SUMMARY TABLE

TABLE OF CONTENTS

APPENDICES

          Appendix A:     Relationship between Total Suspended Sediment and Turbidity
            Appendix B:     SWQB/NMED draft Protocol for the Assessment of Stream Bottom Deposits Relationships
          Appendix C:     Relationship between Turbidity and Total Phosphorus
          Appendix D:     Conversion Factor Derivation
          Appendix E:     POLLUTANT SOURCE(S) DOCUMENTATION PROTOCOL
          Appendix F:     Public Participation Process Flowchart
          Appendix G:     Response to Comments

EXECUTIVE SUMMARY

The Cimarron River Basin is a sub-basin of the Canadian River Basin, located in northeastern New Mexico. Stations were located throughout the basin to evaluate the impact of tributary streams and to establish background conditions. As a result of this monitoring effort, several exceedances of New Mexico water quality standards for turbidity were documented on Cieneguilla Creek from the inflow to Eagle Nest Lake to the headwaters (13.6 mi.), Six-Mile Creek from the inflow to Eagle Nest Lake to the headwaters (6.6 mi.), Moreno Creek from the inflow to Eagle Nest Lake to the headwaters (14.4 mi.), and North Ponil Creek from the confluence with South Ponil Creek to the mouth of M^cCrystal Creek (17.6 mi.). An exceedance of New Mexico water quality standards for total phosphorus was documented on North Ponil Creek from the confluence with South Ponil Creek to the mouth of M^cCrystal Creek (17.6 mi.). Some level of impairment due to embeddedness was seen on both reaches listed for stream bottom deposits, Cieneguilla Creek from the inflow to Eagle Nest Lake to the headwaters (13.6 mi.) and North Ponil Creek from the confluence with South Ponil Creek to the mouth of M^cCrystal Creek (17.6 mi.). This Total Maximum Daily Load (TMDL) document addresses these three constituents.

A general implementation plan for activities to be established in the watershed is included in this document.  The Surface Water Quality Bureau's Nonpoint Source Pollution Section will further develop the details of this plan.  Implementation of recommendations in this document will be done with full participation of all interested and affected parties.  During implementation, additional water quality data will be generated. As a result, targets will be re-examined and potentially revised; this document is considered to be an evolving management plan.  In the event that new data indicate that the targets used in this analysis are not appropriate or if new standards are adopted, the load capacity will be adjusted accordingly.  When water quality standards have been achieved, the reach will be removed from the TMDL list.

LIST OF ABBREVIATIONS

BACKGROUND INFORMATION

Surface water quality monitoring stations were used to characterize the water quality of the stream reaches (see Figure 2).  Stations were located to evaluate the impact of tributary streams and to establish background conditions.  As a result of this monitoring effort, several exceedances of New Mexico water quality standards for turbidity were documented on these streams flowing into Eagle Nest Lake.  On the North Ponil reach, exceedances of New Mexico water quality standards for turbidity and total phosphorus were documented.  Stream bottom deposits were assessed using techniques in the draft New Mexico Sediment Protocol (NMED 1999b).  Some level of impairment due to embeddedness was seen on both reaches listed for stream bottom deposits, Cieneguilla Creek and North Ponil Creek.

ENDPOINT IDENTIFICATION

TARGET LOADING CAPACITY
Target values for turbidity, stream bottom deposits and total phosphorus will be determined based on 1) the presence of numeric criteria, 2) the degree of experience in applying the indicator and 3) the ability to easily monitor and produce quantifiable and reproducible results.

Turbidity
The State’s standard leading to an assessment of use impairment is the numeric criteria for turbidity of 25 NTU for a High Quality Coldwater Fishery (HQCWF). Turbidity levels are inferred from studies which monitor total suspended sediment (TSS) concentrations. Extrapolation from these studies is possible because of the relationship between concentrations of suspended sediments and turbidity. Activities that generate varying amounts of suspended sediment will proportionally change or affect turbidity (USEPA 1991). In this watershed both total suspended sediment (TSS) and turbidity were measured. A strong correlation (R²=0.84) was found between TSS and turbidity (Appendix A).

