the protection they can get to survive these impacts. Countless peop...↓

With Respect,

Emily Sadow

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Comment From: Martin Heinrich

6/13/22 @ 12:00 AM

Dear Water Quality Control Commissioners: I write to you today about the Outstanding National Resource Waters (ONRW) petition put forth by the New Mexico Outdoor Recreation Division. Under the Clean Water Act, you have the authority to designate our...↓

Attachments:

Comment From: Our NM Waters Petition - 460

6/13/22 @ 12:00 AM

Dear Water Quality Control Commission: I am writing today to support the proposal to designate over 125 miles of waters along the Rio Grande, Rio Hondo, and Lake Fork, and in the headwaters of the Jemez River as Outstanding National Resource Waters (...↓

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Comment From: Ben Lujan

6/13/22 @ 12:00 AM

Dear Water Quality Control Commissioners, We write to you today in regards to the Outstanding National Resource Waters (ONRW) petition put forth by the NM Outdoor Recreation Division (NM-ORD). To deliver on the promise of clean water for future gener...↓

Attachments:

Comment From: Our NM Waters Petition - 1089

6/13/22 @ 12:00 AM

Dear Water Quality Control Commission: I am writing today to support the proposal to designate over 125 miles of waters along the Rio Grande, Rio Hondo, and Lake Fork, and in the headwaters of the Jemez River as Outstanding National Resource Waters (...↓

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Comment From: Phaedra Greenwood

6/12/22 @ 8:40 PM

I am a long-time resident of Arroyo Hondo and a parciente on the Acequia de Atalaya. For many years I have been concerned about the health of the Rio Hondo. Our household is dependent on this vital river for both irrigation and domestic use. Over the...↓

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Comment From: Diane Kulpinski

6/11/22 @ 3:48 PM

I'm looking to relocate out of Scottsdale, AZ and Taos is calling me back after my first & only visit 40 years ago.

Just last week I spent four days camping & hiking along the Rio Grande canyon. Observing the fishermen, rafters & even horseback riders...↓

Driving up to Taos Ski Village, I had run out of water & was getting thirsty. Surprise, surprise, there was the Rio Hondo rushing beside the roadway! I filled my water bottle with this beautiful, clear water, treated it with my UV filter and quenched my thirst. "What a gift," I thought.

I urge you to designate all waters in New Mexico under petition for ONRW as such.

We can not live without clean water. The Western US is drying up. It's critical TO ALL of us to protect our streams & rivers.

Thank you for your consideration.

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Comment From: Tiffany Rivera

6/10/22 @ 1:47 PM

Please find attached New Mexico Farm and Livestock Bureau's comments in opposition to the ONRW.

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Comment From: Defenders of Wildlife

6/10/22 @ 12:00 AM

Dear Water Quality Control Commissioners: Defenders of Wildlife supports protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (Rio San Antonio, East Fork Jemez River, and Redondo Creek) as Outstanding Nat...↓ional Resources Waters (ONRWs). The nominated waters are rich with ecological resources and have important cultural and recreational significance. Protecting these waters will ensure their water quality is protected for current and future generations. Defenders of Wildlife is a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities. Defenders of Wildlife is committed to protecting wildlands and wildlife in New Mexico and has 2.2 million members and supporters, 21,900 of which call New Mexico home. Our Southwest program works with diverse partners to protect aquatic and riparian areas throughout the region. ONRW designation of the more than 125 miles of nominated streams would protect the ecological, cultural, and recreational significance of these water bodies. The nominated waters provide vital habitat for a myriad of state and federal endangered and threatened species, state species of greatest conservation need, and special status species. For example, the Upper Rio Grande Gorge supports a population of the endangered Southwestern Willow Flycatcher (Empidonax trailii extimus), which is closely associated with healthy riparian areas. San Antonio and Redondo Creeks provide federally designated critical habitat for the Jemez Mountains salamander (Plethodon neomexicanus) and New Mexico meadow jumping mouse (Zapus hudsonius luteus), both of which are federal and state endangered species that rely on healthy riparian areas for survival. The petitioned waters also support a population of New Mexico’s endemic Rio Grande cutthroat trout (Oncorhynchus clarkia virginalis), a candidate for federal endangered species protection. Overall, at least 35 special status animal species inhabit the area within or around the nominated waters. Local communities also depend on clean water from the nominated river and stream segments to feed their acequia systems. For generations farmers have irrigated their crops with water from the Rio Hondo, Upper Rio Grande, and Jemez watershed. ONRW designation will ensure that cleanwater continues to flow downstream and protect this traditional use from new development and impacts. Finally, the nominated waters provide exceptional recreational opportunities for New Mexicans and visitors alike. Anglers, rafters, hikers, and hunters flock to the petitioned waters year-round to experience the unique beauty, world class rafting, and cold-water fishing of New Mexico. Protecting the nominated waters will ensure they remain prime recreation destinations for New Mexican and visitors. Defenders of Wildlife fully supports protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (Rio San Antonio, East Fork Jemez River, and Redondo Creek) and urges the Commission to designate these waters as ONRWs. Sincerely, Patricia Estrella

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Comment From: Defenders of Wildlife

