Amigos Bravos - Friends of the Wild Rivers

Clean Water Act policy and regulatory issues
Clean Water Act training and watershed organization capacity building
Technical assistance developing Watershed Restoration Action Strategies (WRAS) and assistance with water quality standards for local waters and other permitting processes
River Otter restoration and other native species issues

Following are some specific recent examples

Volunteer River Cleanups
Amigos Bravos coordinated with Centinel Bank Taos, The Rio Pueblo de Taos Watershed Group, The Bureau of Land Management, and Water Sentinels—Ríos de Taos to conduct three stream cleanups between June 2 — June 14th.

Two of the three cleanups were trash cleanups, one on the Río Pueblo de Taos and one on the Río Fernando and then the final cleanup on the Río Grande near the Taos Junction Bridge focused on helping BLM with salt cedar (or Tamarisk) removal and control. Salt Cedar is an invasive plant species that invades and degrades riparian river corridors; drinks a lot of water; and turns the surrounding soil salty. Sections of the Rií Pueblo de Taos, Río Fernando de Taos and the Río Grande in the Taos area are all listed as impaired (polluted) by the New Mexico Environment Department.

Click here to view a video of the Río Fernando de Taos Cleanup.

2007 Taos Water Quality Sampling Report
A joint water quality sampling project of Sierra Club's Water Sentinels, Rivers and Birds and Amigos Bravos found high levels of E. Coli in the Río Hondo and the Río Pueblo de Taos. During May 2007, very high E. coli results were obtained from two sites in the lower Río Hondo and two sites in the lower Río Pueblo de Taos. These results exceeded water quality standards that are safe for swimming. All other samples taken in the Río Hondo, Río Fernando de Taos and Río Pueblo met water quality standards for all tested constituents. For more details on this sampling project, please see attached report 07Sentinels Rios Report (204 KB pdf). Sampling in these three river systems is ongoing.

Río Pueblo de Taos Watershed Group
In October 2005, following eleven months of meetings and research, the Río Pueblo de Taos Watershed Group prepared the Río Pueblo de Taos Watershed Restoration Action Strategy (WRAS) (12.8 MB pdf) under a State of New Mexico 319 grant administered by Amigos Bravos. The CWCR serves as Watershed Coordinator.

Outstanding National Resource Water (ONRW)
As part of the State's Triennial Review of Water Quality Standards process, Amigos Bravos nominated the Río Santa Barbara as an Outstanding National Resource Water (ONRW) (27.0 MB pdf), a category of water that receives the highest protection under the Clean Water Act. The state designated the Río Santa Barbara as the state’s first ONRW river in 2004. In 2005, the Governor’s office petitioned to have all rivers within the Valle Vidal designated as ONRWs.

Village of Taos Ski Valley Wastewater Treatment Plant
The Village of Taos Ski Valley proposed doubling the peak daily flow capacity of its wastewater treatment plant from the existing peak of 100,000 gallons per day to 200,000 gallons per day. There were a number of community concerns expressed at a community meeting on December 20th, 2004. These included concerns about what impact this increased discharge will have on downstream users in the communities of Valdez, Des Montes, and Arroyo Hondo; what impact the associated development facilitated by this upgrade will have on surrounding communities and the environment; and what impact the upgrade will have on water quality in the Rio Hondo. The Rio Hondo is presently impaired for temperature and nutrients (Total Maximum Daily Loads – TMDLs – can be downloaded from the New Mexico Environment Department's webpage at http://www.nmenv.state.nm.us/swqb/Projects/TMDL/index2.html). The environment department issued an Environmental Assessment (EA) and a preliminary Finding of No Significant Impact (FONSI) (288 KB pdf) for this upgrade. There were a number of concerns that this EA and FONSI did not address all the potential impacts of the upgrade.

The issue is complicated because the upgrade will enable the Village of Taos Ski Valley to expand service to existing residences that are currently on septic tanks. This would help to improve water quality and stop contamination from these septic tanks leaching into ground and surface water. Septic tanks are considered a non-point source pollution, the biggest threat to water quality in the state.

In March 2006, the final discharge permit for the Village of Taos Ski Valley’s wastewater treatment plant now has much stricter limits on pollution entering the Río Hondo (see the Press Release). Many community members, including Amigos Bravos, submitted detailed comments on the draft permit and testified at an October 6th, 2005 public hearing. In the final permit released by the EPA, phosphorus limits have been reduced by half and, in some sections of the permit, total nitrogen limits have been reduced by 75% from the limits proposed in the draft permit. The new permit goes into effect on April 1, 2006.

Antidegradation Implementation Policy
Antidegradation is the least well know of the three components of water quality standards. The first two components of water quality standards, designated uses and water quality criteria, provide minimum goals for a water body. However, antidegration provides a process for keeping waters clean once they have met the minimum goals. Antidegradation also provides a process for protecting waters that were always clean.

Federal Clean Water Act regulations outline a three-tiered approach for implementing an antidegradation policy. These three tiers make sure that:

no activities are permitted that would result in the exceedance of water quality standards;
lowering of water quality of water bodies that currently meet or exceed standards is avoided or at least held to a minimum and;
waters that are of outstanding or exceptional value are strictly protected.

To make sure that these three tiers are being adequately implemented each state is required to draft an antidegradation implementation policy.

In November 2003, the Surface Water Quality Bureau of the New Mexico Environment Department (NMED) released a draft antidegradation implementation as an amendment to the state’s Continuing Planning Process Document. Comments on this policy were due January 12th 2004. A final proposal was submitted to the Water Quality Control Commission for review and approval at a regular public meeting later in 2004. The final policy was approved in January 2005.

The draft policy, Amigos Bravos' comments, and other parties' comments can be viewed on the New Mexico Environment Department's website: http://www.nmenv.state.nm.us/swqb/index.html

Stormwater Permits
In August of 2003, the EPA released a draft general National Pollutant Discharge Elimination System (NPDES) permit (http://www.epa.gov/earth1r6/6wq/npdes/sw/ms4/) for small municipal separate storm sewer systems (MS4s). Amigos Bravos submitted comments on the draft permit (128 KB pdf) as well as comments on which municipalitites should obtain coverage under the permit (84 KB pdf). A general permit is a permit that is developed for a specific category of activity. A business that falls under this category can then apply to be covered under this general permit rather than applying for an individual permit. Urban storm sewers often channel polluted water that is generated in a storm event from runoff from streets, rooftops, parking lots and other urban surfaces to rivers, stream and lakes. Stormwater pollution is a major source of pollution to our nation’s waters.