United States      Region 6        EPA 906/9-81-002
           Environmental Protection   1201 Elm Street      August 1981
           Agency        Dallas TX 75270

v>EPA      Environmental       Draft
           Impact Statement

           Wastewater Treatment

           Twining Water and
           Sanitation District
           Taos County, New Mexico

Thts report is available to the public through the
National Technical Information Service, us Department
of Commerce, Springfield, Virginia 22161


                                   REGION VI

                                 12O1  ELM STREET

                               DALLAS, TEXAS 7527O
                              August 24, 1981

 Enclosed  is  a  copy of the Draft Environmental Impact Statement (EIS) on
 the awarding of additional grants under Section 201 of the Clean Water
 Act for design and construction of upgraded wastewater treatment facili-
 ties in the  Twining Water and Sanitation District (TWSD), Taos County,
 New Mexico.  The EIS has been prepared concurrently with a wastewater'
 treatment facilities plan under a grant from the U.S. Environmental
 Protection Agency  (EPA).

 This document has  been prepared in compliance with the National  Environ-
 mental  Policy Act  of 1969 and implementing regulations.   Written  comments
 or inquiries regarding this EIS should be addressed to Mr. Clinton B.
 Spotts, Regional  EIS Coordinator, at the above address by the date
 stamped on the cover sheet following this letter.

 EPA  and the TWSD  will  hold a  public  hearing on the Draft EIS  and  facili-
 ties plan  at 7:00 p.m.,  Tuesday,  October 20,  1981  in the auditorium of
 Enos Garcia Middle School  on  West Kit Carson  Road  in Taos, New Mexico.
 I  request  that  individuals and respresentatives  of groups wishing to
 make a  statement  at the  hearing  submit a written copy of their proposed
 statement  at the  time  of the  hearing, if possible.   Witnesses should
 limit their testimony  to a five minute summary of  their  written state-
 ment.   Comments on  the Draft  EIS  will  be considered  in the preparation
 of the  Final  EIS.

 If changes  required in the Draft  EIS  are minor,  the  Final  EIS will
 incorporate  the Draft EIS  by  reference and  include only:   (1)  a revised
 summary, (2)  revisions necessary to the  Draft  EIS as  a result  of  public
 comment, and  (3) EPA's response to comments made on  the  Draft  EIS.
 Therefore, the Draft EIS should be retained for  possible  use  in conjunc-
 tion with the Final EIS.  The  Final EIS will be  sent  only  to  those  who
 request a copy or who make substantive comments on the Draft  EIS.

 In cases where persons requested only  a copy of the  summary of the  Draft
 EIS,  this transmittal letter accompanies that  summary.

A technical reference document containing additional background informa-
tion  has been compiled and may be reviewed along with the Draft EIS, a
Spanish  translation of the summary of the Draft EIS, and the draft
facilities  plan at the following locations:

1. Harwood Foundation
Public library
LeDeux Street
Taos, New Mexico
2. Twining Water and Sanitation
District Offices
Above the Fire Station
Taos Ski Valley, New Mexico
3. Taos Pueblo Administrative
Taos, New Mexico
4. Taos Ski Valley, Inc.
Taos Ski Valley, New Mexico
If you need additional Information,
at (214) 767-2716 or (FTS) 729—2716.
Frances E. Phillips
Acting Regional Administrator
5. Supervisor’s Office
Carson National Forest
Cruz Alta Road
Taos, New Mexico
6. New Mexico Environmental
Improvement Division
Taos County Health Building
Paseo De Pueblo Sur
Taos, New Mexico
7. New Mexico Environmental
Improvement Division
Crown Building
725 Saint Michael’s Drive
Santa Fe, New Mexico
please contact Mr. Clinton B. Spotts

Responsible Agency: U.S. Enviromental Protection Agency, Region VI
Action being considered: Possible awarding of design and construction funds
for wastewater treatment facilities in the Twining
Water and Sanitation District, Taos County, New
Cooperating Agencies: U.S. Dept. Agriculture, Forest Service
Carson National Forest
New Mexico Environmental Improvement Division
Contact for further
information: Clinton B. Spotts, Regional EIS Coordinator
U.S. Environmental Protection Agency, Region VI
1201 Elm Street
Dallas, Texas 75270
Phone: Commercial (214) 767—2716
FTS 729—2716
Abstract: The Twining Water and Sanitation District has considered alterna-
tives for wastewater management which would solve a pollution
problem in the high—quality Rio Hondo watershed of northern New
Mexico. The District proposes construction of a new advanced
treatment plant with a capacity of 95,000 gallons per day which
would allow about 20 percent growth. A major alternative is to
rehabilitate the existing plant, add phosphorus treatment, and
provide only the capacity needed to treat existing wastewater flows
(80,000 gallons per day). EPA is considering approval and funding
of either alternative (as well as providing no funding). Many
canplex issues bear on EPA’s decision, Including impacts on water
quality, water supply, and soda—economic conditions.
Date Comments Due: 3 NOv 1981
Responsible Official:
Frances E. Phillips
Acting Regional Administrator


The Twining Water and Sanitation District (TWSD) is responsible for
wastewater management for the resort complex of Twining, commonly known as
Taos Ski Valley. FigUre 1—1 illustrates the general location of Twining with
respect to other coITw1 unitieS in Taos County, which is in Northern New Mexico.
TWSD owns and operates an existing sewer system and treatment plant which
serves recreational, commercial and residential facilities in the base area of
the resort complex. The existing facilities have long been and remain a
source of pollution which has adversely affected the high—quality waters of
the Rio Hondo. Past problems related to excessive discharges of organic
matter, solids and bacteria have largely been controlled by recent
improvements to the treatment plant. However, treatment would improve if
infiltration problems were corrected. Also, the existing plant must be
modified or replaced in order to comply with proposed regulations requiring
the control of the nutrient phosphorus. Full protection of water quality In
the Upper Rio Hondo may require control of non—point pollution sources such as
runoff from the base area, erosion of fertilized ski trails and discharges
from septic tanks and cesspools. Runoff control measures are discussed In the
U.S. Forest Service Draft Environmental Impact Statement, proposed Taos Ski
Valley, Inc. master development plan, April 1981.
A major issue concerning alternative solutions to the existing problems
Is whether or not any treatment facilities should provide capacity to
accommodate further development lfl the resort area. TWSD intends initially to
provide sufficient treatment capacity to allow an approximate 20 percent
increase In the sale of lift tickets and a O percent expansion in base area
overnight accommodations; additional expansion for overnight visitors may
Occur if stream quality can be protected. This development is opposed by
groups representing downstream residents who are concerned that the growth
will harm the water quality and quantity of the Rio Hondo and will have
adverse effects on the soclo—economic envirori ent of the area.
The no action alternative would fail to solve the existing pollution
problem and is not acceptable. Fifteen specific treatment alternatives were
evaluated as shown in Table 1—1 based on eight issues: cost; engineering
reliability; impacts on water quality and water supply; construction and land
use (growth) impacts; potential for community conflict; and benefit to the
region. For example, alternatives rated 1 as to cost are the least expensive
options. Costs presented represent totar annual costs over a 20—year period
and include construction and operation and maintenance costs.
a. the widespread use of septic tanks (alternative 3) would have
unacceptable water-quality impacts;

“• .4”
N • i
o OmiI

ISSLES are identified by letter, as follows. = Cost. 9 Reliability. C = Water jality. D = Water supply. E Construction impacts.
F = Land use (growth). C Community conflict. H r 9enefits to region.
Build new plant In Twining using
advanced technology which needs
energy, chemicals
Build new plant In Twining using
new technology which grows algae
in ponds inside a areenhouse
Abandon the sewer system;
everyone uses septic tanks
4. Greywaterf Some sewage goes to existing
blackwater (renovated) plant; toilet wastes
to compost ing toilets
5. Storage and Store the winter sewage and dis—
discharge charge it in spring when river
can better assimilate nutrients
6. Total Pipe sewage to ponds near Arroyo
detention Seco and evaporrte it
7. Lard Pipe sewage to ponds near rroyo
applicaticn Seco and let farmers use it for
(fartaing) irrigation
very progressive in Its use of resources;
Comparatively inexpensive
too new an Idea to know hcw well it will work
“Conventional” approach; inexpensive;
will not solve the pollution problem
2 3 2 2 1 2 1 3 Pros: very progressive In its use of resources
Cons: expensive; reliability uncertain
1 2 3 1 2 1 3 Pros:
3 1 1 3 3 2 2 2 Pros:
nay impro’ie downstream water supplies in
terms of nuantity; inexpensive
may not solve pollution problem
simple; takes Twining sewage Out of Rio Honda
expensive; wasteful of water; water rights
would be needed
2 2 2 1 3 2 3 2 Pros: supports farming; not too expensive
Cons: repuires acreement of farmers, and some type
of legal arrangement with Twining
6. Pipeline to Renovate existing Twining plant;
Rio Crande ild pipeline to Rio Grande
(west of Arroyo 1-londo) and
discharge sewage there
. Holding Store sewage in ponds in Twining
tanks and use trucks to haul it to the
Town of Taos sewage plant
Pipe sewage to a new regional
sewage plant near Arroyo Hondo
Pipe sewage to Town of Taos
sewage plant
Renovate existing plant and ado on
advanced processes for nutrient removal
Build very complex plant In Twining
which would turn sewage into drinking
water for use by Twining
14. Greywater Combine alternatives 4 and 6: compost
evaporation toilets, greywater evaporation
15. Aauaculture Combine alternatives 2 and 5
÷ snoveiaking
2 2 1 3 2 2 2 7 ‘ros: takes Twining sewage out of Rio Hondo
Cons: water rights would be needed; major
construction impacts
1 2 1 3 1 2 2 3 Pros: simple, relatively inexpensive; eliminates
pollution in Rio Honda
Cons: uses energy; heavy truck traffic; water
rights would be needed
2 3 1 3 3 3 3 1 Pros: eliminates pollution in Rio Honda; could
previde sewers for downstream residents
Cons: major lend use changes could occur in Hondo
Valley; major construction Impacts; water rieht
would be needed
2 3 1 3 2 3 3 1 Pros: takes Twining sewage out of Rio Honda; could
provide sewers for Arroyo Seco—El Prado area
Cons: major land use chanoes could occur near
Taos; major construction impacts; water riohts
would be needed
1 3 2 2 1 2 1 3 Pros: “conventional”; relatively inexensive
Cons: reliability is questionable
3 3 1 2 1 2 1 3 Pros: takes Twining sewage out of Rio Hondo,
without adverse effects on flows
Cons: extensive energy and chemical use; very
expensive; against federal, state regulations
3 3 l 3 3 2 2 2 Pros: simple; takes Twining sewage out of R o Hondo
Cans: mxpensive; reliability uncertain; wasteful
of water; water rights would be needed
2 2 3 1 1 2 1 2 Pros: progressive in use of resources; would
increase spring and sum ner runoff
Cons: some auestions about reliability; may not solve
pollution problems
a. 1 = less impact IPest ratinc); 2 intermediate impact; 3 = more lmpact.
1. Conventional
2. Aouaculture
3. Septic tanks
Name of
Brief description of
Ratings on
Pros = reasons which might lead some people to
favor an alternative. Cons = reasons which
might lead some people to reject an alternative.
2 2 2
“conventional” approach
1 2 2 2 1 2 1 2 Pros:
1 1 3 2 1 1 1 3 Pros:
10. Regional
plant in
Hondo Valley
11. Regional
plant in
12. Rehabil-
13. Total

b. construction of conventional treatment facilities (alternatives 1
and 12) would be comparatively inexpensive (on the order of $120,000 to
$150,000 per year to serve existing development) and generally have less
adverse enviromental impacts than other choices.
c. Innovative processes (alternatives 2, 4, 5, 13, 14, 15) are
generally much more expensive ($270,000 per year or more for total treatment
or a combination blackwater—greywater system). Aquaculture Is cost-
competitive with conventional systems but may not be reliable in a high
mountain setting. Use of effluent for snowmaking probably would result in
violation of water—quality standards.
d. Regional concepts, Involving treatment facilities in downstream
areas (alternatives 6-11) could benefit some persons outside Twining but would
generally have severe adverse impacts on water supply, land use and community
relations. After considerable public discussion, all such alternatives were
opposed by the people of’ the area.
Of the fifteen alternatives, construction of a new plant or rehabilitation of
the existing plant appear to be the most cost—effective; aquaculture could be
acceptable if a pilot plant were successfully operated. The facilities plan
engineer considers a new plant to be the most reliable choice for meeting
water—quality objectives, which is an important consideration in a basin where
past treatment failures have caused environmental damage.
Seven capacity alternatives range in size from 75,000 gallons per day
(gpd) to 148,000 gpd. As a practical matter, discharges would be limited to
95,000 gpd based on proposed levels of treatment and the assimilative capacity
of the Rio Hondo, unless and until a larger flow can be demonstrated to meet
water—quality objectives. Table 1—2 compares the impact of the two most
representative capacity alternatives: B (an 80,000 gpd plant which would
allow hookups of existing base facitities but provide for no new hookups and
thus no increase in skier capacity nor any new high-density commercial
development); and E (a 95,000 gpd plant which would permit an Increase in the
daily skier limit from 4050 to 4800, and which would service nearly 500 new
pillows in the base area).
Cornriunity opinion regarding alternatives B and E is sharply divided. On
the ore hand there are substantial economic benefits to the Taos region from
Increased skier use at Twining, and these benefits are greater from alter-
native E than alternative B. Moreover, growth in Twining is not constrained
by any legal limitations and is viewed by some as Inevitable. (Indeed, If
water quality requirements are met and county zoning is not adopted, an even
larger plant could be built In the future.) Thus a 95,000 gpd plant is seen
by many as both necessary and as providing substantial economic benefit to the
community by servicing an expanding winter tourism industry.
However, negative impacts (including more traffic, more water use, and
more potential discharge from non—point sources) also Increase with growth.
Many citizens believe that any wealth created by winter tourism is not equally