Stream Bottom Deposits
Surface Water Quality Bureau (SWQB) has combined techniques to measure the level of embeddedness of a stream bottom in a SWQB/NMED draft Protocol for the Assessment of Stream Bottom Deposits (SWQB/NMED 1999a) in order to address the narrative criteria for stream bottom deposits (SBD). The purpose of the Protocol is to provide a reproducible quantification of the narrative criteria for stream bottom deposits (SBD).

Figure 1:  Ecological Regions Coverage Map

Figure 2:  The Cimarron Watershed, Land Use Coverages and TMDL Reaches

The impact of fine sediment deposits is well documented in the literature. USEPA (1991) states that "An increased sediment load is often the most important adverse effect of ....activities on streams." This impact is mediated through the reduction in available habitat for macroinvertebrates and fish species which utilize the streambed in various life stages. An increase in suspended sediment concentration will reduce the penetration of light, decreases the ability of fish on fingerlings to capture prey, and reduce primary production (US EPA 1991). The SWQB Sediment Workgroup evaluated a number of methods described in the literature that would provide information allowing a direct assessment of the impacts to the stream bottom substrate. A final list of monitoring procedures was implemented at a wide variety of sites during the 1998 monitoring season. These procedures included conducting pebble counts (a measurement of % fines), stream bottom cobble embeddedness, Rosgen (1996) geomorphology, and various biological measures.

The SWQB examined two ways to base the target levels for stream bottom deposits. The first is the nominal stream morphology for the specific stream type (Rosgen 1996). Using this Rosgen approach, data collection at each impaired site included an evaluation of the stream geomorphology. Cieneguilla Creek was determined to be an E5 stream type and North Ponil Creek an E4 stream type. Figures from Rosgen (1996) show the derivation of percent fines give target values for an E4 stream type of 27.7% and for an E5 stream type of 60.4%. The disadvantage of Rosgen’s approach is that it is not based on streams in New Mexico and is based on the existing condition of a stream, not a desired or "natural" stream type.

The second methodology chosen to estimate target levels involved the examination of developed relationships between embeddedness, fines, and biological score. Evaluation of data collected at various locations in New Mexico showed a relationship (R²=0.7511) between embeddedness and the biological score results from the SWQB/NMED draft Protocol for the Assessment of Stream Bottom Deposits (SWQB/NMED 1999a) sampling from 1998 (Appendix B). A correlation (R²= 0.7199) was also found between embeddedness and percent fines (Appendix B). These relationships show that at the desired biological score (at least 70, per the SWQB Assessment Protocol, 1998) the target maximum embeddedness (for fully supporting a designated use) would be 45%, and the target fines would be 20%. Since this relationship is based on New Mexico streams it was chosen for the target value for percent fines.

Results from biological sampling at each sampling site are used to support the SWQB/NMED draft Protocol for the Assessment of Stream Bottom Deposits (SWQB/NMED 1999a) results. In this case, Cieneguilla Creek at the USGS gage scored a loss in EPT (Ephemeroptera, Plecoptera, Tricoptera) taxa compared to its reference site, and was rated as partially supporting its designated use for biological quality. Decreases in the EPT taxa are most likely due to increased sedimentation from upstream inputs to this site. The macroinvertebrate community at the North Ponil Creek site was similar to its reference site, and was rated as being fully supporting for biological quality.

Total Phosphorus
The standard leading to an assessment of use impairment is the numeric criterion for total phosphorus (TP) of 0.1 mg/L for a HQCWF. Due to sorbtion characteristics phosphorus loads may be closely linked to sediment loads. This is the case in this watershed; a strong correlation (R²=.89) was seen between turbidity and total phosphorus (Appendix C). Given attainment of the standard for turbidity (25 NTU) the total phosphorus level would calculate to approximately 0.05 mg/L. This is one half the current standard for total phosphorus. This standard is under review in New Mexico’s Triennial review process, and may be changed to 0.1 mg/L, which would be used only as an indicator of possible nutrient enrichment. The Triennial review process is expected to conclude during fall of 1999.