6/10/22 @ 12:00 AM

Dear Water Quality Control Commissioners: Defenders of Wildlife supports protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (Rio San Antonio, East Fork Jemez River, and Redondo Creek) as Outstanding Nat...↓ional Resources Waters (ONRWs). The nominated waters are rich with ecological resources and have important cultural and recreational significance. Protecting these waters will ensure their water quality is protected for current and future generations. Defenders of Wildlife is a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities. Defenders of Wildlife is committed to protecting wildlands and wildlife in New Mexico and has 2.2 million members and supporters, 21,900 of which call New Mexico home. Our Southwest program works with diverse partners to protect aquatic and riparian areas throughout the region. ONRW designation of the more than 125 miles of nominated streams would protect the ecological, cultural, and recreational significance of these water bodies. The nominated waters provide vital habitat for a myriad of state and federal endangered and threatened species, state species of greatest conservation need, and special status species. For example, the Upper Rio Grande Gorge supports a population of the endangered Southwestern Willow Flycatcher (Empidonax trailii extimus), which is closely associated with healthy riparian areas. San Antonio and Redondo Creeks provide federally designated critical habitat for the Jemez Mountains salamander (Plethodon neomexicanus) and New Mexico meadow jumping mouse (Zapus hudsonius luteus), both of which are federal and state endangered species that rely on healthy riparian areas for survival. The petitioned waters also support a population of New Mexico’s endemic Rio Grande cutthroat trout (Oncorhynchus clarkia virginalis), a candidate for federal endangered species protection. Overall, at least 35 special status animal species inhabit the area within or around the nominated waters. Local communities also depend on clean water from the nominated river and stream segments to feed their acequia systems. For generations farmers have irrigated their crops with water from the Rio Hondo, Upper Rio Grande, and Jemez watershed. ONRW designation will ensure that clean - 2 - water continues to flow downstream and protect this traditional use from new development and impacts. Finally, the nominated waters provide exceptional recreational opportunities for New Mexicans and visitors alike. Anglers, rafters, hikers, and hunters flock to the petitioned waters year-round to experience the unique beauty, world class rafting, and cold-water fishing of New Mexico. Protecting the nominated waters will ensure they remain prime recreation destinations for New Mexican and visitors. Defenders of Wildlife fully supports protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (Rio San Antonio, East Fork Jemez River, and Redondo Creek) and urges the Commission to designate these waters as ONRWs. Sincerely, Patricia Estrella

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Comment From: All Pueblo Council of Governor...

6/10/22 @ 12:00 AM

RESOLUTION ALL PUEBLO COUNCIL OF GOVERNORS RESOLUTION NO. APCG 2022 – 11 SUPPORTING THE PROTECTION OF THE UPPER RIO GRANDE, JEMEZ HEADWATERS, LAKE FORK, AND HONDO RIVERS AS OUTSTANDING WATERS WHEREAS, the All Pueblo Council of Governors (APCG) is com...↓prised of the nineteen Sovereign Pueblos of New Mexico including the Pueblos of New Mexico including the Pueblos of Acoma, Cochiti, Isleta, Jemez, Laguna, Nambe, Ohkay Owingeh, Picuris, Pojoaque, San Felipe, San Ildefonso, Sandia, Santa Ana, Santa Clara, Santo Domingo, Taos, Tesuque, Zia, ad Zuni; and 1 Sovereign Pueblo, Ysleta Del Sur, located in the State of Texas, and: WHEREAS, the 20 Pueblos possess inherent government authority and sovereignty over our lands and which include the protection of language, culture, and tradition, WHEREAS, mineral exploration can cause serious impacts to water quality and the US Environmental Protection Agency estimates that 40 percent of the watersheds in the western United States are contaminated by pollution from hard rock mines; WHEREAS, mineral exploration is expected to increase nationwide and in New Mexico to meet demand under the Defense Production Act; WHEREAS, increased recreation in and use of New Mexico watersheds is putting strain on water quality and habitat; WHEREAS, Increased sediment loading from roads and development can impair water quality; WHEREAS, New Mexico’s watersheds are vulnerable to climate change with temperature impairment being the largest cause of impairment in New Mexico streams; WHEREAS, the APCG recognizes that the cold and clean waters of the Upper Rio Grande, Jemez, and Rio Hondo watersheds are part of the ancestral homelands of Pueblo peoples and are the lifeblood of the people and ecosystems that are connected to these watersheds; WHEREAS, Pueblos Peoples perform ceremonies using the sacred waters of these rivers; and WHEREAS, we as Native Peoples see the sacredness of the water ecosystem that sustain life to all the birds, animals, plants, and aquatic life that humans greatly benefit from;WHEREAS, Outstanding National Resource Water (ONRW) designation, as per 20.6.4 NMAC, protects water quality for future generations; WHEREAS, the headwaters of the Jemez River (East Fork of Jemez River, San Antonio Creek, and Redondo Creek), the Upper Rio Grande from the state line down to the Rio Pueblo de Taos, the Rio Hondo from the USFS boundary to the headwaters, and the Lake Fork of the Rio Hondo from the confluence of the Rio Hondo upstream to the headwaters have been nominated as ONRWS by the New Mexico Outdoor Recreation Division as per requirements in 20.6.4 NMAC; and WHEREAS, there is a hearing on this nomination set for June 14th, 2022 in front of the New Mexico Water Quality Control Commission. NOW THEREFORE BE IT RESOLVED THAT the APCG supports protecting the Upper Rio Grande from the Rio Pueblo upstream to the state line; the Rio Hondo from the U.S. Forest Service Boundary upstream to the headwaters; Lake Fork of the Rio Hondo from the Rio Hondo to the headwaters; the East Fork of the Jemez River from San Antonio Creek to its headwaters; San Antonio Creek from the East Fork of the Jemez River to the headwaters; and Redondo Creek from Sulphur Creek to its headwaters as Outstanding National Resource Waters (ONRWs). BE IT FINALLY RESOLVED THAT, the All Pueblo Council of Governors Chairman and his designee(s) do all that is necessary to carry out the intent of this Resolution. CERTIFICATION We, the undersigned officials of the All Pueblo Council of Governors hereby certify that the foregoing Resolution No. APCG 2022-11 was considered and adopted at duly called council meeting held on 26th day of May 2022, and at which time a quorum was present and the same was approved by a vote of 16 favor, 0 against, 1 abstain, and 3 absent. ALL PUEBLO COUNCIL OF GOVERNORS By: _______________________________ Mark Mitchell, APCG Chairman ATTEST: ___________________________________ Governor