Impacts from Alternative B relate to: no increase in skier limit (remains at 4050); increased visitation during off—peak periods
(winter); small increase In summer; 470 new pillows in 94 new cabins (added to 295 existing pillows); no increase in commercial
facilities (remain at 931 pIllows); see Tables 6—7, 6—8, 6—9. In reality, Impacts associated with alternative E would probably
also occur from alternative B, but serviced by on—site systems rather than a central treatment plant.
Impacts from alternative E would include all changes listed for alternative B, increase In skier limit from 4050 to 4800,
proportional (20 percent) Increase in off—peak use; expansion/construction of lodges and condos to provide for 50 percent more
overnight capacity In commercial facilities of base area (489 new pillows added to 931 existing) - /. As stated above, all these
changes could occur under alternative B; however, alternative E would facilitate these changes. Impacts marked with asterisk ()
could occur outside Twining if skier limit Is increased, but overnight capacity is not (symbolically this should be achieved by
alternative 0).
Economics /
(See Table 6—8, 6-9)
Peak day remains at 4705
Overnight capacity increase from 1226 to 1696
Annual visitation increase from 275,000 to 2O,0OO
Reduce pollution due to improved wastewoter treat-
ment; increase in potential non—point source pol-
lution from cabins (but may be controlled — see
5.4.2); potential decrease In other non—point sources
(see 5.4.7)
Need for 11 acre-feet/year of water rights (includ-
ing expanded snowmaking); can be obtained from
rights already held by ISV, Inc. sod/or TWSD
Increase in annual visitation would require an
additional 5 acre—feet of rights outside of TWSD
(e.g. Anijzette, Valdez, flrroyo Seco or wherever
the skiers are lodged)
Peak traffic stays at 1651) cars/day
Total traffic Increase from 104,000 vehicle—trIps
per year to 196,000 vehicle trips per year
1)ir emissions, noise and energy use Increase
proportionally hut standards not violated
Increase in revenues from $27.5 million to
$52 million/year; jobs remain at 1560
Alternative E (95 0 gRd)
Peak day increase to 5579
Overnight capacity increase from 1696 to 2185*
Annual visitation increase from 520,000 to 615,000
If half new jobs In Twining taken by existing
residents, then 38 persons would immigrate to
region because of increased employment
Reduce pollution due to improved wastewater treat-
ment (but, if plant should fail, pollution would be
greater than from B); potential increase in non—
point source pollution from cabins (but may be
controlled — see l .4,?); more potential for con-
struction impacts* (see Table 6—fl; potential
decrease in other non—point sources (see 5.4.7)
Need for 4 additionai acre—feet of water rights
beyond impacts of alternative B; of these 1 4EV
would be for the skier limit increase and 3 AFY*
would be for the increase in overnight capacity;
can be obtained riom rights already held by TSV,
lnc. and/or rwso
Could reduce the demand for regional water rights
from 5 to 2 AFY because skiers stay in Twining,
not elsewherp*
Peak traffic Increases by 310 cars to 1960/day
total traffic increase from 196,000 to 233,000
vehicle trips per year
Air emissions, noise and energy use Increase
proportionally but standards not violated
Increase in revenues from $52 to $61.5 million
per year; 190 additional jobs (total 1750)
Culture; Sensi-
tive Resources
(See Section 6.5,
(See Table 6—1;
Section 6.7, 6.6.7)
Growth/Impacts part of complex factors which In-
fluence chanoes In traditional agrarian society;
significance of impacts widely debated
Possible increase In use of wilderness area nd
trespass on Indian lands (but small compared to
problems If area becomes summer resort)
Construction on 94 cabin lots; improvements In
ski area as described in USFS (1981) and Table
6—6; construction at treatment plant; investment
of energy, chemical and money to improve waste-
water treatment; much higher sewer rates than at
Similar to B but: more tourist influx and cash
flow; areater portion of tourists lodge in TWSD*
Similar to B, but sliohtly greater because of
more skiers and overniaht resident s*
Similar to B except: addtional construction
on 3 — 5 acres of base area*; increase in rates
more widely shored
a. If the District were to so allow, some or all of this change could occur
treatment systems.
in high-density development using independent
b. Assumes no benefits from shuttle service or from reduced commuting which may result from expanded lodging In Twining.
c. Values are for a good ski year and, as discussed in Table 6—9, more than half occur in Taos region, not In Twining.
I actor Alternative 8 (80.000 and)
Populations; see
Tables 6—7, 6—8, 6—9
Water Resources;
see Section 6.2.7
Traffic, Air
Quality, Noise
(See Section 6.5,
Table 6—8, 6-9)
The historic decline in streamflow in the Rio bonds, would not be significantly affected by either
alternative because It is caused by reforestation of the watershed arid reduced snowfall, and not by
development at the ski valley

shared among community members, but rather adds to the many stresses which
threaten the survival of the established Indian and Hispanic culture. These
residents — including many living downstream of’ Twining — believe that as a
matter of equity an 80,000 gpd plant is more appropriate until TWSD can
demonstrate that its facility will reliably solve existing water pollution
problems. They propose that if and when TWSD is In full compliance with all
regulations, expansion of’ the facility would be possible using private funds —
that is, at the direct expense of those who benefit. The debate over the
capacity alternatives has been sharp and without apparent consensus to date.
At least in part this may reflect widely different Individual perceptions
about what is ‘best’ for the Taos area.
The District has made a preliminary decision (subject to public Input on
this ElS) to select alternative 1 (conventional treatment plant). Design
capacity would be 95,000 gpd but actual flows would be gradually expanded from
80,000 gpd.
A large number of other alternatives being considered by the District
relate to specific components of wastewater management. In general, it
appears to be most cost—effective to: rehabilitate the sewer system to
control infiltration; actively manage on—site systems; use advanced on—site
disinfection techniques to more fully protect the quality of the Rio Hondo;
increase water—conservation efforts, especially through use of’ dry toilets or
extremely low—flush toilets; design rates to recover costs from those who use
the area. Of particular importance are alternatives being considered by the
District for ensuring that water—quality objectives are indeed met by any new
facilities. The primary options include: adoption of an expansion policy, In
which new hookups would be contingent on plant performance; and value
engineering analysis of plant design, construction and operation.
EPA may choose to fund all, part, or none of the District’s preferred
alternative or some other alternative. In reaching Its decision, EPA believes
that decisions about regional growth and land use must be made at the local
level; the agency will not impose its judgment as to the appropriate future
for the region. Rather, EPA will act within the constraints of the choices
which are available, will evaluate Impacts such as Identified In Table 1—2,
will consider community input and comments concerning the DEIS, and will
Identify the process and capacity alternative which it deems to be the most
cost-effective. Any decision to limit or deny funding would not remove the
District’s responsibility to improve its treatment works.
The New Mexico Environmental Improvement Division has funding options
par iliel to those available to EPA.

The U.S. Forest Service administers the site of’ the existing treatment
plant through a special use permit and must approve any construction or
expansion of new facilities on National Forest Land. Also, Taos Ski Valley
Inc. has prepared anci the Forest Service has approved (with modifications)
expanded parking facilities and various up—mountain improvements in the ski
area. Implementation of the improvements awaits resolution of appeals to the
USFS decision to approve the plan. When implemented, the agency will oversee
the control of’ non-point source pollution from these actions and thus shares
with TWSD responsibility for protection of the overall quality of the Rio


6.1.1 Existing Conditions 6- 2
6.1.2 Impacts of’ the No—Action Alternative 6— 5
6.1.3 Impacts of Treatment Alternatives 6— 5
6.1.4 Impacts of Capacity Alternatives 6— 7
6.1.5 Impacts of Other Types of Alternatives 6— 8
6.1.6 Impacts of EPA and Other Agency Alternatives 6- 8
6.2.1 Existing Surface Water Quantity 6- 9
6.2.2 Existing Surface Water Quality 6-11
6.2.3 Ground Water Quantity and Quality 6—21
6.2.4 Water Supply and Water Rights 6—22
6.2.5 Impacts of’ the No—Action Alternative 6—26
6.2.6 Impacts of Treatment Alternatives 6—26
6.2.7 Impacts of Capacity Alternatives 6—30
6.2.8 Impacts of Other Types of Alternatives 6—32
6.2.9 Impacts of’ EPA and Other Agency AlternativeS 6—33
6.3.1 Existing Conditions 6—34
6.3.2 Impacts of’ the No—Action Alternative 6—35
6.3.3 Impacts of Treatment Alternatives 6—35
6.3.4 Impacts of Capacity Alternatives 6—35
6.3.5 Impacts of Other Types of Alternatives 6—36
6.3.6 Impacts of EPA and Other Agency Alternatives 6—37
6.4.1 Existing Conditions —37
6.4.2 Impacts of’ the No—Action Alternative 6—41
6.4.3 Impacts of Treatment Alternatives 6-41
6.4.4 Impacts of Capacity Alternatives 6—41
6.4.5 Impacts of’ Other Types of Alternatives 6—42
6.4.6 Summary of Impacts on Endangered and Threatened Species 6-42
6.4.7 Impacts of’ EPA and Other Agency Alternatives 6—42

6.5.1 Existing Conditions 6—43
6.5.2 Impacts of the No—Action Alternative 6—46
6.5.3 Impacts of’ Treatment Alternatives 6—46
6.5.4 Impacts of’ Capacity Alternatives 6—47
6.5.5 Impacts of Other Types of’ Alternatives 6—48
6.5.6 Impacts of’ EPA and Other Agency Alternatives 6—48
6.6.1 Existing Population, Land Use, Economy and Infrastructure 6—49
6.6.2 Cultural Patterns 6—59
6.6.3 Development Potential and Population Projections for Twining 6—67
6.6.4 Impacts of the No—Action Alternative 6—75
6.6.5 Impacts of Treatment Alternatives 6-75
6.6.6 Impacts of Capacity Alternatives 6—76
6.6.7 Impacts of Other Types of Alternatives 6—89
6.6.8 Impacts of EPA and Other Agency Alternatives 6-92
6.7.1 Existing Conditions 6—93
6.7.2 Impacts of’ the No—Action Alternative 6—93
6 7.3 Impacts of’ Treatment Alternatives 6—93
6.7.4 Impacts or Capacity Alternatives 6—94
6.7.5 Impacts of Other Types of’ Alternatives 6—94
6.7.6 Impacts of EPA and Other Agency Alternatives 6—95
6.8.1 Adverse Impacts Which Cannot be Avoided 6-95
6.8.2 Short—term Uses of the Environment Versus 6—96
Long—term Productivity
6.8.3 Irreversible and Irretrievable Commitments of 6—96
10. GLOSSARY 10—1

List of Figures
1-1 Location Map: Taos County, New Mexico 1— 2
3-1 Location Map: Taos County, New Mexico 3— 2
4—1 Twining Water And Sanitation District 4— 3
5—1 Location of Alternative Treatment Facilities 5— 4
6-1 Twining Water and Sanitation District Soil Type and Slope 6— 4
6—2 Runoff Patterns, Rio Hondo, New Mexico 6—10
6—3 Violations of Stream Standards, Rio Hondo 6—17
6—4 Water Quality of the Rio Hondo 6—18
6—5 Sensitive Areas, Taos County 6—44
6—6 Existing Land Use Twining Water and Sanitation District 6—52
List of’ Tables
1—1 Evaluation of Fifteen Treatment Alternatives 1— 3
1—2 Impacts of Capacity Alternatives 1— 5
3—1 Interagency Coordination Responsibilities 3— 5
4—1 Stream Standards and Effluent Limitations 4— 2
5—1 Description of Treatment Alternatives 5— 3
5—2 Issues Used To Evaluate Treatment Alternatives 5— 6
5—3 Evaluation of Fifteen Treatment Alternatives 5— 8
5—4 Evaluation of Six ‘Semifinal’ Alternatives 5—14
5—5 Plant Capacity Alternatives 5—19
5—6 Impacts of Capacity Alternatives B and E 5-25
6—1 Environmental Impacts of Construction Activities 6- 6
6—2 Summary of Water Quality Data, Rio Hondo 6—15
6—3 Taos County Employment, 1960-1980 6—53
6—4 Seasonal Unemployment Rate, Taos County 6—53
6—5 Employment and Personal Income by Sector, Taos County 6—55
6—6 Summary of TSV, Inc. Development Plan 6—60
6—7 Year 2000 Peak—Day Populations and Sewage Flows 6—72
6—8 Population, Economic and Development Impacts of Increased
Skier Limit 6—78
6—9 Distribution of Population, Economic and Development Impacts 6—81
Year 2000
7—1 Issues Identified by EPA at the Scoping Meeting 7— 6
7—2 Issues Identified by the Citizens Advisory Committee 7— 7
3—3 Coordination 7.. 8