Flow
Sediment movement in a stream varies as a function of flow. As flow increases the concentration of sediment increases. This TMDL is calculated for each reach at a specific flow. When available, US Geologic Survey gages are used to estimate flow. Where gages are absent, geomorphological cross sectional information is taken at each site and the flows are modeled. It is important to remember that the TMDL is a planning tool to be used to achieve water quality standards. Since flows vary throughout the year in these systems the target load will vary based on the changing flow. Management of the load should set a goal at water quality standards attainment; not meeting the calculated target load.

Calculations
Target loads for turbidity (expressed as TSS) and total phosphorus are calculated based on a flow, the current water quality standards, and a unit less conversion factor, 8.34 that is a used to convert mg/L units to lbs/day (see Appendix D for Conversion Factor Derivation). The target loading capacity is calculated using Equation 1.

Equation 1. critical flow (mgd) x standard (mg/L) x 8.34 (conversion factor) = target loading capacity

Table 1: Calculation of Target Loads

Location	Flow (mgd)	Standards			Conversion Factor	Target Load Capacity
		TSS* (mg/L)	Stream Bottom Deposits (% fines)	Total Phosphorus (mg/L)
Moreno	16.3+	31			8.34	4,214 (lbs/day)
Six-Mile	5.9‡	31			8.34	1,525 (lbs/day)
Cieneguilla	24.5+	31	None		8.34	6,334 (lbs/day) 20% fines**
North Ponil	6.49^	31	None	0.1	8.34 8.34	1,678 (lbs/day) 20% fines** 5.4 (lbs/day)

+	Flow is the greatest monthly mean flow at each location from 1928-1993 (USGS 1994).
‡	Flow is the greatest monthly mean flow at each location from 1958-1993 (USGS 1994).
^	Since a USGS gage was unavailable on this reach, flow is modeled using cross sectional data that is used to estimate stream discharge using USGS Technical paper 2193 (USGS 1982) and the channel cross-section analyzer WinXSPRO® (USDA-FS 1998).
*	This value is calculated using the relationship established between TSS and turbidity (y=.7973x) R2=0.841 (Appendix A). The turbidity standard is 25 NTU.
**	The background values for stream bottom deposits were taken from the NMED Draft Sediment Protocol for the Assessment of Stream Bottom Deposits (1999b).

The measured loads were calculated using Equation 1. The flows used were either taken directly from a USGS gage or from field measurements. The geometric mean of the data that exceeded the standards from the data collected at each site was substituted for the standard in Equation 1. The same conversion factor of 8.34 was used. Results are presented in Table 2.

Background loads were not possible to calculate in this watershed. A reference reach, having similar stream channel morphology and flow, was not found. It is assumed that a portion of the load allocation is made up of natural background loads. In future water quality surveys, finding a suitable reference reach will be a priority.

Table 2: Calculation of Measured Loads

Location	Flow (mgd)	Geometric Mean		Conversion Factor	Measured Load (lbs/day)
		TSS*(mg/L)	TP(mg/L)
Moreno	12.7†	133		8.34	14,087
Six-Mile	6.2†	81.2		8.34	4,199
Cieneguilla	26.4†	32		8.34	7,057
North Ponil	6.71^	209.3	0.17	8.34 8.34	11,713 9.5

†	Flow is the geometric mean of USGS daily gaged flows taken on days samples were collected.
^	Since a USGS gage was unavailable on this reach, flow is modeled using cross sectional data that is used to estimate stream discharge using USGS Technical paper 2193 (USGS 1982) and the channel cross-section analyzer WinXSPRO® (USDA-FS 1998).
*	TSS measured during critical condition (spring sampling) were used to calculate these values.