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Comment From: Support Petition 121

6/10/22 @ 12:00 AM

I support protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (San Antonio Creek, East Fork Jemez River, and Redondo Creek) as Outstanding Waters (ONRWs). Protecting these waters will ensure that water q...↓

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Comment From: Tiffany Rivera

6/10/22 @ 12:00 AM

Dear Commissioners, Thank you for the opportunity to comment on the Outdoor Recreation Division’s petition to designate segments of the Rio Grande, Rio Hondo, Lake Fork, East Fork Jemez River, San Antonio Creek, and Redondo Creek as Outstanding Natio...↓nal Resource Waters (ONRWs). New Mexico Farm and Livestock Bureau [NMF&LB] is the largest agriculture organization in the state, representing more than 20,000 member families involved in all aspects of agriculture including dairy, livestock, fruits, and vegetables. NMF&LB is a grassroots advocacy organization which represents our members’ interests at a local, state, and national level. NMF&LB respectfully opposes the proposal submitted by the petitioners to designate segments of the Rio Grande, Rio Hondo, Lake Fork, East Fork Jemez River, San Antonio Creek, and Redondo Creek as ONRWs. NMF&LB adamantly opposes ONRW designations, these designations have the potential to severely limit economic growth while also placing additional restrictions and regulations on water and land use. In a state as arid and dry as New Mexico, continued access and use of water on our working lands is imperative. We actively support and encourage voluntary and incentive-based conservation and management practices and these efforts should be conducted through a grassroots effort and supported by citizens of the state. Water Data Data presented in the petition, which was collected by the New Mexico Environment Department’s Surface Water Quality Bureau (SWQB), described that the water quality was equal to or better than the numeric water quality criteria outlined in the New Mexico Administrative Code for each respective segment. This data indicates that the current management practices in place are providing sufficient protection to the water segments identified and are supporting a higher quality standard than those established in the administrative code. For this reason, we do not support any additional regulations to control water quality. Activities that Might Reduce Water Quality The petition highlights climate change, increased recreation without proper management, and wildfires as a few of the activities that may reduce water quality. This year New Mexico has already faced its fair share of wildfire and its impacts on our local communities. Wildfires across the state have severely damaged the landscape and compromised our water resources. New Mexico, along with the Federal Government, must rethink its approach to forest and watershed management, proactive and preventative management measures must be taken to better protect our resources. The designation of an ONRW cannot shield our natural lands from extreme wildfires, flooding, and the impairment of water resources that follow. Active management practices like forest thinning, grazing of hazardous fuels, and herbaceous weed control not only contribute to overall forest health, but also work to provide more beneficial and thriving habitat for wildlife. Additionally, we oppose this petition as it aligns with the Governor’s Executive Order (2021-052) which looks to protect 30% of the state’s land and waters by 2030. Our state’s farmers and ranchers are some of the best and most experienced stewards of our natural resources as their very livelihoods depend on land and water. In New Mexico, our state’s farmers and ranchers have voluntarily enrolled over 10.5 million acres in the Conservation Reserve Program, Conservation Stewardship Program, and the Environmental Quality Incentives Program. Our state’s farmers and ranchers continue to do their part by reducing their carbon footprints, participating in voluntary conservation programs, and working to restore and improve our state’s natural resources. We encourage more voluntary and incentive-based approaches to assist in caring for our environment and natural resources instead of additional mandates, restrictions, and designations. Lastly, we oppose the submitted proposal as we do not believe that the designation will mediate the root cause of the problem which it is trying to solve. Water quality, especially on our natural lands should be approached from a holistic perspective and not one that seeks to address only one specific component of the problem. The State and Federal Government must place more emphasis and designate additional resources to collectively improve the entire forest ecosystem. These improvements will result in healthier forests, better wildlife habitat, and higher water quality, all of which will lead to increased recreation and economic opportunities. Thank you for the opportunity to provide comment on the proposed ONRW designation. We encourage the commissioners to reject the petition and instead encourage a more comprehensive approach to watershed conservation and resource management. Best, Tiffany Rivera Director of Government Relations