The resort complex known as Taos Ski Valley is located in northern New
Mexico, approximately 20 miles northeast of the Town of Taos (Figure 3—1).
The resort contains recreational, commercial and residential facilities
capable of accommodating more than 4,000 day visitors and about 1,200 over-
night visitors and residents; the permanent population IS on the order of 50
persons. Water and Sewer services are provided by the Twining Water and
Sanitation District (TWSD), a legal subdivision of the State of New Mexico
which incorporates a 267—acre area of the Rio Hondo drainage basin (see Figure
4—1). In this report, the terms ‘TWSD’ and ‘the District’ will be used
interchangeably with the name Twining.
As discussed in chapter 4, the wastewater facilities owned and operated by
TWSD have a long history of inadequate performance which has resulted in
pollution of the high—quality waters of the Rio Hondo. Although recent im-
provements to the facilities have significantly improved the situation,
problems remain. TWSD is a designated management agency (DMA) in the New
Mexico state-wide Water Quality Management Plan. As a DMA, TWSD is
responsible for wastewater facilities management within its area of
jurisdiction and can apply for grants for wastewater treatment facilities
improvement. TWSD has applied for and received such a grant to prepare a
facilities plan for improvements to its wastewater collection and treatment
tem. The plan is to provide a framework for wastewater management
decisions through the year 2000. Funding of 75 percent of the planning costs
is provided by U.S. Environmental Protection Agency (EPA) under grant number
C_35—1064—Ol. The New Mexico Environmental Improvement Division (EID) and
TWSD pay the remainder of the planning costs in equal shares. Burton,
LeyefldeCker and Leyendecker, an engineering firm located in Albuquerque, New
Mexico, is preparing the facilities plan.
Decisions made by TWSD about water and wastewater management are partly
dependent upon the laws, regulations, and grant programs of the Federal gov-
ernment, especially the Congressional mandates known as the Clean Water Act
and the National Environmental Policy Act.
Clean Water Act . In 1972 Congress enacted Public Law 92—500, Amendments
to t1 i Federal Water Pollution Control Act, in order to establish a comprehen-
sive program which would “restore and maintain the chemical, physical and bio-
logical integrity of the Nation’s waters”. B ecause municipal sewage is one of
the major point sources of water pollution in the U•S Title II of the new
law provided for an expanded program of federal assistance in the construction
of sewage treatment facilities, and gave the Environmental Protection Agency
3 -1

0 5 IOrnèles
Scale North

(EPA) authority to fund such activities, provided that state and local govern-
ments supply 25 percent of the necessary rinancial support. The EPA grants
are normally qiven in three steps or phases: I. initial planning; II.
detailed design; and ill, actual construction. Under the law the initial
planning phase is emphasized, and must provide a long—range look at a wide
range of alternatives for the collection, treatment and ultimate disposal of’
waterborne wastes. Actions which promote the reclamation and reuse of waste—
water are especially encouraged by the Act, as is clean—up of wastes to the
point that no discharge of’ pollutants occurs from a treatment facility.
Public Law 92—500 requires that a permit be issued for any wastewater
discharge to the waters of the U.S. The permit system is referred to as the
National Pollutant Discharge Elimination System (NPDES), Compliance with the
water—quality requirements of a wastewater plant’s NPDES permit is a mandatory
objective of the facilities planning process.
In 1977 Congress passed Public Law 95—217, which revised portions of the
1972 Act. Collectively, the ompiete amended act is referred to as the Clean
Water Act (CWA). Emphasis was placed upon giving planning consideration to
innovative technologies t ’oi water reuse, energy conservation and/or complete
removal of pollutants. Selection of’ innovative alternatives is encouraged by
the availability of 85 perrent Federal participation in facility design and
construction, instead of the conventional level of 75 percent funding.
EPA has eva].uated whether or not TWSD is eligible for EPA funding. A 1976
opinion of the New Mexico Attorney General (Anaya, 1976) states that TWSD is a
legally formed sanitation district under the laws of the state, notwithstand-
ing its basic commercial nature. The EPA Regional Counsel has determined that
sanitation districts formed under New Mexico law are eligible for EPA con-
struction grants (EPA, 1979b).
National Environmental Policy Act (NEPA) . NEPA is Public Law 91—190, and
was signed in 1969. There are six specific environmental objectives of
federally—funded actions, set forth in section 101(b) of NEPA as follows.
1. To fulfill the responsibilities of each generation as trustee of the
environment for succeeding generations.
2. To assure for all Americans safe, healthful, productive and aesthet-
ically and culturally pleasing surroundings.
3. To attain the widest range of beneficial uses of the environment
without degradation, risk to health or safety, or other undesirable
or unintended consequences.
4. To preserve important historic, cultural, and natural aspects of our
national heritage, and maintain, wherever possible, an environment
which supports diversity, and variety of individual choice.

5. To achieve a balance between population and resource use which will
permit high standards of living and a wide sharing of life’s amen-
6. To enhance the quality of’ renewable resources and approach the
maximum attainable recycling of depletable resources.
NEPA also provides that an Environmental Impact Statement (EIS) be pre-
pared by federal agencies which propose a major action that significantly
affects the quality of the human environment. The EIS must provide informa-
tion to be used in federal decision—making. Section 102(2)(c) of’ NEPA
requires the EIS to consider:
a) the environmental impact of the proposed action;
b) any adverse environmental effects which cannot be avoided should the
proposal be implemented;
c) alternatives to the proposed action;
d) the relationship between local short-term uses of man’s environment
and the maintenance and enhancement of long—term productivity; and
e) any irreversible and irretrievable commitments of resources which
would be involved due to the implementation of the proposed action.
EPA’s decision to prepare an EIS on the Twining project is discussed in
section 4.2. Based on the most recent regulations regarding EIS preparation
(CEQ, 1978; EPA, 1979c), the document is to concentrate on key issues as
determined through an early public “scoping” process, and as further defined
during an extensive public participation process. The public participation
program normally includes the formation of a Citizens Advisory Committee of
local citizens to provide review and advice in the Facilities Plan and ElS
process. The EIS must provide a concise analytical statement which
concentrates on evaluation of real alternatives; for most projects the
document should contain less than 150 pages.
The EIS process includes cooperation with all federal and state agencies
which have management responsibilities for key environmental resources. Table
3—1 lists agencies normally concerned with wastewater projects in New Mexico.
Chapter 7 documents the public participation program during EIS preparation
and describes the process of coordination and review which will apply to the
Draft EIS. A chapter of the Final EIS will include all public comments on the
Draft, and EPA’s responses to these coments.
In addition to the general coordination associated with any wastewater EIS
(Table 3—1), EIS preparation mandates consideration of project—related deci-
sions which may be made by governments or agencies otner than EPA. In the
specific case of Twining, any decisions made regarding wastewater management
may interact with decisions of the U.S. Forest Service (US FS), New Mexico
Environmental Improvement Division (EID), County of’ Taos, and Taos Pueblo.

While all coordination needs to be docunented in the EIS, items with an asterisk (*) represent major, mandatory elements of the consultation process.
EPA Coordination Responsibilities ! 1 Coordinating Agencies and Responsibility Auttority
Identify properties listed on or eligible
for listing on the National Register of
Historic Places that may be affected by the
undertaking.* Identify effects of under-
taking on those properties.
State Historic Preservation Officer; Advisory Council on
Historic Preservation; National Park Service: Identify
existing and potential Recister properties and cosm ent
on findings of environmental document. * Undertake data
recovery and preservation activities if the undertaking
may cause irreparable loss or destruction of significant
scientific, prehistoric or archaeological data.
National Historic Preservation Act of 1966,
as amended; Archeologic and Historic Preser-
vation Act of l97L ; Reservoir Salvage Act of
1960; and Executive Order 11593, entitled
“Protection and Enhancement of the Cultural
Determine if proposed actions will be in or
affect wetlands. If so, prepare a wetlands
assesmeent as part of the environmental
doct.emnt. Identify flood hazard areas as
they are related to existing and proposed
U.S. Army Corps of Engineers: Make wetland determina-
Federal Emergency Management Agency: Provide flood ha-
zard maps of the planning area.
Executive Order 11990, Protection of Wet-
lands; EPA’S Statement of Procedures on
Fiood 1ain Management and Wetlands Pro-
tection (Jaruary 5, 1979).
Executive Order 11988, Floodplain Manane—
ment; Flood Insurance Act of 1968; Flood
Control Act of 1970; National Flood
Disaster Protection Act of 1973; refer also
to Wetlands Protection.
Request preliminary determination of need for
permits for constrt.ction in a waterway, as
relates to dredge ac-si fill activities.
U.S. Army Corps of Engineers: Cooimnt on findings of
environmental doc jpent as may relate to Corps projects;
indicate likelitood of need for Section 404 or Section
10 permits.
Section 404 of Clean Water Act of 1972;
Section 10 of the Rivers arid Harbors Act
of 1899.
Request identification of s1 cificant agri-
cultural lands in the plarning area. Evalu-
ate impacts of the proposed action and recur—
mend mitigation measures.
State and/or Area Conservationist, U.S. Soil Conservation
Service: Identify significant agricultural lands, such
as reported in the Important Farmland Inventory.
EPA’s Policy to Protect Envirorvnentally
Sensitive Agricultural Lands (Septentier 8,
1978); memo frcan CEQ to Heads of Agencies
on ‘Analysis of Ispacts on Private or
Unique Agricultural Lands In Implementing
the National Environmental Policy Act”,
Septeeder 8, 1980.
Request identification of designated or run—
mated Wild, Scenic or Recreational rivers
under the Wild and Scenic Rivers Act. Iden-
tify and avoid or mitigate all impacts to
such rivers.
National Park Service; State Scenic Rivers Adeinistrator;
Bureau of Land Management; U.S. Forest Service: Identify
Wild and Scenic rivers. Conasent of findings of environ-
mental document.
Wild arid Scenic Rivers Act of 1968; Water
Resources Planning Act of 1965.
Identify and determine impacts to flora and
fauna and to any natural stre a or body of
water and consult with reviewing agency on
mitigating, preventing or compensating for
project—related losses of wildlife and to
enhance other resources.
U.S. Fish and Wildlife Service; State Department of Game Fish and Wildlife Coordination Act of 1958.
and Fish: Comment on findings of the envirormental

EPA Coordination ResponsibilitiesY Coordinating Agencies and Responsibility
Request identification of all designated and U.S. Fish and Wildlife Service; State Department of Same
proposed endangered or threatened species and and Fish: Identify endangered species or habitats, in—
critical habitats in the area. Prepare bio— cludirç formal review by the Office of Endangered Species
Endangered Species Act of 1973.
logical assessment of endangered species and! if required under Section 7 of the Endangered Species Act.
or critical habitats if necessary.
Assess direct and indirect iapacts of the NJ4. Environsental leprovement Division (NHEID), Air
Clean Air Act, as amended, 1977.
project on air quality. If there are possi— Quality Bureau: Assist with assessment of project ire—
ble significant adverse effects, consult with pacts. Respond to request for conformity concurrence.
the state or local agency to ascertain con-
formity of the action to the State Air G Jality
Irr lmnentation Plan (SIP). Determine if any
increased emissions are allowable or will be
Consult with propriate agencies and assess U.S. Forest Service; U.S. Bureau of Land Management;
impacts. Submit draft enviror,nentai document State Planning Office; Council of Goverments; Nt.EID;
to A-95 Clearinghouses for review. 2 Iden— of Goverments; I.€lD: Consent on findings
tify P115 standards and violations, and of enviromental document*; opportunity for
relationship of project to the Clean Water consent from local Council of Goverrinents and State
Act. Assess conformance to the Section 208 Planning Office required.
NEPA and Clean Water Act; Noise Control
of 1972; Federal Insecticide, Fungicide
Rodenticide Act; as amended; Resource
servation and Recovery Act; Toxic
stances Control Act; Safe Drinking Water
Act; Office of Management and Budget
Areawide Wastewater Management Plan. Access
Circular A—95.
conformance to other State and local plans,
such as recreation and open space, economic
development and cou ty and rainicipal plans.
1. EPA refers to EPA or persons acting on behalf of EPA or the grantee.
2. Office of Management and Budget Circular A—95 requires that State and areawide “clearinghouses” coordinate Federally—funded projects.
Sources: a) EPA, 1978. Implementation of procedures on the National Enviromental Policy Act. 44FR 64174—64193, Nov. 6, 1979, 40 CFR Part 6.
b) EPA Region 6, 1978. Instruction for preparing enviromental information docrjnents for construction grants projects. CG-99, revised
c) Spotts, Clinton 8., August 1979. Working guidelines for the preparation of envirorreental Impact statements.
d) EPA, 1979. Enviromental assessment of construction grants projects. EPA—43O/9—79-007.