WASTE LOAD ALLOCATIONS AND LOAD ALLOCATIONS

•    Waste Load Allocation

There are no point source contributions associated with this TMDL. The waste load allocation is zero.

•    Load Allocation

In order to calculate the Load Allocation (LA) the waste load allocation, background, and margin of safety (MOS) were subtracted from the target capacity (TMDL) following Equation 2.

Equation 2.        WLA + LA + MOS = TMDL

Results are presented in Table 3a (Calculation of TMDLs for Turbidity), Table 3b (Calculation of TMDLs for Stream Bottom Deposits), and Table 3c (Calculation of TMDLs for Total Phosphorus).

Table 3a: Calculation of TMDL for Turbidity

Location	WLA (lbs/day)	LA (lbs/day)	MOS (25%) (lbs/day)	TMDL (lbs/day)
Moreno	0	3,160	1,054	4,214
Six-Mile	0	1,144	381	1,525
Cieneguilla	0	4,750	1,584	6,334
North Ponil	0	1,258	420	1,678

Table 3b: Calculation of TMDL for Stream Bottom Deposits

Location	WLA (% fines)	LA (% fines)	MOS (25%) (% fines)	TMDL (% fines)
Cieneguilla	0	15	5	20
North Ponil	0	15	5	20

Table 3c: Calculation of TMDL for Total Phosphorus

Location	WLA (lbs/day)	LA (lbs/day)	MOS (25%) (lbs/day)	TMDL (lbs/day)
North Ponil	0	4	1.4	5.4

The load reductions that would be necessary to meet the target loads were calculated to be the difference between the target load (Table 1) and the measured load (Table 2), and are shown in Table 4 (Calculation of Load Reductions).

Table 4: Calculation of Load Reductions

Location	Target Load			Measured Load			Load Reduction
	TSS (lbs/day)	SBD (%fines)	TP (lbs/day)	TSS (lbs/day)	SBD (%fines)	TP (lbs/day)	TSS (lbs/day)	SBD (%fines)	TP (lbs/day)
Moreno	4,214			11,397			7,183
Six-Mile	1,525			2,885			1,360
Cieneguilla	6,334	20		7,057	65		723	45
North Ponil	1,678	20	5.4	10,291	63	9.5	8,613	43	4.1

IDENTIFICATION AND DESCRIPTION OF POLLUTANT SOURCES

Table 5: Pollutant Source Summary

LINKAGE OF WATER QUALITY AND POLLUTANT SOURCES
Where available data are incomplete or where the level of uncertainty in the characterization of sources is large, the recommended approach to TMDLs requires the development of allocations based on estimates utilizing the best available information.

SWQB fieldwork includes an assessment of the potential sources of impairment (SWQB/NMED 1999b). The Pollutant Source(s) Documentation Protocol, shown as Appendix D, provides an approach for a visual analysis of a pollutant source along an impaired reach. Although this procedure is subjective, SWQB feels that it provides the best available information for the identification of potential sources of impairment in this watershed. Table 5 (Pollutant Source Summary) identifies and quantifies potential sources of nonpoint source impairments along each reach as determined by field reconnaissance and assessment. A further explanation of the sources follows.

Cieneguilla Creek
The main source of impairment on this reach appears to be the improper installation and maintenance of culverts. This has led to serious streambank destabilization and has altered the geomorphology of the stream near roads. SWQB will continue to monitor bank pins that were installed in the fall of 1998 in order to evaluate the amount of bank erosion occurring along Cieneguilla Creek that may be attributable to these culverts. Recreation in this area is associated with the development of resort areas in the watershed. These activities may result in erosion from ski slopes, parking areas, road construction and maintenance, and land development. Allocation of loads across these varied sources is problematic.

Six-Mile Creek
The main source of impairment along this reach is streambank destabilization. According to results from the Pollutant Source Summary it is estimated that this impairment is most likely due to removal of over 95% of the riparian vegetation (except for short grass) and the extensive grazing of rangeland along this reach. The land surrounding this creek is privately owned.

