The county is in the midst of updating its Long Range Water Supply Plan. The goal of this plan is to analyze water demand for the county, including LANL, and lay out options for meeting that demand, with a planning horizon of 40 years.
The Dept. of Public Utilities, working with a consultant, has completed a second draft of the plan (revised figures and tables are in separate files). This draft was influenced by our feedback on the first. It is currently scheduled for consideration by the BPU at its March 15 meeting; if approved, it then goes to the County Council.
In our view, the second draft is better but still has several important problems. Factors which favor development of San Juan-Chama water are well-represented, but factors which don’t are included only briefly or declared out of scope. For example, a key scenario is that the county might choose to supply LANL without LANL contributing any of its water rights; this scenario isn’t justified and seems implausible to us. On the other hand, the draft is dismissive of scenarios such as conservation reducing demand, return flows being credited (treated wastewater and re-injection of decontaminated water), and groundwater contamination addressed with upstream wells or treatment. The draft also ignores environmental, historic, and quality of life issues that may affect development of San Juan-Chama water in White Rock Canyon.
We argue that all significant, credible factors deserve a careful, open-minded treatment. We have asked the DPU to revise the plan again to address these issues.
It is important to emphasize that we don’t advocate giving up the county’s San Juan-Chama water rights. Rather, we want these rights to be deployed in an evidence-based, thoughtful way that respects Los Alamos’ conservation and science values. Because there is no water shortage anticipated and our current beneficial use of San-Juan Chama water rights is stable (we lease the water to the Bureau of Reclamation to support the silvery minnow in the Rio Grande), we have plenty of time to figure out how to use the water rights in a way consistent with these values.
The three key problems we identified in the second draft are:
1.— Water conservation opportunities aren’t considered properly. We realize that the draft is not a conservation plan, but because conservation significantly affects demand, it should be considered carefully.
The draft includes a conservation scenario of per capita water usage the same as Santa Fe, but no analysis of what conservation levels are plausible or why matching Santa Fe is an appropriate goal. We asked the DPU for evidence-based high/low/medium conservation scenarios, similar to what the draft already contains for several other demand factors.
Another concern we have is mixing conservation with unrelated demand factors. The draft's assessment of LANL water demand is based on LANL documents that contain only a single scenario. The DPU rightly understands that there is uncertainty in how much water LANL will use, but the draft then mitigates this uncertainty by assuming any LANL underestimates are offset by water conservation. This seems bizarre to us — the two factors are separate and require separate uncertainty analysis.
2. — San Juan-Chama surface water’s value in a drier climate is overstated. The county has rights to surface water that originates in the San Juan River basin and is transported under the Continental Divide to the Chama River and then the Rio Grande.
The draft presents this water as a hedge against localized contamination issues in groundwater, which the current source of Los Alamos water and of sufficient volume to last hundreds of years. It correctly points out that surface water is different than groundwater but not that it’s a good diversification strategy. In particular, surface water is less reliable than groundwater in the anticipated drier climate, and drilling new groundwater wells upstream of contamination is considered by the draft only in passing.
3. — Impacts on White Rock Canyon are ignored. The San Juan-Chama water rights are for surface water, not groundwater. This can be fudged, however, by extracting groundwater that is about to become surface water; this process happens at springs. Thus, development of San Juan-Chama water by drilling wells, which is the only way the DPU has proposed doing so, will necessarily impact springs; the only question is which ones and by how much. Many of these springs support state-listed sensitive species. Further, development risks impacting the historic and cultural resources protected by the White Rock Canyon Archaeological District.
The DPU claims that these issues are out of scope for the plan. However, developing the canyon has a lot of potential obstacles, including environmental, historic, and cultural issues as well as the effects on folks’ homes. Potential obstacles are analyzed in detail for many of the scenarios already in the plan, but the DPU feels these obstacles are out of scope. We disagree.
Our detailed analysis of this second draft, as expressed in our letter to the BPU, is below. You can also read the PDF version. We do share key goals with the DPU, specifically conservation (“a common goal of our two organizations”, as stated by the DPU) and a desired to make the water plan as strong as it can be.
We are continuing to collaborate with the DPU on this issue and will publish updates as needed. If you’re interested in helping out, please get in touch.
Dear Mr. Johnson and BPU members:
I write on behalf of the Pajarito Conservation Alliance, a non-profit community organization that supports the ecosystems and outdoor experience of the Pajarito Plateau.
We have reviewed the Long Range Water Supply plan, revised, to be considered at the February 15 BPU meeting. This letter comprises our critique in part.
We appreciate Mr. Alarid’s thoughtful reply letter dated February 3 and sent to us February 8. Further, we appreciate that the plan revision includes detailed changes — this makes re-critique easier. We are glad that Mr. Alarid points out we share conservation goals; in turn, we emphasize that we share the goal of making the Long Range Water Supply Plan as strong as it can be.
