Construction and Staging Areas

Stated in the draft EA Table 1.1:

“Watershed conditions, stream and riparian health, and surface water and groundwater quality, quantity, and distribution have the potential to be impacted by the proposed action. Specifically, this includes potential impacts to the Rio Hondo and downstream areas. Ground disturbance, including tree clearing and grading associated with construction and operation of the proposed projects, have the potential to increase erosion and soil compaction within the study area.”

The EA acknowledges that the proposed construction activities will likely increase impacts to the Rio Hondo and downstream areas.

There is scant location or physical detail on the trails, roads, access, pads, or staging areas proposed in the EA. Without infrastructure clearly identified, it is difficult to understand what the analysis accounts for and how it evaluated impacts. Further details need be provided and analyzed.

The EA suggests that ‘Staging would occur primarily in the existing parking lots at the Frontside and Kachina Basin base areas.’ Will this staging impact other recreational users in the area? It appears that there is no plan to accommodate other recreational users; a plan should be developed with input from the public.

Today if you walk along the Rio Hondo at the base of TSV you will notice plenty of debris from both traffic and construction in the stream below. The EA has no analysis of locally added pollution from construction or increased visitation adjacent to the streams.

The ground-disturbing activities during construction, staging areas, as well as new and existing trail and road maintenance could negatively impact water quality and require compliance with applicable designations and laws. The Rio Hondo was recently designated by the New Mexico Water Quality Control Commission as a Outstanding Natural Resource Water (ONRW) - NMAC 20.6.4.8(A)(3) and (4). However, without detailing more specifically the potential impacts to the aquatic ecosystem in the EA, there is insufficient analysis for the protection of ONRW water quality as well as compliance with Clean Water Act (Section 404). The USFS is required to work jointly with the Surface Water Quality Bureau to develop shared protocols for implementing ONRW protections, including strategies to prevent future degradation in ONRWs such as increased water quality monitoring frequency to at least once annually (Per the USFS-NMED interagency Memorandum of Agreement). The EA does not provide enough detail on the potential impacts to ONRW, Clean Water 404, aquatic ecosystems, and what strategies and monitoring will be in place to protect water quality and ecosystems.