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Comment From: Our NM Waters Petition - 496

6/09/22 @ 12:00 AM

Dear Water Quality Control Commission: I am writing today to support the proposal to designate over 125 miles of waters along the Rio Grande, Rio Hondo, and Lake Fork, and in the headwaters of the Jemez River as Outstanding National Resource Waters (...↓

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Comment From: Amigos Bravos

6/09/22 @ 12:00 AM

Dear Commission: As a statewide water conservation organization dedicated to protecting and restoring the waters of New Mexico, Amigos Bravos whole heartedly supports the designation of the Rio Hondo, Lake Fork of the Rio Hondo, the Upper Rio Grande ...↓

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Comment From: Diana Gries

6/09/22 @ 12:00 AM

Dear Water Quality Control Commission: I support protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters as Outstanding National Resource Waters (ONRWs). They have exceptional ecological, cultural, and recre...↓ational significance and must be protected against new pollution. The nominated waters provide vital habitat for a myriad of state and federal endangered and threatened species, state species of greatest conservation need, and special status species. For example, the Upper Rio Grande Gorge supports a population of the endangered Southwestern Willow Flycatcher (Empidonax trailii extimus), which is closely associated with healthy riparian areas. San Antonio and Redondo Creeks provide federally designated critical habitat for the Jemez Mountains salamander (Plethodon neomexicanus) and New Mexico meadow jumping mouse (Zapus hudsonius luteus), both of which are federal and state endangered species that rely on healthy riparian areas for survival. The petitioned waters also support a population of New Mexico’s endemic Rio Grande cutthroat trout (Oncorhynchus clarkia virginalis), a candidate for federal endangered species protection. Overall, at least 35 special status animal species inhabit the area within or around the nominated waters. Local communities also depend on clean water from the nominated river and stream segments to feed their acequia systems. For generations farmers have irrigated their crops with water from the Rio Hondo, Upper Rio Grande, and Jemez watershed. ONRW designation will ensure that clean water continues to flow downstream and protect this traditional use from new development and impacts. Finally, the nominated waters provide exceptional recreational opportunities for New Mexicans and visitors alike. Anglers, rafters, hikers, and hunters flock to the petitioned waters year-round to experience the unique beauty of New Mexico. Protecting these waters will ensure that water quality is protected for generations to come. I support the efforts to ensure the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters will continue to provide clean water for wildlife, downstream communities, and recreators. I urge the Commission to designate these waters as ONRWs. Sincerely, Diana

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Comment From: Ronald Loehman