Moreno Creek
This creek is predominantly impaired due to streambank destabilization as well as an unknown source. There is a gravel operation located about a half mile upstream of the sampling station that may have some inputs into the creek. This land is privately owned; access for sampling is restricted. SWQB is investigating whether this gravel operation is subject to any permitting, such as CWA §§401, 404, or NPDES.

North Ponil Creek
In 1996 the US Forest Service removed a fishing pond that had been established some years earlier. It appears that the stream was not restored to its natural geomorphology, therefore causing serious streambank destabilization.

MARGIN OF SAFETY (MOS)
TMDLs should reflect a margin of safety based on the uncertainty or variability in the data, the point and nonpoint source load estimates, and the modeling analysis. For this TMDL, there will be no margin of safety for point sources, since there are none. However, for the nonpoint sources the margin of safety is estimated to be an addition of 25% of the TMDL, excluding the background. This margin of safety incorporates several factors:

•    Errors in calculating NPS loads

MONITORING PLAN

The SWQB utilizes a rotating basin system approach to water quality monitoring.  In this system, a select number of watersheds are intensively monitored each year with an established return frequency of every five years.

The SWQB maintains current quality assurance and quality control plans to cover all monitoring activities.  This document "Quality Assurance Project Plan for Water Quality Management Programs" (QAPP) is updated annually.

Current priorities for monitoring in the SWQB are driven by the 303(d) list of streams requiring TMDLs.  Short-term efforts are directed toward those waters which are on the EPA TMDL consent decree (Forest Guardians and Southwest Environmental Center v. Carol Browner, Administrator, US EPA, Civil Action 96-0826 LH/LFG, 1997) list and which are due within the first two years of the monitoring schedule.  Once assessment monitoring is completed those reaches still showing impacts and therefore requiring a TMDL will be targeted for more intensive monitoring. The methods of data acquisition include fixed-station monitoring, intensive surveys of priority water bodies, including biological assessments, and compliance monitoring of industrial, federal and municipal dischargers, and are specified in the Assessment Protocol (SWQB/NMED 1998).

Pebble counts are used to develop a particle size distribution curve of the bed surface material.  The method described by Wolman (1954) was selected for inclusion in the parameter suite evaluated during the sample season.  The advantage of this procedure is that it is relatively quick to perform and is reproducible.  In streams dominated by fine sediments, coarser particles that provide beneficial habitat tend to become surrounded or buried in fines leading to a loss of suitable habitat.  Cobble embeddedness is a measure of the extent to which these coarser particles are buried by these finer sediments and has both biological and physical significance (USEPA 1991).  The sampling procedure chosen for New Mexico streams is that devised by Skille and King (1989).  This technique uses 60-cm diameter hoops as the basic sampling unit.  The use of hoops rather than individual particles as the basic unit of measure reduces the variability of the sample.  Software obtained from the Idaho Bureau of Reclamation allows for the evaluation of the data (Burton 1990).  Values calculated and reported by the software are percent embeddedness, the Interstitial Space Index (ISI), and percent free matrix cobble.  Also available in the software is a sample size evaluator that helps in determinations of whether sufficient sample size has been collected to statistically define the population.  The advantage of this procedure is that it is quantifiable.  The major disadvantage is in the substantial effort required to complete the data collection.

Long term monitoring for assessments will be accomplished through the establishment of sampling sites that are representative of the waterbody and which can be revisited every five years. This gives an unbiased assessment of the waterbody and establishes a long term monitoring record for simple trend analyses. This information will provide time relevant information for use in §305(b) assessments and to support the need for developing TMDLs.

This approach provides:

The following schedule is for sampling seasons through 2002 and will be done in a consistent manner to support the New Mexico Unified Watershed Assessment (UWA) and the Nonpoint Source Management Program. This sampling regime allows characterization of seasonal variation through sampling in spring, summer, and fall for each of the watersheds.

