Current Action:
Public Comments - Triennial Review of Water Quality Standards (comments due September 30, 2008)
Dear Ms. Homer:
Thank you for the opportunity to provide public comments about the August 2008 Discussion Draft of New Mexico’s Water Quality Standards for the Triennial Review, which is required by the Clean Water Act. Generally, I support the draft changes made by the New Mexico Environment Department (NMED). Specifically:
1. I support the revised definition of “perennial” which ensures that waters that may be impacted by climate change continue to receive the appropriate protections.
2. I oppose the limited aquatic life use and urge NMED to remove this use from the standards. The limited aquatic life use is used only several times in the standards and is not necessary as segment specific criteria could be used in these limited situations. The presence of a whole separate use with special weaker standards only encourages the application of such a use.
3. I support the NMED proposal to include criteria for plutonium, americium and tritium in order to protect public water supplies along the Rio Grande from the Rio Pueblo de Taos to the Elephant Butte Reservoir. 20.6.4.105, 106 and 114 NMAC. The health-based criteria for these radionuclides address impacts from their migration from Los Alamos National Laboratory (LANL) to waters soon to serve large populations living along the Rio Grande.. In order to protect public health and the environment, I support further lowering the plutonium standard from the proposed 1.5 picocurie per liter (pCi/L) to 0.15 pCi/L (the state of Colorado has adopted the more protective standards of .15 pCi/L); the americium standard from 1.9 pCi/L to 0.15 pCi/L; and the tritium standard from 4,000 pCi/L to 400 pCi/L.
4. I support including a water quality standard for perchlorate in 20.6.4.900.J. In order to protect public health and safety, New Mexico should adopt a perchlorate standard of 1 microgram per Liter (ug/L) for domestic water supply. Criteria for irrigation, wildlife habitat and livestock watering should be developed as well. New Mexico has increasing problems with perchlorate contamination as is evidenced by the numerous perchlorate hits in both ground and surface water in the past ten years. Although there is currently no federal drinking water standard for perchlorate, the EPA has considered a reference dose of 1ug/L for perchlorate in drinking water.
5. I oppose NMED not taking action to ensure that intermittent waters on Los Alamos National Laboratory property are protected with the same standards as other intermittent waters in the state. Currently the state standards apply weaker protections to LANL intermittent waters. NMED should ensure that LANL is not given special, weaker standards.
6. I oppose the lack of new water quality standards for Pharmaceuticals and Personal Care Products (PPCPs). EPA’s lack of action to protect public health from PPCPs by not setting national standards does not excuse NMED from its duty to protect New Mexico water quality and public health. I urge NMED to adopt water quality standards for key PPCPs such as sulfamethoxazole, loxacin, DEET, TDCPP, caffeine, and tris (2-chlorethyl) phosphate, all of which have been detected in New Mexico’s waters.
7. I support the proposed Narrative Biocriteria in order to protect biological integrity. 20.6.4.13.M NMAC.
8. I oppose NMED’s proposed changes to the Domestic Water Supply criteria when the changes disregard the potential health effects of people who are both drinking water and eating fish from a water source.20.6.4.900.J NMAC.
9. I support the revised standards for unclassified ephemeral, intermittent and perennial waters, which will provide stronger protections and address EPA comments on amendments adopted during the last Triennial Review. 20.6.4.11.H, 15D, 97, 98, 99 NMAC.
10. I support the new/revised criteria based on EPA updates which will add aquatic life criteria for diazinon and nonylphenol; and update the domestic water supply and human health-organism only criteria for chlorobenzene, cyanide, 1,2-dichlorobenzene, 1,4-dichlorobenzene, 1,1-dichloroethylene, 1,3-dichloropropene, endrin, ethylbenzene, gamma-BHC (lindane), hexachlorocyclopentadiene, toluene, 1,2-transdichloroethylene, 1,2,4-trichlorobenzene and vinyl chloride. 20.6.4.900.J NMAC.
11. I support clarification of designated contact uses, which will change “secondary contact” (fishing/boating with limited contact) designated use to “primary contact” (swimming/water skiing) where the associated criteria protect for primary contact. 20.6.4.100-899 NMAC.
12. I oppose toxic mixing zones. Mixing zones for toxic substances such as found on the chart at 20.6.4.900 J should be prohibited.
Click here to let your comments be heard.
Previous Actions:
Urge Mayor Chávez to Support the Clean Water Restoration Act.
As the co-chair of the U.S. Conference of Mayors Water Council, Mayor Chávez has the ability to urge the Conference to come out in support of the Clean Water Restoration Act, an important piece of federal legislation that would restore crucial water quality protections to New Mexico’s waters.
Recent decisions by the U.S. Supreme Court and federal agencies have created confusion about whether certain waters will remain protected by the Clean Water Act – the nation's most important law limiting water pollution. As an arid state with many small rivers and streams that do not flow year round, up to 94% of New Mexico’s waters are at risk of losing Clean Water Act protections.