USFS and EID have some direct involvement in facilities planning in Twining,
as described in part C of section 5.
U.S. Forest Service . The TWSD treatment plant is located on lands of the
Carson National Forest; ski trails, lifts and some other facilities developed
by Taos Ski Valley, Incorporated (TSV, Inc.) also occur on forest land. TSV,
Inc. has prepared a 30-year master plan which proposes to limit lift—ticket
sales to approximately 4,800/day, and which proposes new parking facilities,
ski lifts and trails. The Forest Service has published a Draft and Final EIS
on the master plan (USFS, l98la; and l98lb). The EIS is limited to facili-
ties which relate directly to skier use of the area and does not discuss
potential development which may occur on private land. Section 6.6.1 char-
acterizes the master plan.
USFS permits issued to TWSD and TSV, Inc. include oeneral stipulations to
maintain water quality (see Appendix A). USFS and EPA have agreed that since
EPA is the federal agency responsible for water pollution control, EPA should
take the lead in enforcing any federal water quality requirements which apply
to Twining. Water quality from non—point sources on recreational lands is
addressed in the Forest Service EIS.
EID . The State of New Mexico, through the Water Quality Control
Commission and EID, establishes wastewater planning priorities in New Mexico
(Twining is number 2 on the 1981—82 draft priority list) and contributes 12.5
percent of the funding to Section 201 wastewater projects. EID also is the
lead agency for enforcement of water—quality regulations. Additional duties
of the agency include development of wasteload allocations for future NPDES
permits and administration of’ on-site wastewater system regulations and the
State ground—water discharge regulations.
County of Taos . The County is the only agency with the power to regulate
land use in Twining. The County currently has extensive regulations with
respect to subdivision activity involving five or more lots. The County has
yet to use its other powers to control land use and at present there are no
zoning laws in effect in unincorporated areas of’ the County (except extra—
territorial zoning by the Town of Taos).
Taos Pueblo . Taos Indian Pueblo land lies south of, but not adjoining,
the TWSD (Figure 3—1). The Pueblo has a general interest in the quality and
quantity of all headwaters in the area that touch the Pueblo directly or are
considered as sacred lands and waters to the tribe (Bernal, 1981; Jiron,
1974). Consideration of’ these interests by federal agencies is guaranteed by
the American Indian Religious Freedom Act (Public Law 95—341). Specifically,
the Act guarantees access to sites, such as sacred lands and cemeteries;
sacred objects, including those gathered, transported and possessed by
museums; and ceremonies and traditional rites, as they relate to federal
agency practice.
For New Mexico, there is specific concern for all lands traditionally
occupied and traveled by Pueblo Indians, the abililty to commune with those

lands, and the need for protection of ecologically sensitive lands and waters
of religious significance, with no federal actions taken to diminish or
degrade natural flows taken without due consultation with affected tribes
(USD1, 1979).


A large nunber of’ issues have been raised concerning wastewater management
in the Twining Water and Sanitation District (TWSD). This section provides a
brief overview of two issues which are especially critical to decision—
making: existing water pollution in the Rio Hondo; and the environmental
impacts of any growth which could occur as the result of new wastewater
facilities. Each discussion is followed by references Indicating where more
detailed information may be found.
Water Pollution . The Rio Hondo is a high—quality mountain stream. The
State of New Mexico has adopted stringent stream standards intended to protect
the river against significant degradation. These standards are listed In
Table 4—1; recent proposed changes are discussed in section 6.2.2. Water
meeting these standards is considered suitable for use as a drinking water
supply (but only after disinfection), and for fish, irrigation, livestock and
wildlife water, and boating. The standards do not require the river to be
maintained in an absolutely pure state.
In 1967 a predecessor of TWSD constructed sewers and a central treatment
plant in Twining. Figure 4—1 shows the District boundaries and the location
of the existing wastewater management facilities. These facilities are
subject to numerous environmental regulations, Including effluent limitations
which strictly limit the amount of pollution which may be discharged to the
Rio Hondo. Table 4—1 lists two sets of effluent limitations for the Twining
treatment plant — existing limitations which have been in effect for the last
several years, and more stringent limitations which would be imposed to obtain
full compliance with proposed changes in the stream standards.
The Twining treatment plant was a source of river pollution almost from
its inception. Problems included poor design and construction of sewers and
the plant itself, and excess water (called infiltration) which has seeped into
Sewers, causing overloading of’ the plant. TWSD’s operation of the facilities
generally was not adequate. The problems were most severe in winter, when
flows into the plant are large due to the influx of skiers, and the facility
has not been able to provide adequate treatment of the sewage.
Violations of the existing effluent limitations were common throughout the
middle and late 1970’s; as a result the Rio Hondo contained excessive amounts
of organic material, suspended solids, bacteria and other contaminants. The
effluent from the plant caused some violations of the stream standards and
damaged aquatic life. The most frequent problems were for bacteria, chlorine,
ammonia, and phosphorus. The problems were concentrated within a few miles
downstream of the sewage plant. By the time the river reached the mountain
front above Valdez, the quality of water met the state standards again. The

mg/i = milligrams per liter. gpd = gallons per day.
(minimi.sn value)
a. I 44WQCC, 1981. See also note f.
b. N4WQCC, 1980.
c. EPA, 1974; the New Mexico regulations also apply to the effluent.
d. These limits are proposed by EID and encompass both the State and Federal requirements; EID, 1981b.
e. The limit of 200 is no longer required by federal regulations.
1’. () existing standard to be eliminated; * proposed standard to be added MW C approved revision April 1981; State Attorney
General and EPA approval expected late sunner 1981.
g. See discussion in 6.6.2.
h. Refer to Appendix B.4 for discussion of proposed phosphorus effluent standard at Twining,
All standards are maximiaii$ (not to be exceeded) except pH (range) and dissolved oxygen
Parameters & Units
Mexico New Mexico
Standards ‘ Effluent Regulations W

Effluent Limitations /
(30 day average)
Effluent Limitations 1
(30 day average)

Biological Oxygen Demand
(5-day) (mg/i)
- 30
Chemical Oxygen Demand
Total Suspended Solids (mg/i)
Settleable Solids (el/i)
Fecal Coliforms (colonies
per 100 ml)
200 !
. 500
to 8.8
6.6 to 8.6
6.0 to 9.0
6.6 to 8.6
Chlorine Residual (mg/i)
Flow or Discharge (gpd)
Total Pmnonia Nitrogen (mg/i)
(0.2) 1’
Un-ionized Aranonia
as N (mg/i)
Conductivity (micramhos)
Dissolved Oxygen (mg/i)
6.0 or 85%
saturation, —
is higher)
Nitrate—nitrogen (mg/I)
(0.8) 1 ’
Temperature (°C)
Total Organic Carbon (mg/l)
Turbidity (Formazin
Turbidity Units)
Total Phosphorus (mg/i) !Y
Total Inorganic Nitrogen
1.0 (Nov-Mar)
2.0 (May-June)
3.0 (Jul-Aug)
5.0 (Sept-Oct)
L -2

Treatm t Plant
0 1000ff.
Figure 41
Beaver Pond
Water Tank
Creeks & Rivers ...— .

pollution has caused changes in the number and kinds of invertebrates (e.g.,
insects) which occur along the stream bottom (which feed higher life foIii s
such as fish), and which are very typical of a river which has too much sewage
in it.
Efforts to improve the quality of the effluent had limited success for
several years. In 1980 EID negotiated an Assurance of Discontinuance with
TWSD which required compliance with state water quality regulations. TWSD
agreed to improve operation of the treatment plant, make substantial changes
in the plant design, and undertake water conservation measures within the
resort complex. As a result of’ these measures (and possibly because of
relatively low sewage flows caused by a poor ski season), the plant was in
compliance with existing effluent limitations during most of the winter of
1980—81. As a result, improvement of the river biology would be expected;
however, when EID visited, over—chlorination had resulted in virtual
elimination of all aquatic life in the reach of the river below the plant.
The long—term ability of the remodelled plant to corrply with the existing
effluent regulations is undetermined. Despite good performance during the
previous winter, TWSD violated effluent standards in the spring of 1981 due to
aerator malfunction. However, as stated in the facilities plan, the design
engineer believes that the facility can meet effluent standards at flows up to
or greater than 100,000 gallons per day. The engineer also concludes that the
plant would function more reliably if additional improvements are made or if
it is replaced with an entirely new facility (BLL, 1981). Resolution of the
infiltration problem is also a necessary prerequisite to optimum performance
of any facility operated in TWSD. TWSD has applied for and received a Step I
grant increase to study and control infiltration through replacement or
rehabilitation of the existing sewer system. It is anticipated that this work
will be completed by mid—1982, prior to operation of any new treatment
Assuming that the existing plant (or a new one of similar basic design)
could conform to the existing effluent standards, such a facility cannot
comply with all of the future effluent standards listed in Table 4—1. In
particular, the existing plant provides no removal of phosphorus, a nutrient
which causes nuisance conditions (excess algal growth) in the river.
Phosphorus removal will be a major requirement of the proposed effluent
In addition to pollution from the Twining treatment plant, water quality
In the upper Rio Hondo is adversely affected by non—point source (scattered)
pollution sources. Such sources include runoff from developed areas, erosion
of fertilized ski trails, and discharges from septic tanks and cesspools. As
a wastewater management agency, TWSD has responsibility to consider and
possibly control at least some of this pollution.
In summary , TWSD has improved considerably the performance of their
treatment plant. However, to provide for full wastewater management in the

upper Rio Hondo, and thus restore the river to an acceptable quality, there is
a need to take further actions. These actions Include: Improvements to make
the existing plant more efficient; upgrading of the facility to provide for
phosphorus removal; and possible control of non—point source pollution. The
significance of the pollution problem on the Rio Hondo is reflected by the
fact that TWSD is second on New Mexico’s priority list for receipt of
construction grant funding.
For additional information on water pollution refer to chapter 6.2., 6.4
and Appendix B. Section 6.2.2 reviews the stream standards, and the history
of water pollution In the upper Rio Hondo and evaluates the effects of
non—point source pollution. Section 6.4.1 summarizes biologic impacts of the
pollution. Appendix A discusses the existing regulations (part A.l), the
history and nature of the existing facilities (part A.3), effluent quality
from the plant (part A.3), and the history of management and enforcement (Part
A.4). Details on the future requirements for phosphorus removal are discussed
in the section on plant capacity alternatives (5.3).
Growth . TWSD intends that in upgrading the existing plant and providing
for phosphorus removal there should be sufficient capacity to provide
treatment of wastewater which would be generated by regulated and considered
growth of the District (Stagg, 1981). The District’s goal of a larger
facility Is not accepted by all area residents. In particular, groups
representing downstream residents are generally opposed to further growth of
the resort complex, and in particular oppose the construction of a larger
wastewater treatment plant which would facilitate such growth.
The growth issue is complex and is discussed throughout this document.
However, there are at least four major sub-Issues which relate to decisions
about the kind and size of any new facilities.
1. Protection of water quality is an unquestioned priority. In addition
to strict and. reliable conformance with the effluent limitations, any new
facilities must be evaluated in terms of how well they benefit (or harm) water
users throughout the Rio Hondo drainage.
2. Protection of water quantity is important, especially to downstream
residents who rely upon the Rio Hondo as a source of irrigation and/or
drinking water.
3. Theze is general interest throughout the region regarding the
relationship between the capacity of a treatment plant, development in
Twining, and impacts on the natural and soclo-economic envirornient of the area.
4. The cost of new facilities is of’ concern, both to government agencies
which may contribute funds toward the construction of the facilities and to
District land owners and residents who are certain to experience Increases in
already high sewer rates.

