Protect New Mexico's Water Resources
Water Quality Control Commission
HELP US PROTECT THE RIVERS, STREAMS AND LAKES THAT YOU CARE ABOUT
The federal Clean Water Act and the New Mexico Water Quality Act require the State to
review its surface water quality regulations at least every three years in a public hearing
process called the Triennial Review. The hearing offers the public an opportunity to
advocate for stronger water quality protections and oppose proposed amendments that
will weaken existing surface water regulations.
The New Mexico Water Quality Control Commission began the Triennial Review public hearing on
Tuesday, July 13, 2021. The virtual hearing, viewable online via WebEx, is gathering
evidence in support of and in opposition to proposed amendments to existing surface
water quality regulations. The public can submit written comments now through the end of the
multi-day hearing, which is expected to last 4 -10 days.
SUBMIT YOUR PUBLIC COMMENT
PLEASE TELL THE WATER QUALITY CONTROL COMMISSION TO PROTECT NEW MEXICO'S WATER RESOURCES
1) Oppose a Limited Definition of Climate Change: The New Mexico Environment Department (NMED) is proposing a new definition of “climate change” that doesn’t identity climate change as predominantly human caused.
Talking Points: Urge the Commission to adopt a definition of climate change that identifies human activities as the major cause of climate change and to specify combatting climate change as a purpose of the regulations.
2) Support Standards for Contaminants of Emerging Concern: NMED is proposing a new
definition of “Contaminants of Emerging Concern” (CEC), while Los Alamos National Laboratory (LANL) and the New Mexico Mining Association (NMMA) are opposing adding aCEC definition and CEC monitoring requirements to the standards.
Talking Points: Support adoption of a CEC definition that clearly gives NMED the authority to required monitoring CECs. Support adding PFAS to the CEC definition as an example of CECs. PFAS are perfluoroalkyl and polyfluoroalkyl substances that are a group of man-made chemicals that research has shown to affect reproductive health, increase the risk of some cancers, affect childhood development, increase cholesterol levels, weaken the immune system, and interfere with the body’s hormones. PFAS have been measured in the Gila River.
3) Say “No!” to Toxic Fish: LANL is proposing to substantially limit the number of waters, including waters on LANL’s property, that currently receive protections under the Human Health – Organism Only (HH-OO) criteria for toxic pollutants. These criteria protect human health by ensuring that pollutants dangerous to human health do not build up in fish and other aquatic life that humans ingest.
Talking Point: Oppose LANL’s proposal to weaken HH-00 criteria because the fish we catch in our rivers, streams, reservoirs, and lakes must be kept safe to eat.
4) Support the Existing Definition of Toxic Pollutants: LANL and the NMMA propose to limit the definition of “toxic pollutant” to only toxic pollutants listed in an outdated EPA list.
Talking Point: New Mexico should not cede is authority to identify and regulate toxic
pollutants based on an outdated federal list of toxic pollutants.
5) Oppose Limited Monitoring for LANL: LANL proposes to limit monitoring to an outdated EPA list of monitoring methods for purposes of permit compliance and enforcement.
Talking Points: This proposal would prevent effective monitoring of PCBs and PFAS. Express your objection that the U.S. Department of Energy and LANL are spending taxpayer dollars to fight state efforts to protect waters from persistent and harmful pollutants.
Fact Sheets
Sponsored by
To:
Water Quality Control Commission
From:
[Your Name]
Thank you for the opportunity to submit public comment as part of the Triennial Review Docket No. WQCC 20-51(R).
I support the proposals by Communities for Clean Water (CCW) and the Gila Resources Information Project (GRIP) to provide more protections of New Mexico’s waters.
Specifically, I urge the New Mexico Water Quality Control Commission (WQCC) to:
• adopt an adequate definition of climate change that identifies human activities as the major cause of climate change. See the CCW and GRIP proposed changes to definitions.
• state in the regulations that a purpose of the regulations is to address climate change.
• support the adoption of the CCW and GRIP proposed definition of "Emerging
Contaminants."
• support adoption of language that clearly gives the NM Environment Department authority to require monitoring for Emerging Contaminants.
• support adding PFAS (perfluoroalkyl and polyfluoroalkyl substances) to the definition of Emerging Contaminants.
• not limit the definition of Toxic Pollutants to the EPA list of toxic pollutants. New
Mexico should not cede its authority to identify and regulate toxic pollutants.
• oppose the efforts of Los Alamos National Laboratory (LANL) to weaken the human
health-organism only (HH-OO) criteria. In order to protect public health and New
Mexico communities, ensure the fish we catch in rivers, streams, reservoirs, and lakes are kept safe to eat.
• not eliminate requirements to monitor for PFAS, a group of harmful ‘forever’ chemicals that have been detected at LANL, the Gila River and other surface waters throughout the state.
• not eliminate the requirement that LANL monitor for PCBs with sufficient accuracy to determine whether state standards are violated.
Thank you for your careful consideration of my comments.