IMPLEMENTATION PLAN

Stakeholder and public outreach and involvement in the implementation of this TMDL will be ongoing. Stakeholder participation will include choosing and installing BMPs, as well as potential volunteer monitoring. Stakeholders in this process will include: SWQB, US Forest Service, New Mexico State Highway Department, local government, private land owners, environmental groups, Angel Fire Ski Area, and the general public.

Other studies are ongoing throughout this watershed. A §319 project designed to establish sediment rating curves should be completed in the next few years. Bank pins were also installed in fall of 1998 to examine the bank erodibility in several locations throughout the watershed. Information derived from these studies, as well as SWQB continued monitoring efforts, will be used in the determination and implementation of BMPs in the watershed.

TIME LINE

Implementation Actions	Year 1	Year 2	Year 3	Year 4	Year 5
Public Outreach and Involvement	X	X	X	X	X
Establish Milestones	X
Secure Funding	X		X
Implement Management Measures (BMPs)		X	X
Monitor BMPs		X	X	X
Determine BMP Effectiveness				X	X
Re-evaluate Milestones				X	X

ASSURANCES

New Mexico’s Water Quality Act does not contain enforceable prohibitions directly applicable to nonpoint sources of pollution.  The Act does authorize the Water Quality Control Commission to "promulgate and publish regulations to prevent or abate water pollution in the state" and to require permits.  Several statutory provisions on nuisance law could also be applied to nonpoint source water pollution.

Nonpoint source water quality improvement work utilizes a voluntary approach.  This provides technical support and grant money for the implementation of best management practices and other NPS prevention mechanisms through §319 of the Clean Water Act.  Since this TMDL will be implemented through NPS control mechanisms the New Mexico Nonpoint Source Program is targeting efforts to this watershed.  The Nonpoint Source Program coordinates with the Nonpoint Source Taskforce.  The Nonpoint Source Taskforce is the New Mexico statewide focus group representing federal and state agencies, local governments, tribes and pueblos, soil and water conservation districts, environmental organizations, industry, and the public.  This group meets on a quarterly basis to provide input on the §319 program process, to disseminate information to other stakeholders and the public regarding nonpoint source issues, to identify complimentary programs and sources of funding, and to help review and rank §319 proposals.

In order to ensure reasonable assurances for implementation in watersheds with multiple landowners, including Federal, State and private land, NMED has established MOUs with several Federal agencies, in particular the Forest Service and the Bureau of Land Management.  MOUs have also been developed with other State agencies, such as the New Mexico Highway Department.  These MOUs provide for coordination and consistency in dealing with nonpoint source issues.

New Mexico’s Clean Water Action Plan has been developed in a coordinated manner with the State’s §303(d) process.  All Category I watersheds identified in New Mexico’s Unified Watershed Assessment process are totally coincident with the impaired waters list for 1996 and 1998 approved by EPA.  The State has given a high priority for funding assessment and restoration activities in these watersheds.

The time required to attain standards for all reaches in this watershed is estimated to be approximately 10-20 years.  This estimate is based on a five-year time frame for implemention.  Watershed projects will be started incrementally; a few projects are already established in response to earlier projects.  The cooperation of private landowners and Federal Agencies will be pivotal in the implementation of this TMDL.

MILESTONES

Milestones will be used to determine if control actions are being implemented and standards attained.  For this TMDL several milestones will be established that will vary based on the BMPs implemented at each site.  Examples of milestones include a percentage reduction in stream bottom deposits within a certain time frame, update or develop MOUs with other state and federal agencies by 2001 to ensure protection and restoration in this watershed, and to increase education and outreach activities regarding sediment erosion in this watershed, particularly for private landowners.

Milestones will be reevaluated periodically, depending on what BMP was implemented.  Further implementation of this TMDL will be revised based on this reevaluation.  The process will involve monitoring pollutant loading, tracking implementation and effectiveness of controls, assessing water quality trends in the waterbody, and reevaluating the TMDL for attainment of water quality standards.