6/08/22 @ 12:00 AM

As an angler and landowner in the Jemez watershed, the streams in the Jemez Mountains are special places for me. I first encountered them soon after moving to New Mexico in the early 1980s. With my young family, I spent many weekends hiking and campi...↓ng along streams in the Santa Fe National Forest. We enjoyed their cool, clear water and the lush vegetation that frequently grew along their banks, all of which were an extreme contrast to the dry, high desert terrain of much of New Mexico. Later, I started carrying a pack rod on my hikes and, after discovering how limited were my flyfishing skills, I joined New Mexico Trout and started attending their meetings and workshops. As my skills developed, I began to explore less accessible waters that offered more solitude and the opportunity to cast my fly to less wary trout. Sometimes the desire to explore new waters was so strong that I just hiked the stream without ever rigging up my fly rod. I called that virtual flyfishing, as I spotted places in the stream that I thought held trout and imagined the fly and presentation I would use as I continued walking past. To me, fly fishing is a solitary or almost solitary activity. It puts a premium on silence, stealth, and quiet observation and analysis of the water and its surroundings. The social part of fly fishing is in club activities such as meetings, workshops, and especially in volunteer conservation projects they sponsor. Those activities have kept me involved in New Mexico Trout for more than twenty-five years. New Mexico Trout is an all-volunteer, local, nonprofit organization whose mission is to promote the sport of fly fishing, to educate the public on the value of cold, clear streams and waterways, and to support restoration of those waters through donations and volunteer work. For example, we have donated money for supplies and provided volunteer labor for many of the barriers along USFS roads that prevent vehicles from driving down to sensitive riparian areas along the Rio Guadalupe and Rio Cebolla. We do an annual trash pickup along the Rio Guadalupe from the Gilman Tunnels to Porter’s Landing. We have cleaned up and restored dispersed campsites in riparian areas all along the Rio Guadalupe and Rio Cebolla. We helped rebuild the eroding access trail to a part of the East Fork of the Jemez that is very heavily used by picnickers and waders. These are just a few examples of the many ways we promote our mission to preserve and restore coldwater streams and their riparian areas in New Mexico. Over the years I have become very familiar with most of the streams in the Jemez Mountains through hiking, fishing, and participating in volunteer restoration and monitoring projects. The Jemez streams being considered for Outstanding Waters status by New Mexico’s Outdoor Recreation Division, together with the Rio Guadalupe, are particular favorites. I have hiked and fished the entire Rio San Antonio from its origin in the Valles Caldera National Preserve to where it passes under NM Highway 126. I have likewise hiked and fished the East Fork of the Rio Jemez from its origin in the Valle Grande all the way to where it joins the Rio San Antonio at Battleship Rock. Two equally deserving streams not being considered for ONRW status, the Rio Guadalupe and its Rio Cebolla tributary, are in my backyard. For many years, I have hiked, fished, and done restoration projects on them from their headwaters down to the southern SFNF boundary. My wife and I own the property on the Rio Guadalupe that borders the SFNF, as well as another parcel on the Guadalupe about two miles downstream. Together they encompass over thirty acres and a half mile of the stream. Over the years we have been privately restoring our property to a more natural condition to improve its function as wildlife habitat. Our property is serving as a personal laboratory for implementing different restoration practices. This work has led me to an intimate knowledge of stream function and how to improve it to enhance water quality and aquatic habitat. Some successes on our property include creation of a 5 acre marsh and wet meadow, increasing stream bank willow density, building in-stream features to narrow and deepen the stream channel, creating habitat for brown trout, chubs, and suckers, replacing invasive trees and forbs with native species, and supporting a substantial increase in numbers and species of birds. Two years ago, a beaver family took up residence, adding their expertise as hydraulic engineers to our efforts. In summary, I know the importance of these streams as places of refuge, solace, and recreation and I care very deeply about them. These Jemez streams are delightful places where visitors can go to refresh their minds and bodies. The waters are clear and cool, the surrounding vegetation is green, and the sounds of civilization are distant. Whether for a few hours, a weekend, or longer, visitors will go away feeling better and knowing that they want to come back. But all of New Mexico’s coldwater streams are at risk. The climate in the Southwest is doing exactly what scientists have been predicting for more than thirty years. New Mexico is getting hotter, drier and with less winter snow that melts earlier. Stream flows are decreasing, and runoff levels get ever lower. Water temperatures are too high on parts of some streams to support trout and other coldwater species. People depend on these streams for recreation, for irrigation, for watering their livestock, and indirectly for drinking water. Because of our warming climate we increasingly have less and lower quality water. Outstanding National Resource Waters status (ONRW), a state-level designation intended to preserve water quality, will provide an extra level of protection to these Jemez streams that are so important to us. New activities that degrade water quality will be prohibited, but already existing activities in a watershed, such as grazing or acequia use, can continue as before. This point needs emphasis. Existing activities, as well as private property rights, will not be impacted by ONRW designation. In fact, existing uses will benefit from the continued delivery of clean water that these protections require. The state rules establishing the program explicitly state that ONRW status protects all existing uses and rights, such as those of acequias, grazing, wood collecting, bird watching, hiking, and gathering of traditional plants and herbs. Landowners, local residents, and people living in the Jemez corridor will be blessed with cleaner water and healthier waterways, not increased regulation. Favorable publicity in the Jemez watershed prompted by ONRW status may bring additional resources to improve stream health and to address community concerns about water quality. People may say, “because this stream is so special, let’s do more to improve it!” Finally, we need to recognize that the New Mexico Environment Department already manages water quality on all of the state’s surface waters. ONRW designation doesn’t bring increased bureaucratic oversight or undermine local interests, but it does mean managing for a higher water quality standard, something that is increasingly important in light of the previous national administration’s attempted rollback of protections for most of the Jemez watershed’s surface waters. As a longtime angler and a landowner in the Jemez watershed, I strongly support ONRW designation for Rio San Antonio and the East Fork of the Rio Jemez. These designations will benefit all of us who rely on these waters, be it for recreation, agriculture, or cultural practices, and it will help ensure clean water flows through our communities in the years ahead.

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Comment From: Western Resource Advocates

6/07/22 @ 12:00 AM

Dear Water Quality Control Commissioners, I am writing today on behalf of Western Resource Advocates (WRA), in support of the petition to nominate the waters of the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (...↓Rio San Antonio, East Fork Jemez River, and Redondo Creek) as Outstanding National Resource Waters. WRA fights climate change and its impacts to sustain the environment, economy, and people of the West. We respect the different needs of New Mexico’s diverse communities and partner with them to develop a shared vision for progress—one that advances communities while protecting biodiversity. Our team of policy experts, scientists, economists, and attorneys has a 30-year history of working where decisions are made, sweating the details, creating evidence-based solutions, and holding decisionmakers accountable. This on-the-ground work advances clean energy, protects air, land, water, and wildlife—and sustains the lives and livelihoods of the West. The waters nominated in this petition comprise some of the most prized recreational opportunities in the state. From fishing in the Jemez headwaters, to rafting the Upper Rio Grande or hiking, camping, and birdwatching along the banks of the Rio Hondo and Lake Fork, these rivers provide treasured opportunities to their immediate community and residents across the state. The outdoor recreation industry is one of the fastest growing economic sectors in New Mexico, and the added protection of ONRW designation will ensure that these streams maintain their exceptional quality to support this growing industry and continue to support the state’s economy. Designating the 125 miles of nominated streams ensures that these waters continue to provide recreational, ecological and cultural benefits for generations to come. Through this designation, existing traditional and cultural uses such as farming and ranching will be protected, providing clean water and restricting future damaging projects that might impact water quality. In a state as dry as New Mexico, rivers and riparian areas provide critical habitat and unparalleled richness in species and diversity, which humans and wildlife depend on. Today we join with our partners across many sectors – from conservation non-profits to local governments, acequias to businesses – and urge you to designate all 125.9 miles of the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (Rio San Antonio, East Fork Jemez River, and Redondo Creek) as Outstanding National Resource Waters. Sincerely, Anjali Bean Healthy Rivers Senior Policy Analyst Western Resource Advocates

