Spring 2002 Bulletin

Dear friend of wild rivers, We need your support to realize a highly unusual opportunity – the chance for the public to nominate a New Mexico river for the highest degree of pollution protection afforded by the Clean Water Act. Normally we, the public, are confined to a reactive role when it comes to protecting rivers, limited to protesting about pollution or providing ‘input’ on government regulations. There is one exception under the Clean Water Act – the nomination of Outstanding National Resource Waters (ONRWs). The Act provides that “where high quality waters constitute an outstanding national resource, such as… waters of exceptional recreational or ecological significance, that water quality shall be maintained and protected.” Under the New Mexico water quality Standards, which implement the Clean Water Act, “Any person may nominate a surface water of the state for designation as an ONRW by filing a petition with the Water Quality Control Commission.” As an earlier Bulletin article explained, Amigos Bravos, hopefully backed by a variety of non-government supporters, intends to nominate the upper Río Santa Barbara. The fact that this will be New Mexico’s first nomination, though the Clean Water Act has been in existence for thirty years – plus the small number of citizen-nominated ONRWs elsewhere in the country – gives some indication of the challenge we face. Because ONRW designation allows no water quality degradation (in contrast to the rest of the Clean Water Act, which allows degradation down to a level of water quality just capable of supporting ‘designated uses’), the idea raises fears that economic interests could be harmed. (In fact, ONRWs don’t prevent any economic activities, only increases in pollution they might cause.) The second reason citizen-nominated ONRWs have been rare is that the nominating requirements imposed by the states are often onerous. In New Mexico, the petitioners must provide scientific and other strong evidence that the candidate water is ‘outstanding’, in ecological or recreational terms; must describe possible pollution threats; and must give additional evidence “including an analysis of the economic impact of the designation on the local and regional economy.” The implication seems to be, if the designation could have any negative economic impact, the Commission won’t approve it. On the Santa Barbara, fortunately, it looks like ONRW designation will have a favorable ecological and economic impact. The Wilderness Santa Barbara, we believe, is one of the most pristine watersheds in the state, providing excellent habitat – fallen streamside trees damming deep pools, clean gravels for spawning, the clear water needed by sensitive invertebrates such as stonefly nymphs – for the rare Rio Grande Cutthroat trout, which is even now being reviewed for listing as an Endangered Species. It is a place where the ecology of the whole watershed is quite clearly interlinked, with small wet meadows filtering out any sediment in feeder streams, willow roots protecting banks against flood flows, tree leaves providing food for aquatic insects in the cold, otherwise unproductive mountain waters. The upper Santa Barbara is quite simply a jewel amongst New Mexico rivers. It is also part of the Valle Grande ‘grassbank’, an innovative grazing management scheme which takes cows off home allotments (such as the Santa Barbara National Forest area) for several years, thereby allowing forest rehabilitation programs, such as thinning and prescribed fire, to take place with the intended effect of improving grass cover and thereby reducing soil erosion by the time the cows return. The Santa Barbara Allotment cows may return from the grassbank this year, and the Wilderness area contains two pastures in the Allotment’s rotation. The proposal under the Grassbank plan is that the returning cows should now be run by a herder – a progressive grazing technique which has shown much promise for protecting range and, in particular, riparian areas in the West Elks Wilderness of Colorado. Where would an ONRW designation fit in? Fundamental to the grassbank concept is rigorous scientific monitoring of the effects of experimental land management techniques, such as the thinning and burning mentioned above. Herding is equally an experimental technique which needs careful monitoring, particularly in the riparian zone and streamside meadows which are often a magnet for cattle. ONRW designation means that existing water quality must be preserved – but there is little chance of determining how far incremental non-point sources of pollution such as sediment are actually increasing, against a typical ‘snapshot’ water quality baseline which cannot account for natural variability. Amigos Bravos therefore proposes that there should be an ecological baseline survey of riparian and instream conditions – such as the quality of streamside canopy and bankholding roots – against which changes resulting from human activity such as grazing cattle and recreation should be measured, or monitored. Monitoring that showed no ecological impact from the experimental technique would represent success; monitored damage would require an appropriate shift in management. Progressive management closely assessed and held accountable through monitoring in this way will, we believe, protect the Santa Barbara’s ecology and therefore its water quality, while existing human uses – including economic ones – continue. The application of this idea on the Santa Barbara should encourage the extension of ‘ONRW Best Management Practices’ for controlling non-point pollution threats to more of New Mexico’s most outstanding waters, an innovative concept which would make the designation particularly valuable. Where, then, do our supporters come in? We need to show that our candidate, as any ONRW candidate should be, is truly an outstanding resource which is an appropriate, democratically-decided priority for focused government management and the expenditure of some scarce resources (though we think the requirements will be modest). What we need from you are testimonials as to the recreational and/or ecological quality of the Wilderness Santa Barbara. If you know and love the Santa Barbara, please put pen to paper and tell us why you feel the way you do – in anything from an anecdote to an essay. We will include your name and hopefully your words in the petition to the Water Quality Control Commission. Your voice will make a difference, perhaps the difference. Sincerely, Brian Shields

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