PUBLIC PARTICIPATION

REFERENCES CITED

Burton, T. and G. Harvey. 1990. Estimating intergravel salmonid living space using the cobble embeddedness sampling procedure. Report No. 2. Idaho Department of Health and Welfare, Division of Environmental Quality, Water Quality Bureau.

Forest Guardians and Southwest Environmental Center v. Carol Browner, Administrator, US EPA, Civil Action 96-0826 LH/LFG, 1997.

Skille and King. 1989. Proposed cobble embeddedness sampling procedure. Unpublished paper available from the USDA for. Serv., Intermount. Res. Sta. Boise, ID.

SWQB/NMED. 1999a. SWQB/NMED Draft Protocol for the Assessment of Stream Bottom Deposits.

SWQB/NMED. 1999b. Draft Pollutant Source Documentation Protocol.

SWQB/NMED. 1998. State of New Mexico Procedures for Assessing Standards Attainment for 303(d) List and 305(b) Report Assessment Protocol

Rosgen, D. 1996. Applied River Morphology. Wildland Hydrology. Pagosa Springs, CO. pp 5-131-136.

USDA-FS. 1998. WinXSPRO A channel Cross-Section Analyzer. West Consultants Inc. San Diego, CA.

USEPA. 1993. Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters. EPA-840-B-92-002. Washington, D.C.

USEPA. 1991. Monitoring Guidelines to Evaluate Effects of Forestry Activities on Streams in the Pacific Northwest and Alaska. EPA-910-9-91-001. Seattle, WA.

USGS. 1994. Water Resources Data New Mexico Water Year 1993. Data Report NM-93-1. Albuquerque, NM.

USGS. 1983. Streamflow Characteristics Related to Channel Geometry of Streams in Western United States. Water Supply Paper 2193. Albuquerque, NM. 17pp.

Wolman, M.G. 1954. A method of sampling coarse river-bed material. Transactions of American Geophysical Union 35:951-956.

APPENDICES

Appendix B: SWQB/NMED draft Protocol for the Assessment of Stream Bottom Deposits (SWQB/NMED 1999a) Relationships

Appendix C: Relationship between Turbidity and Total Phosphorus

Appendix D: Conversion Factor Derivation

Million gallons/day x Milligrams/liter x 8.34 = pounds/day

10⁶gallons/day x 3.7854 liters/1 gallon x 10^-3 gram/liter x 1 pound/454 grams = pounds/day

10⁶ (10^-3 ) (3.7854)/454 = 3785.4/454

= 8.3379
= 8.34

Appendix E

This protocol was designed to support federal regulations and guidance requiring states to document and include probable source(s) of pollutant(s) in their §303(d) Lists as well as the states' §305(b) Report to Congress.

The following procedure should be used when sampling crews are in the field conducting water quality surveys or at any other time field staff are collecting data.

Pollutant Source Documentation Steps:

Appendix F: Public Participation Process Flowchart

Appendix G: Response to Comments

Written, emailed and faxed responses to this document may be addressed to:

Please include the respondent's full name and title, any organizational affiliations, contact address and telephone number.

In response to the Draft Total Maximum Daily Loading document for the Canadian River Basin, issued June 8, 1999, the Carson National Forest would like to offer the following comments. The SWQB prepared the responses that follow each comment.

Comment: Public Notification – typically correspondence between the State Environment Department and the Forest is conducted in a formal manner with hard copy letters sent to the Forest Supervisor or District Ranger. An E-mail notification was sent out via mailing list announcing the draft of this document but it was not clearly stated in that electronic message that this was the only notification that would be made. We feel that a formal hard copy transmittal is appropriate. While the use of electronic mail and document distribution via web sites is becoming more prevalent in this day and age, we feel it is still appropriate to formally transmit this type of information in a traditional manner, especially if you are seeking comment to a document of this type.

Response: The public notification process for TMDLs is extensive. The announcements of availability for the 30-day public comment period go out via email, in several newspapers, to radio stations, and to those on the WQCC mailing list. Although we understand that this may not be the most convenient for everyone, the SWQB has been moving towards a "paperless" workplace and it has not been our practice to mail copies of the document to each individual on these lists.