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Comment From: Ronald Loehman

6/03/22 @ 12:00 AM

Outstanding Waters Status Will Benefit Our Jemez Streams Submission to the New Mexico Water Quality Control Commission hearing on proposal to designate certain New Mexico streams as Outstanding National Resource Waters WQCC 21-62(R) 06/14/2022 By Ron...↓ald Loehman Albuquerque and Gilman, New Mexico ronloehman@gmail.com As an angler and landowner in the Jemez watershed, the streams in the Jemez Mountains are special places for me. I first encountered them soon after moving to New Mexico in the early 1980s. With my young family, I spent many weekends hiking and camping along streams in the Santa Fe National Forest. We enjoyed their cool, clear water and the lush vegetation that frequently grew along their banks, all of which were an extreme contrast to the dry, high desert terrain of much of New Mexico. Later, I started carrying a pack rod on my hikes and, after discovering how limited were my flyfishing skills, I joined New Mexico Trout and started attending their meetings and workshops. As my skills developed, I began to explore less accessible waters that offered more solitude and the opportunity to cast my fly to less wary trout. Sometimes the desire to explore new waters was so strong that I just hiked the stream without ever rigging up my fly rod. I called that virtual flyfishing, as I spotted places in the stream that I thought held trout and imagined the fly and presentation I would use as I continued walking past. To me, fly fishing is a solitary or almost solitary activity. It puts a premium on silence, stealth, and quiet observation and analysis of the water and its surroundings. The social part of fly fishing is in club activities such as meetings, workshops, and especially in volunteer conservation projects they sponsor. Those activities have kept me involved in New Mexico Trout for more than twenty-five years. New Mexico Trout is an all-volunteer, local, nonprofit organization whose mission is to promote the sport of fly fishing, to educate the public on the value of cold, clear streams and waterways, and to support restoration of those waters through donations and volunteer work. For example, we have donated money for supplies and provided volunteer labor for many of the barriers along USFS roads that prevent vehicles from driving down to sensitive riparian areas along the Rio Guadalupe and Rio Cebolla. We do an annual trash pickup along the Rio Guadalupe from the Gilman Tunnels to Porter’s Landing. We have cleaned up and restored dispersed campsites in riparian areas all along the Rio Guadalupe and Rio Cebolla. We helped rebuild the eroding access trail to a part of the East Fork of the Jemez that is very heavily used by picnickers and waders. These are just a few examples of the many ways we promote our mission to preserve and restore coldwater streams and their riparian areas in New Mexico. Over the years I have become very familiar with most of the streams in the Jemez Mountains through hiking, fishing, and participating in volunteer restoration and monitoring projects. The Jemez streams being considered for Outstanding Waters status by New Mexico’s Outdoor Recreation Division, together with the Rio Guadalupe, are particular favorites. I have hiked and fished the entire Rio San Antonio from its origin in the Valles Caldera National Preserve to where it passes under NM Highway 126. I have likewise hiked and fished the East Fork of the Rio Jemez from its origin in the Valle Grande all the way to where it joins the Rio San Antonio at Battleship Rock. Two equally deserving streams not being considered for ONRW status, the Rio Guadalupe and its Rio Cebolla tributary, are in my backyard. For many years, I have hiked, fished, and done restoration projects on them from their headwaters down to the southern SFNF boundary. My wife and I own the property on the Rio Guadalupe that borders the SFNF, as well as another parcel on the Guadalupe about two miles downstream. Together they encompass over thirty acres and a half mile of the stream. Over the years we have been privately restoring our property to a more natural condition to improve its function as wildlife habitat. Our property is serving as a personal laboratory for implementing different restoration practices. This work has led me to an intimate knowledge of stream function and how to improve it to enhance water quality and aquatic habitat. Some successes on our property include creation of a 5 acre marsh and wet meadow, increasing stream bank willow density, building in-stream features to narrow and deepen the stream channel, creating habitat for brown trout, chubs, and suckers, replacing invasive trees and forbs with native species, and supporting a substantial increase in numbers and species of birds. Two years ago, a beaver family took up residence, adding their expertise as hydraulic engineers to our efforts. In summary, I know the importance of these streams as places of refuge, solace, and recreation and I care very deeply about them. These Jemez streams are delightful places where visitors can go to refresh their minds and bodies. The waters are clear and cool, the surrounding vegetation is green, and the sounds of civilization are distant. Whether for a few hours, a weekend, or longer, visitors will go away feeling better and knowing that they want to come back. But all of New Mexico’s coldwater streams are at risk. The climate in the Southwest is doing exactly what scientists have been predicting for more than thirty years. New Mexico is getting hotter, drier and with less winter snow that melts earlier. Stream flows are decreasing, and runoff levels get ever lower. Water temperatures are too high on parts of some streams to support trout and other coldwater species. People depend on these streams for recreation, for irrigation, for watering their livestock, and indirectly for drinking water. Because of our warming climate we increasingly have less and lower quality water. Outstanding National Resource Waters status (ONRW), a state-level designation intended to preserve water quality, will provide an extra level of protection to these Jemez streams that are so important to us. New activities that degrade water quality will be prohibited, but already existing activities in a watershed, such as grazing or acequia use, can continue as before. This point needs emphasis. Existing activities, as well as private property rights, will not be impacted by ONRW designation. In fact, existing uses will benefit from the continued delivery of clean water that these protections require. The state rules establishing the program explicitly state that ONRW status protects all existing uses and rights, such as those of acequias, grazing, wood collecting, bird watching, hiking, and gathering of traditional plants and herbs. Landowners, local residents, and people living in the Jemez corridor will be blessed with cleaner water and healthier waterways, not increased regulation. Favorable publicity in the Jemez watershed prompted by ONRW status may bring additional resources to improve stream health and to address community concerns about water quality. People may say, “because this stream is so special, let’s do more to improve it!” Finally, we need to recognize that the New Mexico Environment Department already manages water quality on all of the state’s surface waters. ONRW designation doesn’t bring increased bureaucratic oversight or undermine local interests, but it does mean managing for a higher water quality standard, something that is increasingly important in light of the previous national administration’s attempted rollback of protections for most of the Jemez watershed’s surface waters. As a longtime angler and a landowner in the Jemez watershed, I strongly support ONRW designation for Rio San Antonio and the East Fork of the Rio Jemez. These designations will benefit all of us who rely on these waters, be it for recreation, agriculture, or cultural practices, and it will help ensure clean water flows through our communities in the years ahead.