In summary, there is a clear need for some improvements in wastewater
management within TWSD, but different opinions exist as to the appropriate
size (capacity) of any new treatment facilities. The ‘best’ solution as to
plant size (as well as type of treatment process, location of plant, etc.)
depends upon many factors, especially water quality, water quantity, regional
environmental issues, and costs.
This limited discussion of issues will be expanded in the chapters which
follow. Chapter 7 reviews all the major issues which have been raised
regarding wastewater management in the Twining area.
The U.S. Environmental Protection Agency (EPA) determined that an
Environmental Impact Statement (EIS) was necessary regarding any proposed or
alternative wastewater facilities considered for Twining. The EPA decision
was announced in a Notice of Intent dated August 20, 1979 and published in the
Federal Register . The EIS has been prepared using the “piggyback” approach
whereby the impact evaluation for EPA was completed by Lee Wilson and
Associates, Inc., of Santa Fe, New Mexico, concurrently with preparation of
the facilities plan.
This EIS is intended to provide essential information regarding the
options available for treatment and reuse of wastewater, with particular
reference to the issues outlined above and discussed in Chapter 7. The
purpose of the information is to permit citizens and government officials to
make an informed choice among the available alternatives, so that the
decisions made will be of environmental benefit to the project area, the
Twining region, and the nation as a whole. In evaluating alternatives, the
technique of cost—effectiveness analysis is used. The analysis involves
comparing all alternatives in a logical, objective, and systematic manner in
order to identify relative merits and deficiencies. Where practical the
comparisons are quantitative, and In some cases they involve the use of
monetary values. The goal of the analysis is to identify the most
cost—effective alternative, which is the option that:
—achieves all requirements mandated by federal, state and local laws and
regulations, including environmental requirements; and
-does so with the minimum long-term cost to society; that Is, with the
most benefits and lowest attainable combination of dollar expenditures,
environmental sacrifices and social burdens.
While quantitative and monetary terms are used in the analysis, cost—
effectiveness is partly dependent upon qualitative considerations and sub-
jective judgments. Consequently, the results of the analysis are neither
absolute nor fixed.


This chapter describes and evaluates alternative plans for controlling
water pollution from the Twining Water and Sanitation District (TWSD). Alter-
natives considered by the District are presented in part A of the chapter.
Alternatives available to the Environmental Protection Agency (including
funding alternatives) are discussed in part B (see page 5—47). Decisions
which might be made by the U.S. Forest Service, New Mexico Environmental
Improvement Division and others are presented In part C (p. 5—48). In all
cases the evaluation focuses on key issues which bear on the selection of the
‘best’ (most cost—effective) alternative. Technical details on these Issues
are presented (as necessary) in chapter 6.
With the assistance of the Citizens Advisory Committee (CAC), TWSD eval-
uated a large number of alternatives for the collection and treatment of
wastewater within District boundaries. One general alternative, that of
taking no action, is discussed in section 5.1. Section 5.2 provides data on
treatment alternatives and considers treatment processes, plant sites and
potential wastewater reuse. Section 5.3 concerns the Issue of plant
capacity. Section 5.4 deals with the many other aspects of a wastewater
management plan: construction of sewers (5.4.1); use and management of’
on—site systems such as septic tanks (5.4.2); determination of the specific
plant site (5.4.3); sludge disposal and disinfection (5.4.4); energy conser-
vation (5.4.5); flow reduction — water conservation (5.4.6); control of
non—point source pollution (5.4.7); design of’ sewer rates (5.4.8); qualIty
assurance (5.4.9); and other administrative matters (5.4.10). 0? these
alternatives, the subjects of quality assurance (guarantees of reliability)
and rate design (equity; ability to generate sufficient funds) have received
the greatest public attention.
Section 5.5 sunmarizes the preliminary decisions which have been made by
TWSD and the CAC regarding the preferred alternatives. Supporting technical
data related to various alternatives are presented In Appendix B.
For reference purposes it Is useful to consider what would happen If Iwso
makes no Improvements to the existing wastewater management system. As stated
In chapter 4, the existing plant causes pollution of the Rio Hondo and viola-
tion of applicable standards. Failure to correct the problem could: 1) cause
continued pollution of and environmental harm to the Rio Hondo; 2) place the
District in jeopardy of’ enforcement actions, which could include large fines
and court-imposed remedial actions; and 3) possibly lead to a court—mandated
sewer hookup ban which could result in limits on growth within the District
(or, alternatively, lead to widespread, uncontrolled growth using septic tanks

and a proliferation of independent treatment plants). Collectively these
effects would have a large, adverse impact on District land owners and
downstream residents and would conflict with federal and state environmental
regulations. Consequently the no—action Alternative is unacceptable. At a
minimum, some actions must be taken to resolve the existing pollution problem
and bring TWSD into compliande with future effluent standards.
It should be noted that comments on the no—action alternative have no
bearing on the no—growth alternative (see ection 5.3.) or on the no—funding
alternative (see part B). Thus, for example, rejection of no—action does not
imply either that EPA must fund a TWSD plar* nor that TWSD must build a plant
which provides more capacity than needed by xisting development.
Alternatives for treating Twining’s sewage were developed to conform to
the mandatory objective of meeting stream standards in the Rio Hondo. The
main concern is that during low—flow perio Is the river cannot assimilate the
nutrients now being discharged; this caus s the stream to become “over—fer-
tilized”, resulting in adverse changes in the ecology of the river for several
miles below the plant.
Many approaches can be considered as a means of providing nutrient control
(along with conventional treatment). For example, consideration can be given
a. use of different t eatment processes, including ‘conventional’
approaches which requ e a lot of chemicals and energy, and ‘innova-
tive’ approaches which could be much more efficient, but which are
not fully proven;
b. use of different locations for a treatment plant, including Twining,
Valdez, Arroyo Hondo and Taos;
d. use of alternative discharge points, including the Rio Hondo, Rio
Grande, Rio Pueblo (below Taos), as well as non-discharge alter-
natives including several types of sewage recycling (for farming,
drinking, snowmaking).
Fifteen specific treatment alternatives were developed as part of the
facilities planning process. Many addit ional variations and alternatives were
discussed briefly at various public forUms but were not judged to be feasible
and are not discussed in this EIS. The fifteen alternatives were numbered
sequentially as they were proposed. Table 5—1 provides a sunmary description
of each alternative. Figure 5—1 illustrates how the alternatives are located
with relationship to the Rio Honda wafershed. The table and figure illustrate

tEls .s ottieruise noted for purposes of cc Varisam, data given ass e 95,0 i gpo plant (with enualizatlon basin to accept peak flows of l53,OC ) gpd), secondary treatment, and phosphorus r wal.
The existing treatment plant would be replaced by a new facility
which would use convent ional aeration processes for secondary
treatment with chemical additives for removal of phosphorus. The
specific proposal is for: 1. an entrance works to screen raw
sewage; 2. an equalization basin; 3. four extended aeration
cha ers , uncovered, usIng diffused air (only one would be needed
In suimter); 4. a settling clarifier, with fiber glass cover; 5. a
reector clarifier for coagulation (with lime) and flocculation,
with fiber glass cover; 6. dual-media pressure filters (using
anthracite and sand); 7. recarbonatlon using carbon dioxide to
lower the rh; 6 disinfection with ozone; 9. an aerated holding
tank for the lime sludge; 10. greenhouse-covered sand drying beds
for sludge. Items 6, 7 and B, will all be within a building.
Treated sewage would be discharged to the Rio Nendo.
A greerdiouse would cover a pond; the pond would simulate the
conditions found in the natural environment and would use natural
processes for treatment. Chemical tre itment for phosphorus rraoval
would still be necessary, as would ozone disinfection. The clean
water would be discharged to the Rio Hondo.
Replace the sewer lines and treatment plant with septic tanks.
Large tanks would serve lodges and condaminiams, smail tanks wouhi
be used for Taos Ski Valley, and cabins. The treated sewage (still
containing nutrients and same other impurities) would be discbaroed
to ground water throu tirainfields.
Each building or groop of buildings would be served by its own cam-
posting toilets for treating blackwater (toilet wastes). Compost
would be recycled. Gxeywater (kitchen, bath, laundry wastes) wo Jd
continue to be treated at the existing treatment plant (which would
be opgraded along the lines of Alternative 12, or perhaps less
extensively). The treated greywater would be discharged to the
Renovate the existing treatment plant, hut cáo not provide a process
for removing nutrients. Instead, use the sewage for snowmaking.
The snow will runoff in spring, when the river flow is greatest,
and the stream can absorb the nutrients without adverse impacts.
During sumner and fail, store the sewage In ponds and dischar e it
in amounts which are proportional to the stream flow.
advanced biochemical Complexity of plant is similar to that being
operated tcsiay. Bypassing or storage of raw
sewage would ta necessary during construction
of a new plant on the existing site.
advanced bIochemical Process is unproven; a small—scale pilot plant
would be essential prior to raking a cocasit—
ment to a full—scale operation. C tion may be
eligible for extra EPA funding and, if suc-
cessful, would be a model for other areas of
northern New Mexico.
Necessary to determine the best types of septic
tanks for use in twining and Study the effects
of discharges on ground water and the Rio
hondø. District would need to consider active
inanagenent of individual tanks. If another
alternative is selected, the more remote parts
of the District eight continue to use septic
Corrposting toilets can be used as part of other
alternatives. Existing buildIngs would need to
be extensively remodeled. District would
become legally responsible for the inspection
and maintenance of toilet in the
District. Laundry wastes may need special
handling, such as their own recycling unit.
standard dilution Many variations could be considered. lnitial
assiasption is that ponds would store 60—days of
sewage. bYould require special provisions in
M’DES permIt.
Alternative t(.at,er, Name Concept
plant i”;
discharge ‘
approach ! Cornents; Problems
I. New Plant
2. Aquacul tore
3. Septic tanks
4. Campostin toilets;
greywater recycling
5. Storage/discharge
discharge to
Rio Honda
discharge to
Rio Hon k
discharge to
simple soil
Twining; simple and biological
discharge to advanced
Rio Honch
discharge to
Rio Honda

TABLE 5-1.
Build a pipeline to the Arroyo Seco area and build 30 acres of
ponds. The ponds would be sealed to prevent leaks, all the sewage
would be evaporated. No water (or nutrients) would be discharged
to the Rio Hondo. The existing plant in Twining could be used to
provide some treatment of the sewage before it enters the pipe, to
reduce odor problems in the pipe and ponds.
Similar to 6, except that only 5 acres of ponds would be built, and
the p water would be put into Irrigation ditches during spring
and sima er, for use by the farmers in the Valder area. The
nutrients in the sewage would become a fertilizer to be reused in
the soils and crops of the valley.
Renovate the existing treatment plant; build a pipeline from
Twining to a point west of Arroyo Hondo; discharge the (nutrient—
rich) treated sewage into the Rio Grande, which has enough flow to
assimilate the sewage.
Ponds built in Twining would store raw or partially treated
sewage. Trucks (honey wagons) would haul the sewage to the Town of
Taos treatment plant. Discharges from the Taos plant occur just
above the Rio Grarwie, which bes enough flow to assimilate small
sits of nutrients.
Build a new regional treatment plant near Arroyc Honda, which would
discharge sewage to the Rio Grarxie. Twining would build a pipeline
to the new plant and be one of many potential users.
Similar to 10, except the pipeline would go through Arroyo Seco and
El Prado, and eventually to the Town of Taos treatment plant, which
wcijld be expanded.
The existing treatment plant would be rehabilitated to in rove its
performance, and phosphorus treatment would be added. Major
changes would include: 1. addition of covered equalization basins;
2. repair and covering of the existing aeration basin; 3. addition
of sludge removal in the existing clarIfier; 4. covering of
existing aerobic digester; 5. addition of sludge dewatering; 6.
addition of phosphorus reomval by chemical addition (lime) and sand
filters; 7. disinfection by ozone; and 8. general reconstruction of
the piping at the plant. Treated sewage would be discharged to the
Rio Hondo.
simple evaporation; Various locations for the ponds could be con-
landfill sidered. Ponds might provide aesthetic bene-
fits; e.g. wildlife refuge. Potential for
odors exists. No potential for agricultural
re—use exists.
See alternative 6. There would need to be a
legal arrangement between Twinino and the ditch
associations. The type and feasibility of such
an arranoement mist be studied. EPA is very
supportive of this type of alternative
wherever there is a problem with nutrients in
standard dilution It might be possible to discharge into the
Rio Hondo, a mile or two above the Rio
Grande, and save a few miles of pipe. Would
need BLM approval because the Rio Grarsie is a
wild and scenic river; potential exists for
conflict with recreational use at the Dunn
Bridge (e.g., odors, solids, algae).
standard dilution Ponds might be covered and put underneath pro-
proposed new parking lots. Potential for high
energy costs (gasoline) and traffic impacts
(safety, emissions, spills).
stanclarc dilution Costs in Appendix C are for Twininn portion of
facilities only. Different locations for a
plant could be considered.
standard dilution Costs in Appendix C are for Twining portion of
facilities only.
advanced biochemical Conpared to Alternative 1 the ‘add-on’ nature
of the plant would lead to a greater potential
for periodic breakdowns arC possible failures
to meet effluent standards. For ecaaple, it
would be less fle ibile In dealing with the
relative low flows experienced in sumner.
Some solution must be selected for taking care
of the sewage during the period when the
existing plant is being rehabilitated, and is
therefore out of service.
of plant
Alternative Ntsnber, Name Concept discharge
approach / Coasments; Problems
6. Total detention
7. Land application
8. Pipeline to Rio
9. Holding tanks
10. Hondo Valley plant
11. Taos regional plant
12. Rehabilitate exist-
ing plant
simple soil
discharge to
the air
discharge to
Arroyo Seco
& Valley
aischarge W
of Arroyo
discharge to
Rio Pueblo
Honda; W. of
Arroyo Hondo
Taos; dis-
charge to
Rio Pueblo
discharge to
Rio Honda