The SWQB plans to addresses the Forest Service’s desire for a more "formal process" through the use of the existing liaison from the Forest Service to SWQB. Hard copies of the TMDLs will be provided to the liaison for distribution to the Forest Service Ranger District(s) concerned.

Comment:  Document Readability – the TMDL document is not particularly "reader friendly" in that it uses many technical terms that are not understood quickly and easily by the public at large. Technical terms, when used, should be defined and referenced either in the body of the text or in a glossary of terms at the end of the document. In addition, many assumptions are made which serve as the basis for your conclusions and these assumptions and their sources are not clearly defined or explained within the context of their use in this document.

Response:  The SWQB agrees that this document is somewhat technical in nature. It was necessary to strike a balance between "readability" and technical accuracy throughout the document. It is understandable that this document may not be "understood quickly and easily by the public at large." In order to provide an opportunity to ensure public understanding of not only the document but the entire TMDL process, the SWQB provided a forum for clarification and discussion of the TMDL in the watershed in the form of a public meeting held in Angel Fire June 16, 1999. It was unfortunate that no Forest Service representatives were able to attend this meeting.

Without more specific instances where clarification in the document is needed it is difficult to address this comment.

Comment:  Land use/cover and Cimmaron (sic) watershed Figures (1 and 2) – these two figures display various types of information without citation as to the source of the information (ie – land cover and use Southern Rockies – Eco #210, etc.). Also, Figure 1 displays "TMDL segments" with a bold line type indicating various stream segments of interest but Figure 2 does not display the same stream segments with this bold line type in all cases. This is confusing from the standpoint of what these two figures are intended to display or not display.

Response:  The two figures have been updated to address your concern. Both figures now show the Impaired Reaches (in pink) that are being addressed in this document.

Comment:  Rosgen Stream type and stream bottom deposits – on page 4 of the document there is a discussion of Rosgen type for Cienguilla (sic)(E5) and North Ponil (E4) Creeks. This discussion goes on to indicate that a target value of 27.7 (E4) and 60.4 (E5) percent fines was derived from Mr. Rosgen’s published data (1996). We do not understand how these target values were derived, a cursory review of Mr. Rosgen’s publication did not readily answer this question. Also in the next paragraph you state that a target level for percent fines would be 20 percent. If the published data you cite (Rosgen, 1996) indicate a Rosgen E channel can range from approximately 28-60 percent fines, is a target level of 20 percent fines within the natural capability of these stream types? Again, this portion of the document utilizes many terms and concepts not completely familiar to the general public. We would suggest that a discussion of Rosgen methodology and the terms used within this methodology would be helpful to enable persons unfamiliar with the topic to understand more completely.

Response:  The text in this document (in the References) has been updated to include the page numbers in the Rosgen text from which the values you questioned were obtained. However, the SWQB does not feel that it is necessary to include any further discussion of Rosgen methodology. The reference to Rosgen’s book on the topic should provide those interested with a place to start for more information.

As mentioned in the text of the TMDL (p 4), the relationships between embeddedness and biological scores and embeddedness and percent fines indicate a target percent fines of 20%. This methodology is based on New Mexico streams (unlike the Rosgen approach) and was considered a more representative and conservative value.

Comment:  Linkage of water quality and pollutant sources – on page 9 of the document there is a short paragraph describing the removal of M^cCrystal Dam and the resulting damage. The Carson National Forest recognizes that this stream segment is a source of sediment. We would like to extend an invitation to the Surface Water Quality Bureau personnel to meet with forest personnel and evaluate this situation on site and discuss possible remediation efforts to alleviate this situation. Please contact the Questa District Forest Ranger to arrange a date convenient to all.

Response:  The SWQB appreciates the invitation by the Forest Service to address the sediment loads resulting from the removal of M^cCrystal Dam and we look forward to the opportunity to address nonpoint source pollution in this watershed.

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This page last updated August 30, 1999