New Mexico is much more at risk of losing critical clean water protections than other wetter states. At risk include waters in closed basins, which make up 20% of New Mexico’s land area, as well as smaller non-perennial rivers and streams. Many New Mexicans depend upon water in these closed basins and intermittent streams for drinking water, irrigation, and recreation. New Mexico’s Playa Lakes, which provide drinking water and habitat for 59% of New Mexico’s vertebrate species, are also threatened.
The Clean Water Restoration Act would restore Clean Water Act protections that applied to New Mexico’s rivers and streams before the recent Supreme Court decisions. These protections were in place for almost 30 years, and we desperately need them back! Please call Mayor Chávez and urge him to support the Clean Water Restoration Act.
Call and/or email Mayor Chávez and let him know how important the Clean Water Restoration Act is for protecting New Mexico’s rivers and streams.
Mayor Martin J. Chávez
(505) 768-3000
Help protect New Mexico’s waters.
Ask the administration to change course on a new policy that puts New Mexico’s waters at risk.
Click here to protect water quality!
Recent decisions by the U.S. Supreme Court and federal agencies have created confusion about whether certain waters will remain protected by the Clean Water Act – the nation's most important law limiting water pollution. As an arid state with many small rivers and streams that do not flow year round up to 94% of New Mexico’s waters are at risk of losing Clean Water Act protections.
The Bush administration is now taking public comment on a policy that further confuses the situation and jeopardizes thousands of streams and wetlands. Take action today!
Click here to urge the Bush administration to change course and protect New Mexico’s waters from destruction and pollution.
The policy affects 20 million acres of "isolated" wetlands and nearly 2 million miles of streams that do not flow year-round. Even in the case of water bodies that provide drinking water, the guidance as written does not provide protection.
Urge the EPA and the Army Corps of Engineers to revise their policy. Please send a comment by the end of the comment period on January 21st.
Ask Heather Wilson to support the Clean Water Restoration Act!
Listen to our radio ad urging Heather Wilson to support the Clean Water Restoration Act.
For more information Click Here!
To Protect Clean Water, Contact Your Congressperson!
The U.S. House of Representatives is poised to act this fall on what could be the most important clean water legislation in 35 years: The Clean Water Restoration Act (H.R. 2421). We are asking all Amigos Bravos supporters to place calls to the three New Mexico U.S. Representatives – Representative Heather Wilson, Representative Tom Udall, and Representative Steve Pearce – to ask them to support the Clean Water Restoration Act (H.R. 2421).
This bipartisan bill is needed now to ensure that all of the nation’s streams, headwater tributaries, wetlands and other waters remain protected from pollution by the federal Clean Water Act. It will reaffirm that the Clean Water Act was intended to protect all of the waters of the United States, from big rivers to small streams. Passage of this historic legislation will ensure that Amigos Bravos will be able to continue to promote strong environmental protection of New Mexico’s streams, wetlands and other waterways.
Please call the offices of your U.S. Representatives in Washington DC anytime between 9 am – 6 pm Eastern Time to ask for support of the Clean Water Restoration Act.
How to Make the Calls:
1. Representatives Heather Wilson and Steve Pearce are not currently co-sponsors of the Clean Water Restoration Act (H.R. 2421). Please call them and urge them to become a co-sponsor.
Rep. Heather Wilson: 202-225-6316
Rep. Steve Pearce: 202-225-2365
Once connected, you can ask to speak to your representative directly. If you cannot speak to your Representative, or would rather speak with staff, ask to speak to the staff person who handles environmental issues. If that person is unavailable, then ask to speak to another staffer who works on policy or constituent issues. Be sure to leave a message(s) if you cannot reach a staffer in person.
The message is simple: Here is what you can say – Please support the Clean Water Restoration Act (H.R. 2421) NOW. The Clean Water Restoration Act will provide environmental protection for ALL of our nation’s waters. The Act will ensure protection of waterways in all of the communities in New Mexico. The House needs to pass this bill ASAP.
2. Representative Tom Udall is already a co–sponsor of the Clean Water Restoration Act. Please call and thank him for supporting the bill and ask him to use his influence to bring the bill to the House floor for a vote. You could also request that he speak to his House colleagues about supporting the bill.
Rep. Tom Udall: 202-225-6190
3. If you do not live in New Mexico: Please call your own Representative. If you do not know the phone number you can call 202-224-3121 for Capitol Information and ask for your Representative’s office.
Let Us Know How the Calls Go!
Thank you very much for taking action to protect clean water.
We would appreciate hearing about your telephone conversations with Members of Congress and staffers. You can send any and all reports to Rachel Conn with Amigos Bravos at rconn@amigosbravos.org. The information you send will be used to help pass the bill. |
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