Environmental Monitoring Report...My Analysis

By Richard Barish

I have now reviewed the draft SWCA report.  The purpose of this report is to provide baseline data about existing environmental conditions in the Bosque in the Central to Montaño stretch where development is being proposed.  Future surveys can be compared to this survey to determine if the development has had an adverse environmental effect on the Bosque and to correct any such adverse impacts.  The purpose of the report is not to evaluate whether the project (which does not yet exist) will have any adverse environmental impacts, like an environmental impact statement would.

The guts of the report are quite technical and beyond my ability to evaluate.  The report is being looked at by various scientists, however, and I will provide a further report after I hear back from them, assuming there is anything to report.  For now, I want to focus on several obvious problems with the report.

First, the report makes this statement in its conclusion at page 84: "Given the already environmentally disturbed condition of the MRG [Middle Rio Grande] bosque, the proposed project is not anticipated to have a significant negative environmental impact on the area."  Naturally, the Berry administration is focusing on this sentence to try to justify what has been done from day one.  However, this conclusion is highly inappropriate for three reasons:

(1) The study did not evaluate the environmental impacts of any proposed project.  It merely established baseline environmental conditions as described above.  The conclusion of no negative environmental impact is unsupported by any scientific study or evaluation in the report.  It is an entirely political statement, made solely for the purpose of providing fodder to the Mayor to justify development in the Bosque. 

(2) The sentence states that the Bosque is already disturbed, so more disturbance will not cause any harm.  The premise of the sentence is misleading.  It is true that the Bosque is an ecosystem that is very altered from its condition prior to extensive human development.  However, that does not mean that there is not a lot of terrific native habitat in the area of the proposed development.  There is.  The alteration of the Bosque over the last few centuries should not be used as an excuse to degrade outstanding Bosque habitat.

(3)  There is no "proposed project" at this point (in large measure due to YOUR participation!), so it is impossible to say whether any project does or does not have adverse environmental effects. 

We need to demand that a purportedly scientific report not be used for an entirely political purpose and insist that this sentence be removed from the final report! 

The second obvious objection to the report is that it assumes that certain decisions have already been made about the development.  Specifically, it states on page 1 that "The trail cross-section is proposed to vary from approximately 1.2 meters to 2.4 meters (4 to 8 feet) in width."  This is highly disturbing, because it indicates someone in the Mayor's office is telling the consultants what the trail will be before public comment has even been taken on the trail design!  Please tell the City:  The wishes of the public must be taken into account before any decision about the trail is made!

The third point I want to make is something we can commend the City for.  The SWCA study appears to give the City a tool to evaluate whether its development will have an adverse environmental effect on the Bosque.  However, this will be an after-the-fact evaluation, only done after the project has been constructed and used.  We also need to attempt to assess what the effects might be before-hand, so that we can choose a project plan that will not have an adverse environmental effect.  The Bosque Action Plan, the City plan that governs the Bosque, requires such an analysis, and the BAT has repeatedly criticized the City for failing to undertake such an evaluation.  The City has now agreed that it will undertake such an analysis of the proposals once they are developed! 

We have been very critical of the City, but we should also credit where credit is due.  Please commend the City for its decision to undertake an analysis of the expected environmental impacts of project proposals before selecting the project that will be constructed.

Please plan on sending comments on the draft report to the City by November 30.  You can draft your own, or I will send out suggested comments that you can adapt and modify later this week after I hear back from the science folks who are reviewing the report. 

Comments should be sent to:

Dr. Matt Schmader
Open Space Division
PO BOX 1293
Albuquerque, NM 87103

or email to:

There will also be a public meeting about this report on Tuesday November 18th, at the Rio Grande Nature Center, from 6pm to 7:30pm.  Please attend!

UPDATE:  the public meeting has bee CANCELED, but the BAT has organized it's own alternate meeting, same day and time:

Plan "B"osque