In terms of logistics, we are concerned by the time frame allotted for feedback. We received the response letter and a pointer to the revised documents on February 8; the BPU is to consider the plan on February 15. Seven days are not sufficient to review over 100 pages of technical documents, write a high-quality response, and transmit said response to BPU members in time for them to read and consider it. The stated review period for the first revision in November was even shorter: the story ran in the Monitor on November 20 and feedback was requested by November 22. In our experience, 30 days is a good balance between enough time for careful feedback and completing business efficiently.
Accordingly, our critique presented in this letter is preliminary. We urge the board to table consideration until its March meeting, to properly allow for public comment.
The bulk of this letter summarizes the points of our original critique and how they have been addressed in the revision. Page numbers refer to Exhibit A of the agenda packet.
1. Our first concern with the November draft was that it did not sufficiently consider water conservation. The current draft is improved, but much of our original critique stands.
We realize that the plan is not a conservation plan. However, because conservation significantly affects demand, its possible effects should be considered thoroughly.
1.1. — Impact of conservation on demand not quantified.
The current draft still uses conservation to offset uncertainty in LANL demand (p. 43), which is still of concern. Conservation and LANL demand are independent and should be treated independently.
1.2 — Conservation opportunities understated.
Using Santa Fe’s current per-capita demand is an improvement, and this direction should be further developed. Evidence-based high, medium, and low conservation scenarios should be included in the plan.
1.3 — Legal requirements for conservation planning unclear.
The explanation in the response letter seems plausible, and we encourage the DPU and consultants to include such an explanation in the plan itself.
2. Our second concern was that San Juan-Chama water is not a good hedge against supply/demand imbalance. Again, the current revision is improved, but much of our critique stands.
2.1 — Reliability of San-Juan Chama water in a drier climate.
The revision is significantly improved in this area, which we appreciate. The basic argument is that diversification is “geographically and in terms of water rights” (p. 24). We point out that wells upstream of potential contamination also diversify geographically.
However, the revision does not address our core concern, which is that our groundwater is essentially immune to climate dryness on a horizon of several hundred years, well beyond the 40-year planning horizon. Surface water is different, but how does it help in a drier climate when groundwater is unaffected?
Streamflow estimates reflecting climate change were added (p. 54), which is an improvement. However, just like the rest of the document, high/low credible scenarios are essential here.
2.2 — New groundwater wells upstream of potential contamination.
The response letter states that “a cost-benefit analysis for drilling replacement wells is out of scope”.
Let us clarify our concerns. The first draft already presents a cost-benefit analysis, because it cites specific costs: difficulty of obtaining drilling permits, “technical and legal fees”, and other municipalities’ negative experiences. Our critique is two-fold: (a) if any cost-benefit analysis is presented, as the current revision does, it must be a reasonably complete analysis, and (b) drilling upstream wells is a credible alternative to developing SJC water and merits a similar quality of analysis.
2.3 — LANL is unlikely to force water supply from the county without rights.
The response letter’s reasoning for this scenario is that it represents a “worst case scenario”.
We agree that worst-case scenarios are important, but we are concerned about the plausibility of this one. Because this factor is crucial to the argument that SJC water development is needed, it should be well-justified to prevent it from being challenged in possible future water-rights disputes. The form of justification we envision is to describe a plausible set of circumstances that would lead the county and LANL to agree that the county will supply LANL with water but not contribute its water rights.
2.4 — Effects of possible return flow credits.
The response letter explains that “the consultants feel that it would be premature to assume that any return flow credits would be obtained”.
Return flow credits is a plausible factor increasing supply, meriting a high/low analysis like many other factors in the plan. Both obtaining and not obtaining return flow credits are plausible, and both scenarios should be included.
3. — Our third concern was that the impacts of SJC water development on White Rock Canyon were not considered. The response letter states that the SJC project “is entirely separate from this effort” and that considering impacts on WRC is out of scope.
Because the plan analyzes the case for developing SJC water, we argue that possible constraints on how that water might be developed are within scope. Specifically, it is plausible that water development in White Rock Canyon — the logical place to develop SJC water — would turn out to be difficult or impossible for cultural and/or environmental reasons. These potential obstacles are in scope and should be included in the plan.
Such treatment would be consistent with the potential obstacles cited for various other approaches already in the plan.
We appreciate the softened language on the inevitability of SJC water development, and we believe another revision of the plan is needed in order to add high/low scenarios on the factors cited above.
Specifically, factors pointing towards development of SJC water (e.g., LANL not offering rights but forcing supply, assuming no return credits) are well-represented in the report, but factors pointing away (conservation, vulnerability of surface water to climate change, possibility of return flow credits, treatment of contaminated groundwater, new wells upstream of contamination) are represented only briefly or declared out of scope.
All significant, credible factors need high/low scenarios included, and the conflation of LANL uncertainty with conservation should be removed. (A new style of plotting would help avoid a profusion of one-per-scenario figures. We would be happy to assist in visualization.)
We believe that the revised plan has improved but still needs another revision cycle in order to address the remaining issues detailed above. We appreciate the opportunity to engage in this process and look forward to further collaboration.
/s/ Reid Priedhorsky
Secretary, Pajarito Conservation Alliance