Public Comments from the MRG Water Advocates were emailed to ISC in advance of their Water Planning study session held February 18, 2021. The ISC does not allow oral public comment during their public meetings.

hese are urgent matters. Without action, they will become dire.  Both require State leadership and funding.   Both are being neglected even though the issues present grave and unacceptable risks — economically, environmentally, socially, to water equity, and to the State’s treasury.

February 17, 2021

Mr. Chairman, Commissioners:

We, the Middle Rio Grande Water Advocates, are delighted that the ISC is seriously addressing the Governor’s request to develop a Fifty-Year Water Plan for the state.  These public comments are our top-level thoughts pertaining to this long-term water planning effort and to the short-term Middle Rio Grande crisis.

Planning for the Long Term – The Fifty-Year Water Plan should:

  • Meet the urgent need for New Mexico to plan for water scarcity and our changing climate.
  • Seriously consider our moral obligation to ensure adequate water for future generations.
  • Provide specific implementable actions to address adaptation to water scarcity.
  • Serve as a foundation for ongoing water planning efforts as knowledge and climate evolve.  
  • Require scientific integrity of the hydrologic data underlying water planning.
  • Recognize that planning for specific water problems must be within hydrologic regions.
  • Recognize the foundation of any meaningful water planning within a hydrologic region of the state is adequate information and data availability.
  • Delineate the specific hydrologic regions of the state to be the domains of continuing water planning.
  • Prioritize subsequent works based on the fifty-year water plan’s expert evaluation of the resilience and sustainability of current regional water uses.
  • Include provisions to establish and support diverse regional water planning stakeholders to engage in water planning within each distinct hydrologic region of the state.
  • Create regional water planning entities. Define their initial and ongoing roles in adapting to water supply limits and expected changes.     
  • Include an action plan to implement the fifty-year water plan as prominent plan component.

The ISC should formally approve the fifty-year water plan upon public review and response to comments, a detailed review by Commissioners, and the Commission’s public deliberations.  Approval should connote a commitment to implement the action plan.

Planning for the Near Term – In addition to planning long term for water scarcity through evolving climate change, we would like to remind the Commission of an urgent water problem that the Commission must plan to solve.  That problem is the cost of likely failure in state’s obligation to meet the Rio Grande Compact deliveries at Elephant Butte, regardless of weather conditions.  As indicated in the two graphics, New Mexico has been regularly under-delivering for ten years.  The ISC should plan now for how it will reverse the trend in order to avoid a violation.  At the current rate, that violation is likely within a few years, surely within the next decade.

Backup Data – The “Actual Water Delivery” chart below illustrates annual compact deliveries variances from the delivery schedule of the Rio Grande Compact that we would like to bring to your attention.  It was prepared from a spreadsheet graciously provided by ISC staff.  Over the last decade, the Middle Rio Grande net underdelivery was 158,500 acre-feet, an average of about 16,000 acre-feet per year.  This compact compliance performance metric was unaffected by relinquishment of credits, as none occurred during the last decade.

The ISC staff “Compact Status” chart of long-term cumulative departures is significantly affected by relinquishment of New Mexico’s accrued delivery credits.  The graph illustrates the net of actual annual deliveries compared to the compact delivery requirements and relinquishment of NM credits.

Finally, it’s worth emphasizing that last year continued the increase since the 1970s of annual average state temperature.  2020 scored a record high tied with 2016 and with the fourth lowest annual average state precipitation.  Given the scientific relationship between increasing temperature and exponentially increased water evapotranspiration, last year was undoubtably the driest ever.

The temperature trend, the six red bars, and the downward trend in the “Compact Status” graphic should be cause for alarm and action.

Thank you for considering our public comments.  We would be pleased to meet with you individually or as a group or with ISC staff to discuss our points and concerns.

Respectfully submitted,

MRG WATER ADVOCATES EXECUTIVE COMMITTEE

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