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Comment From: Patrick Lane

6/02/22 @ 3:50 AM

Please see the attached document outlining the support of The Pew Charitable Trusts for the designation of the waters to be considered under WQCC 21-62 (R) as Outstanding National Resource Waters. We thank the New Mexico Water Quality Control Commiss...↓

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Comment From: Robinson Kurth

5/23/22 @ 12:38 PM

Please continue to support efforts for clean, protected waters in NM ! So many of our waters need to be designated as Outstanding National Resource Waters (ONRW). With drought and climate changes, our state's limited waters need protection and rest...↓

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Comment From: CAVU

5/16/22 @ 12:00 AM

Dear Water Quality Control Commissioners, Climate Advocates Voces Unidas (CAVU) writes today to express our fervent and strong support for protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (San Antonio...↓

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Comment From: NM Wildlife Federation

5/11/22 @ 12:00 AM

Dear Water Quality Control Commissioners, The New Mexico Wildlife Federation strongly supports the pending outstanding waters designations for the Upper Rio Grande, the Lake Fork of the Rio Hondo and the headwaters of the Jemez River. Founded in 1914...↓

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Comment From: Robert Pearson

4/25/22 @ 7:42 AM

Clearly, water is one of the fundamental natural resources anywhere.

Due to the negative effects of climate change, New Mexico (and other western states) have to get deadly serious about water conservation, restoration of watersheds, and other water q...↓

One particular way these important goals can be accomplished is by designating the following areas as Outstanding National Resource Waters (ONRWs):

The upper Pecos watershed

The upper Rio Grande

The Rio Hondo

The upper Jemez/San Antonio and Redondo (the latter being

In the Valle Caldera National Preserve)

All residents and visitors to New Mexico must have clean water available for a myriad of purposes too obvious and numerous to mention here.

As an extremely concerned member of the public, I ask you to do the right and necessary thing to protect the State's precious clean water resources. Time is rapidly slipping away.

Sincerely,

Professor Robert D. Pearson Jr.

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Comment From: MARGARET BELL

4/17/22 @ 2:09 PM

I support clean water in New Mexico and designating these waters as ONRWs.

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Comment From: NM Acequia Commission

3/24/22 @ 12:00 AM

Dear Water Quality Control Commissioners, ONRW designation for New Mexico’s precious water resources will support and protect existing community uses, such as ranching and farming, while prohibiting new pollution from impacting our watersheds. For ce...↓