TABLE 5-1.
I .ocation
of plant !!
Alternative Mjr er , e Coocept discharge
approach g Consents; Problems
13. Total recycling Alternative 1 would be modified and coabined with additional
facilities to purify sewage to meet drinking—water standards.
There would be greater use of lime by the advarced plant, plus the
following additional steps: recarbometion (to adjust for the
greater use of’ lime), two granular carbon filters separated by
ozonation; reverse ossosis to remove salts; and final disinfection
by ultraviolet radiation. The entire water system of Twining would
be revme ,ed to eliminate bypassing of flows; tiwis, 100% of the
sewage w zild ge into the water system.
CoI!bines alternatives 4 and 6. Each building or grow of buildings
would be served by its own ccwa osting toilets for treating black—
water (toilet wastes). The coispost would be recycled. creV E r
‘t Ttaien, bath, laundry wastes) would be disposed of through a
pipeline to the Arroyo Sees area, and evaporation in about 18 acres
of ponds. The ponds would be sealed to prevent leaks; all the
sewage would be evaporated. Nu water (or nutrients) would be
discharged to the Rio Hordo. The existing plant in Twining could
be used to provide some treatment of the sewage before it enters
the pipe, to reduce odur problems in the pipe and ponds.
15. Aquaculture + Aq.Rculture (or any of the other alternatives) would be used in
conjtrttion with smoemaking in order to provide the treatment
benefits of the former and the water su.,ply benefits of the latter.
advarced biochemical Very difficult to isplenent under present EPA
- -. and Eli) regul tions.and policy. Ccaglexity of
this approach is such that for reliability
reasons it is banned in California. An
enviroreentally acceptable variation of this
alternative would be to discharge the
reclaimed water to the Rio Hondo. This
approach, ‘total treatment’, accowpllshes most
of the benefits of total recycling without the
i,mediate viral hazard.
simple and biological Couabines Alternatives 4 and 6; would require 18
advaneed evaporation acres of ponds.
advaneed biochemical Coobines Alternatives 2 and 5; 5 could be added
+ dilution to other alternatives as well
a. location of plant: site where the .ajor treatment of wastes tales place.
b. location of discharge: site where water leaves control of Sanitation District.
c. treatment teclielogy: advarted = tectiology which requires use of biological and chemical processes which are not in
c n use in New Nexico; standard tectulogy similar to that which now exists in Twining and Taos; sisple = techoology
Which is very besic, arri by itself not adequate to treat sewage to the quality deemeded by the standards.
d. nutrient r val a pro : biochemical rewoved by the treatment plant; soil nutrients removed as sewage passes
through soil (for land application, this lncltdes i.pt ce by crpps); evaporation = sewage is evaporated, nutrients
cortentrate in remaining water, add are never discharged; dilution nutrients are discharged to a river which has enough
flow to dilute the nutrients to relatively harmless levels.
14. Blackwater recycling;
total detention of
none -
discharge to
Arroyo Seco
discharge to
Rio Honda


that the alternatives take many different approaches to the control of
pollution in the Rio Hondo, in line with the concepts noted above.
Appendix B of this EIS contains Information of special Importance to
evaluation of the alternatives. Appendix 8.1 discusses an important change in
the treatment objectives which occured during the planning period, and which
altered the perspective on cost—effectiveness. Appendix 8.2 discusses the
role of equalization basins as a factor determining the relationship between
total sewage flow and actual plant capacity. Appendix B.3 provides cost data
on each of the fifteen alternatives. Additional technical Information Is
contained in the draft facilities plan.
The evaluation of the alternatives involved two major steps both of which
are documented in this EIS rather than in the facilities plan.
First, as described in section 5.2.1, all fifteen options were assessed In
a general way. Five were considered deserving of more detailed study.
Second, as described In section 5.2.2, the remaining five alternatives
(plus a revised version of one of the others) were then assessed In
somewhat greater detail.
In both steps the evaluation process involved the rating of the alternatives
according to various economic and environmental issues. Table 5—2 summarizes
the issues which were used in the ratings. These Issues were selected in
order to concentrate on major differences among the alternatives.
5.2.1 Initial Evaluation
Table 5—3 provides a brief description of each alternative and lists a few
of the strong and weak points of each option. The table also contains
generalized ratings or rankings for the alternatives according to their
performance with regard to eight of the issues. (Issues marked ** in Table
5—2 were not used.) Table 5—3 provides three rating categories: for each
issue a r trng of 1 was given for alternatives which had the least adverse
impact (best characteristics); a rating of 2 was assigned to those with
intermediate effects; and a rating of 3 was use to indicate alternatives with
the greatest adverse Impact. For example, the first rating in Table 5—3
reflects the cost of the alternatives. The number 3 is assigned to the most
expensive alternatives; 2 means an alternative is less expensive; and the
number 1 indicates a relatively low—cost option.
Briefly, the basis of the other seven ratings was as follows (see Table
Reliability: the best ratings Identify alternatives which would be
easiest to operate.
Water quality some alternatives may actually fail to meet the mandatory
pollution standards and are rated 3 (in this case indicating the

These issues were selected to focus on differences mtxng alternatives. Issues without an
Issues marked with ore asterisk (‘) were used to rate both the fifteen initial and six semi—final
the six semifinal alternatives only.
asterisk were used to evaluate the initial fifteen treatment alternatives
alternatives. A double asterisk (‘*) identifies issues used to rate
specitic Ratinas/Conments
20-year costs to construct and operate facility. See AppendIx 8.3
for actual cost data, assi .mi ,tjons. For Table 5—3, initial ratings
discussed at public meetings have been adjusted to reflect change in
treatment objectives, which are likely to mandate phosphorus but not
nitrogen removal (see Appendix B.l).
1= generally cost less than $150,000 per year
2= $150,000 — $300,000/year
3= cost more than $300,000/year
I.r act on Rates”
Reflects costs borne by TWSD, asstrilng that some of construction
costs and none of operations costs are paid by federal and state
grants. lepacts on rates increase with higher total costs and with
higher relative proportion of operational costs. (Thus If two
alternatives have similar dollar costs, but one has high energy costs
it has a greater inpact on rates.)
1= low total costs and low operational cost
2= low total costs and intermediate operational costs
3= low total costs and higher operational costs
4= high dollar costs and intermediate operational costs
5= high dollar costs and high operational costs
0= costs borne by Taos Ski Valley, Inc.
Based primarily t.pon the facilities plan engineers judgment as to the
level of effort needed to ensure contirued good performance of an
alternative. With increasing coeiplexity of operation there is sore
potential for operational failures, resulting in odors, water
pollution or other problems. In general any innovative alternative
has urproven aspects and is given a higher rating than conventional
alternatives. For Table 5—3, initial ratings discussed at public
meetings have been adjusted to reflect proposed deletion of nitrogen
treatment processes.
for 13 alternatives:
1= minimal complexity (single technology)
2= involve long pipelines with treated sewage; and/or intermediate technology
3= involve complex plant inherently difficult to operate; and/or involve long
pipeline with raw sewage (significant odor potential at punp stations)
for six semifinal alternatives:
1= most reliable of’ the five treatment alternatives
5= least reliable of the five treatment alternatives
(snowmaking is rated 2 because its ccrvlexity is judged similar to alt. 12)
Water l iality’
Based on Ingact to Rio Ibodo, primarily as measured by state Stream
Standards. Alternatives which minimize or avoid pollutant discharge
to the river are rated favorably as they go beyond re irement of
stream standards.
for 15 alternatives:
1 = no effluent qischarged to Rio 1 -bodo, thus no adverse ippact on stream iality
2 = meets stream standards
3 = may rot meet stream standards
Water Sipply *
Alternatives Which solve the pollution problee by eliminating all
discharges to the Rio Hondo are generally rated unfavorably. No
longer would this water be part of the flow of the river in the
Valdez—Arroyo H o areas. To conpensate for the loss of flow,
Twining would need to acopire water rights along the Horilo. This
would probably involve purchase and retirement of agricultural land.
Depending on the alternative, 30-50 acre—feet of water rights would
be needed. loss of water rights would affect the economy and
lifestyle of the. Ibrx Valley, as about 1% of the farmland along the
river would be retired.
Alternatives which involve recycling may benefit water st p1y and are
rated favorably.
for six semifinal alternatives:
l = least ingact on Rio Horsio of the five treatment alternatives
3 = most iuipact on Rio Hondo (standards will be met)
(see text for discussion of snoamaking)
for 15 alternatives:
1 involve recycling (turn wastewater from a liability to an asset)
2 = contir existing practices
3 = would reopire Twining to acopire water rights
(total detention, alternative 6, has greatest iirçiact since 100% of the
westewater would be evaporated and never put to beneficial use; other options
rated 3 — alternatives 8 to 11 — would allow people downstream — Pilar, Velarde,
Albuquerope, etc. - to eventually use the wastewater, even though the resource
would no longer be part of the water resources of the Hondo watershed.
Total Costs
for six semifinal alternatives: see text

1 59 1 COICEPT Specific Ratings/Coements
Downstream Land Use
Resort Expansion “
Comauiity Conflicts
Regional pipelines may permit high—density development In downstream
areas. See text.
Ability to provide long—term wastewater management in event that
growth occurs in Twining area. See text.
Reflects potential conflicts between Twining and those who live
downstream. Major conflicts could occur from alternatives which
involve a ponding area or treatment plant which is located downstream
(the relocation of sewage facilities almost always leads to some
controversy, e.g. due to odor potential). Similarly, pipelines
through downstream areas could pose special operational problems -
such as odors and leaks - which could lead to coaplaints from people
who live near the pipelines. Pipes which carry sewage which has
swiergons only minimal treatment would be of most concern. A special
problem would occur for alternatives which would re4jire downstream
people to join in a legal arrangement involving Twining; the
historical conflicts between Twining and downstream residents suggest
difficulty in establishing and i lementing such an arrangement.
Alternative 9 would pro e a great deal of road traffic, especially
in winter, which would be of concern to those using the Arroyo Seco
3 = could open downstream areas to urban development.
2 = no downstream ispact
1 = used for alternative 3 because it might tend to result in relatively
low—density development in Twining itself. In particular, this option (septic
tanks) would tend to cause a spread—out type of development, rather than
intensive use of the base area.
1 = most easily expanded of the five treatment alternatives
5 = least flexible if growth occurs (most likely to fail if expanded)
1 = may not cause any of these particular conflicts
2 = have one potential type of conflict
3 have the potential to cause two or more of these conflicts
Benefits to Region
Some alternatives may have benefits beyond solution of the sewage
problems of Twining. These may include: a) creation of a regional
sewer system (assuning that such a system is needed to protect ground
water cpality and poblic health, and i ioring adverse effects as
described tawier regional land use); b) use of wastewater ponds to
provide a regional recreation site; c) successful demonstration of
imovative ted iology, such as aggaculture, which might benefit
mountain co msdties throughout Northern Now Mexico.
1 provide regional sewer system
2 = provide other benefits
3 = no special regional benefits
Construction I acts’
Alternatives which involve major construction down the Ibndo Canyon
are likely to have much greater ispact than alternatives which put
all facilities in Twining. Putting a pipeline along the existing
road would have impacts such as: erosion; disrWtion of traffic;
noise. Right—of-ways (mostly from the Highway Department and the
Forest Service) would be required. Additional (but similar) impacts
would occur if the alternative also involves buildino of a new
treatment plant in a downstream area, or the construction of ponds
for the storage of sewage. Also, the land used would itself be taken
out of production forever.
for 15 alternatives:
1 = involve only construction within Twining
2 = require a pipeline, but no new plant
3 = involve a pipeline and a new treatment plant (or ponding
areas downstream)
for six semifinal altenatives: see text

ISSUES are identified by letter, as follows. A Cost. B Reliability. C Water quality. 0 = Water supply. E Construction impacts.
F Land use (growth). C Community conflict. H Benefits to region. See Table 5—2 for explanation of issues.
Brief description of
Build new plant in Twining using
advanced technolooy which needs
energy, chemicals
Build new plant in Twining using
new technology which grows algae
In ponds inside a greenhouse
Abandon the sewer system;
everyone uses septic tanks
4. Creywater/ Same sewage goes to existing
blackwater (renovated) plant; toilet wastes
to composting toilets
5. storage and store the winter sewage and dis—
discharge charge It In spring when river
can better assimilate nutrients
6. Total Pipe sewage to ponds near Arroyo
detention Seco and evaporate it
2 2 1 3 2 2 2 3 Pros: takes Twining sewage out of Rio Honda
Cons: water rights would be needed; major
construction impacts
1 2 1 3 1 2 2 3 Pros: simple, relatively inexpensive; eliminates
pollution in Rio F daO
Cons: uses energy; heavy truck traffic; water
rights would be needed
2 3 1 3 3 3 3 1 Pros: eliminates pollution in Rio fEndo; could
provide sewers for øownstteafl’ residents
Cons: major land use changes could occur in Hon ,1,
Valley; major construction impacts; water rights
would be needed
2 3 1 3 2 3 3 1 Pros: takes Twining sewage out of Rio f ndo; could
provide sewers for ArrOyc Seco—El Prado area
Cons: major land use changes could occur near
Taos; major construction impacts; water rights
would be needed
1 3 2 2 1 2 1 3 Pros: ‘conventional”; relatively inexensive
Cons: reliability Is guestlonable
3 3 1 2 1 2 1 3 Pros: takes Twining sewage out of Rio Hondo,
without adverse effects on flows
Cons: extensive energy and chemical use; very
expensive; aaainst federal, state regulations
3 3 1 3 3 2 2 2 Pros: simple; takeS Twining sewage out of Rio Hondo
Cons: expensive; reliability uncertain; wasteful
of water; wat!r rights would be needed
2 2 3 1 1 2 1 2 Pros: progressive in use of resources; would
Increase spring and sunewr runoff
Cons: same questions about reliability; may not solve
pollution problems
= less inraCt west rating); 2 = intermeaiate impact; I = note ICPdCL.
Name of
I. conventional
new plant
2. Aouaculture
• Septic tanks
Pros = reasons
alternative. Cons
to reject an altern tlve.
lead some
‘conventional” approach
2 2
1 2 2 2 1 2 1 2 Pros:
1 1 3 2 1 1 1 3 Pros:
very progressive in its use of resources;
comparatively Inexpensive
too new an Idea to know how well it will work
conventiona1” approach; inexpensive;
will not solve the pollution problem
2 3 2 2 1 2 1 3 Pros: very progressive In its use of resources
Cons: expensive; reliability uncertain
1 2 3 1 1 2 1 3 Pros: may improve downstream water supplies in
terms of ojantity; inexpensive
Cons: may not solve pollution problem
3 1 1 3 3 2 2 2 Pros: simple; takes Twining sewage out of Rio Hondo
Cons: expensive; wasteful of water; water rir ’ht
would be needed
2 2 2 1 3 2 3 2 Pros: supports farming; not too expensive
Cons: reoulres agreement of farmers, and some type
of legal arrangement with Twining
7. Lana
8. Pipeline to
Rio Grande
10. Regional
plant in
Honda Valley
11. RegIonal
plant in
13. Total
t reatinant
Pipe sewage to ponds near Arroyo
Seco and let farmers use it for
Renovate existing Twining plant;
build pipeline to Rio Grande
(west of Arroyo Horido) aria
discharge sewage there
Store sewage in ponds in Twining
and use trucks to haul it to tie
Town of Taos sewage plant
Pipe sewage to a new regional
sewage plant near Arroyo Honda
Pipe sewage to Town of Taos
sewage plant
Renovate existing plant and add on
advanceo processes for nutrient removal
Build very complex plant in Twining
which would turn sewage Into drinking
water for use by Twining
14. Greywater Combine alternatives 4 and 6: compost
evaporation toilets, greywater evaporation
15. usculture
Combine alternatives 2 and 5

alternative should be rejected); others would clean up the Rio Hondo
beyond the standards and are rated 1. A rating of 2 indicates standards
would be met.
Water supply: alternatives rated 3 would require the retirement of
irrigated lands and the transfer of’ as much as 50 acre—feet/year water
rights; those rated 1 provide special wastewater recycling benefits.
Construction impacts: adverse (higher) ratings oocur for alternatives
involving major construction outside of the Twining area (such as con-
struction of a pipeline through the Hondo Valley and/or construction of’
treatment facilities in the Arroyo Seco area).
Land—use impacts: a rating of 3 is assigned to alternatives which could
lead to urban-level growth in rural areas — along the lower Rio Hondo
(alternative 10) or along the Arroyo Seco highway (alternative 11).
Community conflicts: a rating of’ 3 or 2 (high potential for conflict) is
given if the Sanitation District would have facilities in downstream areas.
Regional benefits: the best ratings (1) reflect alternatives which could
benefit citizens other than those living in TWSD.
The implications of Table 5—3 can be summarized by grouping the alterna-
tives into four categories: use of on—site systems; conventional plants;
innovative alternatives; and regional solutions.
On—Site Systems would treat Twining wastewater without the need to use a
central treatment plant. Alternative 3 (Table 5—1) is the main example of
such an option. This option would use septic tanks and drainfields for
wastewater discharge, a practice which normally accomplishes extensive
phosphorus removal. However, Table 5—3 shows a water-quality rating of’ 3
(unacceptable) for this alternative. The rating reflects soil conditions in
Twining which are not conducive to phosphorus retention and evidence that
on—site systems contribute significantly to pollution of’ the Rio Hondo.
Widespread use of septic tanks in TWSD probably would lead to violation of
stream standards for phosphorus (and perhaps other parameters such as
Rejection of alternative 3 does not preclude limited use of on—site
systems such as septic tanks, as for exarçle in remote parts of’ the District
where construction of’ sewers would be especially difficult.
Alternatives 4, 9 and 14 involve some use of’ on—site systems. However
their primary emphasis is on innovative technology (4, 14) or regional
disposal (9); they are discussed subsequently.
Conventional alternatives would provide standard secondary treatment and
phosphorus control at a facility in the Twining area; treated effluent would
be discharged to the Rio Hondo. As illustrated in Table 5—1 they approach the
nutrient control problem through biochemical treatment processes and

dilution. The two choices involve rehabilitation of the existing plant
(alternative 12) or construction of an entirely new conventional facility
(alternative 1). As suggested in Table 5—3, these approaches generally have
less adverse effects than many other alternatives. Factors which are less
beneficial than from some other options include: complexity (which could
adversely affect reliability); high operational costs (especially for energy);
and the fact that there would still be some effluent discharged to the Rio
Hondo (that is, there would not be a 100% clean—up of the river).
Innovative alternatives all involve some unusual approach to wastewater
management through special facilities built in the Twining area. These
approaches are of three types. First, there are two alternatives which would
take care of toilet wastes through the use of composting toilets . These are
alternatives 4 (which would treat non—toilet wastes in a conventional plant)
and 14 (which would evaporate the non-toilet wastes). Second, two alterna-
tives involve special treatment and recycling of the wastewater. These
options are alternative 5 (which uses wastewater for snowmaking) and 13 (total
treatment of sewage to produce drinking water). Third, there are two aqua—
culture alternatives which would treat sewage by usinç it to grow algae in
solar—heated ponds. These are alternatives 2 and 15 (the latter is number 2
with a snowmaking option added on).
In Table 5—3 the innovative options generally have a poor rating for
reliability because of uncertainty as to whether or not they will work as
intended. This is of special concern considering the long history of
pollution in the Rio Hondo and the interests of all concerned to see the river
protected. Also, some of the innovative alternatives are quite expensive. A
special problem of alternatives 5 and 15 is that snowmaking does not neces-
sarily provide any phosphorus removal and may not meet the water quality
mandate faced by Twining. This is reflected by a water—quality rating of
Regional alternatives would solve Twining’s problems by using wastewater
facilities in other areas of Taos County. Nutrients would not be removed from
the sewage, but rather the nutrient—rich wastewater would be discharged to a
river which has enough flow to assimilate the nutrients without becoming
overb’rdened with algae.
There are four alternatives which involve ‘ export ’ of the sewage to the
Rio Grande or to Taos. Three of these involve big pipelines. Alternative 8
would pipe all of Twining’s treated sewage along the Hondo Valley and
discharge it directly to the Rio Grande. Alternative 10 would build a
regional sewage plant in Arroyo Hondo to serve both Twining and other
communities in the area. Alternative 11 would pipe Twlningts sewage to the
Town of Taos treatment plant, west of Ranchitos. Alternative 9 would not use
a pipeline; instead, trucks would take sewage from Twining to the Town of Taos
tre tmen plant.
two regional alternatives would dispose of the wastewater in the Valdez—
Arroyo Seco area . Alternative 6 would evaporate the sewage in ponds built

near Arroyo Seco, Alternative 7 would provide treated wastewater to farmers
in the Valdez area.
The ratings in Table 5—.3 highlight three major drawbacks to the regional
alternatives. First, these choices are generally expensIve, even when com-
pared to some of the innovative alternatives. Second, except for the land
application option (7) they all would reduce stream flows in the Rio Hondo
because the treated effluent would no longer be part of the river water.
Under New Mexico law, IWSO would have to obtain and retire irrigated lands
along the lower Rio Hondo in order to offset the change in flow; this impact
at the scale required produced a very negative response from the public.
Third, all of the regional options have the effect of’ bringing TWSD’s
wastewater management problems out of the mountains and into the settled part
of the Taos Region.
In addition, alternatives 10 and 11 would open up the possibility that
sewers would be available in downstream areas. The availability of sewers
could have a profound effect . on land use. In genelal, the key to control—
ling land use is zoning, and/or subdivision regulations. Where such controls
are strong, the availability or sewers does not necessarily change land use.
where zoning is not strong (as is the case in Taos County at present) sewers
allow high—density residential and commercial development which otherwise
would occur to a much more limited extent. Put another way, high—density
development is difficult to accomplish using septic tanks, out easier to do
once sewers are in, Sewers do not force a community to accept a high—density
type of development. But they do allow such deveiopmeni. to occur, unless
there are strong zoning controls.
Residents of Taos County are familiar with this problem through the
history of a high—density condominium development between Taos and Arroyo
Seco, known as the Tennis Ranch. This project had significant problems
obtaining state approval of its self-contained sewage system. Such problems
would be expected to have an impact on future developments of the same type —
an obstacle which could increase the costs of development significantly. With
a sewer line in place down the Honda Valley or along the Arroyo Seco highway,
such problems virtually disappear, and sewage disposal would no longer be an
obstacle to development. Unless a strong county zoning policy were adopted,
the sewer line could change development patterns in the Taos area. One result
would be a change of’ land from rural to urban use, and a loss of the agrarian
lifestyle of the affected area.
After the implications of the regional alternatives were discussed at
public meetings, citizen testimony strongly and consistently opposed all such
Screening of Alternatives . The ratings given in Table 5—3 allow ten of
the alternatives to be screened out.
Alternatives 3, 5 and 15 have unacceptable water quality effects and must
be rejected.

The principals of cost—effectiveness analysis explained on p. 4-6 rule out
any of the very expensive options which have no major compensating bene-
fits. This leads to rejection of alternatives 6 and 14; alternative 13 is
not immediately ruled out because of its special water quality benefits.
Four of’ the regional alternatives received no public support and extensive
public criticism because of water rights impacts, potential for community
conflict and in some cases, potential effects on land use. All are
expensive, have no benefits sufficient to make them cost—effective, and
were screened out as a direct result of the public participation process.
The alternatives are: 8 (pipeline to Rio Grande); 9 (holding tanks); 10
(Hondo Valley regional plant); and 11 (use of Taos regional plant).
Alternative 7 has more benefits and less adverse impacts than the other
regional alternatives. However its success requires cooperation between
TWSD and downstream farmers on a day to day basis; this cannot be
assured. Citizen opposition to this alternative indicates it cannot be
implemented effectively and should be screened out.
One implication of’ the initial screening was to emphasize the importance
of water supply as a key public issue. Although all citizens desire the Rio
Hondo to be as clean as possible, public input generally supported continued
discharge of’ treated wastewater to the Rio Honda rather than alternatives
which would put the wastewater elsewhere and which would require retirement of
water rights.
5.2.2 Follow—up Evaluation
Based on the initial screening, five alternatives remained for further
consideration. For purposes of evaluation, the alternatives can be grouped
into two categories.
Conventional Alternatives : either a new treatment plant (alternative 1)
or rehabilitation of’ the existing plant (alternative 12). In both cases
treatment would involve secondary treatment plus phosphorus removal.
Innovative Alternatives : aquaculture plus phosphorus removal (alternative
2); or composting toilets and conventional treatment of kitchen/bath water
(alternative 4); or total treatment to produce and recycle or discharge
drinking water (alternative 13).
In addition, one of the rejected alternatives was revised and reconsidered.
Mdd—On Alternative : use treated wastewater for purposes of snowmaking.
This differs from initial alternatives 5 and 15 in that snowmaking is not
considered as a treatment method, but as a means of wastewater disposal!
recycling that would be added on to one of the above alternatives. It can
be labeled alternative i SA.