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Comment From: NM Trout

3/18/22 @ 12:00 AM

Dear Commission Members: New Mexico Trout enthusiastically supports the proposal by the New Mexico Outdoor Recreation Division and the New Mexico Department of Game and Fish to designate parts of the Rio San Antonio, the Rio Jemez and the Rio Guadalu...↓pe as Outstanding National Resource Waters. New Mexico Trout is a three hundred fifty-member-strong, 501(c) 3, local, all-volunteer organization dedicated to preserving and improving trout habitat and trout fishing in the state of New Mexico. These three streams are very familiar to us and we care very deeply about them. Our members fish them regularly. We volunteer on conservation projects on these streams in support of the US Forest Service, the Valles Caldera National Preserve, and the NM Department of Game and Fish. We have provided monetary support for equipment and supplies to the Forest Service and to area grazing permittees for protecting and restoring these waters. New Mexico Trout considers the Rio Guadalupe to be it home waters. In fly fishing parlance this signifies the stream that the club knows best, has special affection for, and feels most protective of its health. For more than twenty-five years New Mexico Trout has done many volunteer projects with the Jemez District on the Guadalupe. Each year the Club conducts a trash pickup along FR 376 from the Gilman Tunnels to Porter’s Landing. We collect and haul away many pickup loads of trash from the corridor that get tossed on it over a typical season. We built the original buck and pole barriers and the more recent bollard barriers that block illegal vehicle access to the stream and that have substantially reduced a major source of pollution, erosion, and silt flowing to the stream. New Mexico Trout paid for and installed the interpretive panels along FR 376 that promote conservation values and explain the benefits of clean, freeflowing streams to the public. ONRW status will provide an extra level of protection to these Jemez streams that are so important to us. New activities that degrade water quality will be prohibited. We have heard that a few individuals are opposed to ONRW status for these streams because they believe that it will restrict existing activities, particularly those where any of the streams might flow through private property. This is a complete misunderstanding of the meaning of ONRW. Reference to the statute and supporting documents shows that ONRW status protects all existing uses and rights, such as those of acequias, grazing, wood collecting, bird watching, hiking, and gathering of traditional plants and herbs. ONRW status does provide an extra level of protection against degradation of water quality by new activities. We welcome this new tool to prevent activities that threaten our streams and therefore help keep our public waters clean and pure for those who come after us. In summary, we strongly urge the Commission to designate these segments of the Rio San Antonio, the Rio Jemez, and the Rio Guadalupe as Outstanding National Resource Waters. NM Trout members believe that this extra protection will help preserve clean, cool mountain streams for future generations. This is important to us because we treasure the clear, cool water in Jemez Mountain streams that harbors the trout we pursue. Sincerely yours, Ronald E. Loehman Conservation Chairman ronloehman@gmail.com (505) 328-1489 New Mexico

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Comment From: Taos Valley Acequia Associatio...

3/05/22 @ 12:00 AM

Dear Water Quality Control Commissioners, The Taos Valley Acequia Association supports protecting the Rio Hondo and the Upper Rio Grande as Outstanding Waters (ONRWs). Protecting these waters will ensure that water quality is protected for generation...↓

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Comment From: American Rivers

2/15/22 @ 12:00 AM

Dear Water Quality Control Commissioners, American Rivers supports the Outdoor Recreation Division’s petition to protect the following as Outstanding Waters (ONRWs): Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters ...↓(Rio San Antonio, East Fork Jemez River, and Redondo Creek). ONRW designation of these waters will ensure that water quality is protected for generations to come. American Rivers believes a future of clean water and healthy rivers for everyone, everywhere is essential. Since 1973, we have protected wild rivers, restored damaged rivers, and conserved clean water for people and nature. With headquarters in Washington, D.C., and 300,000 supporters, members, and volunteers across the country, we are the most trusted and influential river conservation organization in the United States. Our Southwest River Protection Program utilizes a suite of strategies with diverse partners to inform, protect, and celebrate the long-term resilience of the most ecologically and culturally important rivers across New Mexico, Colorado, Utah, and Arizona. As such, American Rivers is invested in durable protections for these nominated waters in northern New Mexico. ONRW designation of the 125.9 miles of nominated streams would recognize the recreational, cultural, and ecological significance of these six water bodies. Designation will support and protect existing community uses, such as ranching and farming, while prohibiting new pollution from impacting the watershed. For generations, the local community has depended on clean water in the Rio Hondo, Upper Rio Grande, and Jemez watersheds to water livestock and feed acequia systems. This designation will ensure that clean water continues to flow downstream to these critical stakeholders and protect these traditional uses from new development and impacts. These waters are rich with ecological resources, and they also provide significant recreational opportunities for both New Mexicans and visitors alike. Indeed, within the petition’s nominated waters, 52.2 miles of the Rio Grande and 11 miles of the East Fork Jemez River are already 2 designated under the national Wild and Scenic Rivers Act for their outstanding values. ONRW designation complements and strengthens, but does not duplicate, water quality protections for these Wild and Scenic Rivers. In fact, by increasing the reaches of protected rivers through the proposed ONRW nominations, these invaluable Wild and Scenic Rivers will have their water quality protected at watershed scale. In addition, ONRW protections will help draw much needed attention for restoration, and water and fuel management projects throughout these watersheds. American Rivers enthusiastically supports the efforts to ensure the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (Rio San Antonio, East Fork Jemez River, and Redondo Creek) will continue to provide clean water to New Mexico’s communities and wildlife. Sincerely,

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Comment From: Taos County Chamber of Commerc...

2/02/22 @ 12:00 AM

Dear Water Quality Control Commissioners, Taos County Chamber of Commerce supports protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (Rio San Antonio, East Fork Jemez River, and Redondo Creek) as Outst...↓

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Comment From: NM Wild

1/13/22 @ 12:00 AM

Dear Water Quality Control Commissioners, New Mexico Wilderness Alliance (New Mexico Wild) supports protecting the Rio Hondo, Lake Fork of the Rio Hondo, Upper Rio Grande, and Jemez River Headwaters (Rio San Antonio, East Fork Jemez River, and Redond...↓

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