In the public participation process these six options were termed the
‘semifinal’ alternatives (see chapter 7 for discussion of this process). Six
of the issues listed in Table 5—2 (those marked * or **) were used to evaluate
the semifinal alternatives. These issues are: impacts on rates; reliability;
impacts on water quality; impacts on water supply; construction impacts; and
potential for expansion. The results of the ratings are given in Table 5—4;
the table also highlights the major pros and cons of each alternative and
provides data on the dollar costs of the alternatives. The rating system was
similar to that used in the initial evaluation, except that the numbers
extended from 1 to 5 (5 = worst). The basis for the ratings on each of the
six issues is explained below.
Rates . The dollar costs of the alternatives will have a direct impact on
land owners, residents and visitors in TWSD. In general, the rankings given
in Table 5—4 parallel total annual dollar costs: the most expensive
alternatives have the greatest impact on rates. In the special case of
snowmaking, it is presumed that the ski corporation would pay all of the
District’s share of costs for this alternative through some sort of
contractual relationship; the rating of 0 reflects the fact that the costs of
snowmaking should not show up in District rates.
Reliability . As in Table 5—3, ratings reflect comp3exity of operation.
Total treatment is banned in California because of concerns over reliability;
a rating of 5 is warranted. Maintaining composting toilets throughout the
District is a special headache of the greywater alternative; hence, the rating
of 4. The rating of 3 for aquaculture reflects the risks inherent in under-
taking any innovative alternative. Alternative 12 is considered slightly less
reliable (less flexible) than alternative 1 because the former must make use
of existing facilities which are not in optimum condition. This is a special
liability because of the substantial fluctuation of inflows; for example,
alternative 12 could experience operational problems during low—flow (summer)
Water quality . The five treatment alternatives all meet the mandatory
requirement to protect the Rio Honda against pollution. Variations in ratings
regarding water quality reflect relatively small differences in the amount of
water clean—up beyond the stream standards. Three of the alternatives (1, 12,
15) would exactly conform to standards and are rated 3. (However, it is
possible that alternatives 1 and 15 would perform better than alternative
12.) Alternative 13 is ranked as the best of the choices (rating = 1) because
it would completely eliminate all pollutant discharges to the Rio Hondo. The
composting toilets/greywater alternative also goes beyond stream standards
(although less so than alternative 13). This approach eliminates water—borne
toilet wastes from the discharge to the river; only kitchen, bath and laundry
wastes remain to be treated and discharged. The water—quality aspects of
snowmaking are complex and are examined in section 6.2.6. The analysis
indicates that this alternative would probably cause violations of the stream
standards; therefore it is rated 5.

Total annual cost sian of construction (mortgage) and operating costs for a 95,0(X) god plant (maximian allowed by regulations), in 1980 dollars. (In
parentheses are costs for an 80,OcXJ god plant, which Is just large enough to accomodete existing development). Iscue are identified by letter, as
follows: A = Rates; B = Reliability; C = Water ouality; 0 = Water sr ply; E = Construction impacts; F Expansion potential. See Table 5—2 for
explanation of issues.
Niarber and Total Ratings on ISSUES “ alternative. Pros = reasons which sight lead to selec-
name of Brief description of Annual tion of an alternative. Cons = reasons which eight
alternative alternative Cost . / A B C P E F lead to rejection of an alternative.
Pros: “conventional” approach; cost reliable
i Conventional Build new plant In Twining using $175,360 3 1 3 3 1
($155,324) Cons: core expensive than #12
rew plant advanced technology
Other: preferred by engineer
energy, chemicals
relatively Inexpensive
12. Rehabil-. Renovate existing plant and add on $133,846 2 2 3 3 2 5 Pros: “conventional”;
($120,867) Cons: reliability is less than S new plant
itation advanced processes for phosphorus
Other: salvages some of the past investment
1 3 3 1 3 Pros: progressive I c use of resources; least icr-
Aquaculture Build new plant in Twining using $108,172
new technology which grows algae ($98,748) pact on user charges
in ponds inside a greenhouse Cons: reliability and ‘energy efficiency’ are un-
Other: possibly could be demonstration plant for area
1 . Compost Scare sewage goes to existing $254,967 5 4 2 1 5 2 Pros: progressive in its use
toilets/ (renovated) plant; toilet wastes ($192,200) Cons: expensive; reliability uncertain
Other: might not gain EPA approval
greywater to special systems capable
treatment recycling
Rio without
13. Total Build very complex plant in Twining $338,195 5 5 1 3 1 1 c! Pros: eliminates sewage
recycling which would turn sewage into drink— ($270,833) adverse effects an flos
ing—quality water Cons: extensive energy er’d chemical use; very expen-
sive; reliability is very nuestionable
Other: very unlikely to gain EPA or ElD approval
($40,526) Cons: adverse impacts on wster ruality
Other: can occur usino river water
- ...
a. mites ndt include engineering costs, iegai cees, contingencies, sewer rensoijiltetion, or exlstlnq oeor
b. The alternatives are each rated from I (least impact, best rating) to 5 (cost incOact, worst rating) with reference to six basic issues.
c. Rating assumes dlscharOe of effluent to Rio Hondo, not recycling to water system.

Water supply . In general, the alternatives have little direct effect on
flow in the Rio Hondo; that is, effluent would continue to be discharged to
the river and would be used as an irrigation water supply downstream. An
exception is alternative 4 — the composting toilet/greywater option — which
would reduce water use in Twining. A rating of 1 is justified for this
alternative. The water—supply effects of total recycling and snowmaking are
relatively complex and are analyzed in section 6.2.6. Despite the fact that
recycling occurs, alternative 13 has no special water—supply benefits and is
rated the same as most other alternatives, 3. The net effects of snowmaking
are aciverse due especially to the increased consumption of water; the
alternative is rated 4.
Construction impacts . Alternatives involving an entirely new treatment
plant would have local but not widespread effects and are rated 1 (alter-
natives 1,2, 13). Rehabilitation (alternative 12) would require a shut—down
of the existing plant for prolonged periods, raising the problem of what to do
with sewage in the meantime. Probably some type of trucking would be used,
resulting in traffic impacts along the road to Taos. This option is iated 2.
Even more impacts occur with alternative 4, because of the need to remodel
every building in the District to install composting toilets. It deserves a
rating of 5. snowmaking would involve construction within the ski area, and,
thus, would have impacts beyond those at the plant site. It is given a rating
of 3.
Expansion Potential . The desirability of growth in TWSD is discussed in
section 5.3. It is possible that within several years there will be proposals
to expand any plant built today. Not all the semifinal alternatives would be
equally easy to expand; for some options expansion would significantly
increase problems of reliability and therefore increase the risk of river
pollution. To reflect this issue each alternative was rated as to its
expansion potential. In this context ease of expansion is considered a
positive attribute because a flexible design would help protect the Rio Hondo
if and when growth occurs; this rating does not consider whether growth itself
is good or bad.
Total recycling (or more accurately, total treatment and discharge)
produces such a clean effluent that it can meet stream standards even if flows
approach 1 million gallons per day; it thus provides a virtually unlimited
potential to absorb growth and is rated 1. At the other end of the spectrum
is rehabilitation of the existing plant, which produces a relatively ineffi-
cient system which might be overwhelmed if expanded; thus alternative 12 is
rated 5. The remaining alternatives are generally similar in expansion
potential and can be distinguished on the basis of small differences in the
efficiency of phosphorus treatment (more efficient treatment facilitates
Overall evaluation , Snowmaking as an add—on alternative is probably
unacceptable (at least at a large scale) because of’ water—quality impacts.
Aquaculture is by far the cheapest of the three innovative options; the others

are probably too expensive to be considered cost—effective). (However, use of
composting, dry toilets, or other low—flush toilets can be considered as d
water-conservation technique for new development; see section 5.4.6). The
major problem with aquaculture is that it is an unproven technoloqy fu:
solving problems of the type faced by TWSD.
Either of the conventional alternatives could prove to be the most
cost—effective. Although a new conventional plant is more expensive than
rehabilitating the existing plant, a new plant is considered by the facilities
planning engineer to be a more reliable choice.
Based on the available information the choice lies among three
alternatives: These can be listed in the following way:
Least Expensive (in order) Most Reliable (in order )
1. Aquaculture 1. New Conventional Plant.
2. Rehabilitation 2. Rehabilitation
3. New Conventional Plant 3. Aquaculture
This comparison shows that a major basis for selecting among the options would
be the ‘value’ of spending money for reliability. Public input during tue
planning process has stressed the importance of reliability, operational
flexibility, adaptability and related factors and the irrportance of minimizing
the risks of plant failure and consequent pollution of the Rio Hondo. On the
basis of’ this public input (which reflects the history of problems at the
existing plant), a completely new facility (alternative 1) could be considered
the most cost—effective choice.
However, the cost savings of rehabilitation (alternative 12) are
substantial and this alternative is considered reliable (but less flexible oi
adaptable than alternative 1). TTe reliability is sufficient to meet NPDES
standards; but sustained performance well below standards is less likely than
for alternative 1. If straight economic considerations take precedence,
alternative 12 would be the most cost—effective choice.
The innovative nature of aquaculture (alternative 2) would certainly
increase the risks of failure to well beyond those expected from the two
conventional plans; on the basis of’ public input these risks would be
unacceptable and the alternative would be judged as not the most
cost—effective. Successful operation of a pilot plant could alter this

Substantial controversy exists over the appropriate size for wastewater
facilities in Twining. The controversy arises primarily out of three basic
issues: 1) the prospect that a larger treatment plant will facilitate growth
of the ski valley resort complex; 2) disagreement as to whether or not such
growth has a net beneficial or adverse impact on the human environment; and 3)
concern that growth is inappropriate unless and until water pollution problems
are solved. These issues are discussed as follows: section 5.3.1 summarizes
alternative population projections for TWSD and identifies the treatment plant
capacity needed to accommodate each projection; section 5.3.2 considers any
limits to the development which can occur as a matter of law; section 5.3.3
discusses the policy elements of growth management; and section 5.3.4
evaluates the two major alternatives under consideration — a plant capacity
which would minimize growth versus one which would allow new high-density
development. Two related subjects of major public interest are the timing of’
any capacity increase (see section 5.4.8) and possible EPA funding of
particular capacity alternatives (see part B of this chapter).
5.3.1 Relationship Between Plant Size and Development iii Twining
Existing Development . Section 6.6.1 discusses existing development in the
area. As is typical of a winter resort, the population of TWSD varies greatly
over time, reaching a peak on holiday weekends when snow conditions are good.
These peak populations determine the necessary size of wastewater treatment
plants and many other facilities.
The existing peak population of TWSD is as follows.
Skiers Visitors Employees/Residents Total Population
Day Only 3000 300 200 3500
Night 1050 40 135 1225
Total 4050 340 335 4725
It should be noted that one of the large condominiums and most of the cabins
are not hooked up to the existing sewage system, so that not all these people
contribute to the flows at the existing treatment plant. Also, the limit of
4050 skiers reflects an interim limit on lift ticket sales and is less than
the historic peak of’ 4400 reached in .1980.
Projected Development . Section 6.6.3 presents alternative projections of
the future population in TWSD. There are four major types of growth which may
ircrease the existing peak population. 1) Taos Ski Valley, Inc. wants to
increase maximum sale of lift tickets from 4050 to 4800/day. 2) Existing
lodge and condo owners would like to expand their operations by an average of
25 percent. 3) Many owners uf vacant land have talked about possible new
lodges or condos, encompassing a total of several hundred new units. 4)
Cabins are likely to be built on a large number of’ lots which have been
subdivided for that purpose.

The actual increase in peak population is difficult to predict because
there is no land use or other formal plan for TWSD development. For reference
purposes, several alternative population projections have been established,
These forecasts include: the existing population; a ‘maximum’ populat o
which assumes all announced plans become reality; and several intermediate
levels, including one favored by TWSD.
Existing District Goal ‘ Maximum ’
Skiers 4050 4800 4800
Non—skiing visitors 342 350 300
Employees 333 460 560
Total peak—day population 4725 5610 5660
Overnight Capacity 1225 2625 3550
The projections are explained in able 6-7 and associated text. The projec-
tions indicate that the maximum day population would increase by a small
amount, in comparison to a much larger increase in the proportion of that
population which stays in TWSD overnight. (The ‘maximum’ projection includes
no development on the two largest parcels of vacant land within TWSD.)
The plans to set a lift ticket limit of 4800/day are discussed in the Taos
Ski Valley, Inc., master plan (Fiance, 1980); this document also presents
plans to improve parking facilities, ski lifts and trails. A separate Envi-
ronmental Impact Statement (USFS, 1981a and l9Slb) considers these subjects
anc thus is limited to facilities which relate directly to skier use of the
area. In contrast, this Draft EIS covers actions which relate to upgrading
wastewater treatment facilities in TWSD and therefore addresses impacts
related to development which may occur on private land.
Alternative Plant Sizes . Table 5—5 identifies seven alternative plant
capacities. The alternatives reflect two different reasons for plant
expansion: development of new ski and/or overnight facilities; hookups to
existing high—density and/or projected low—density development. In the
discussions which follow, two of’ these alternatives will be emphasized.
Alternative B , a plant of 80,000 gpd, is the smallest facility which would
effectively accommodate existing development; it provides no hookups for
£xpc1n ion of resort facility. Alternative E , 95,000 gpd, Is the largest
capacity whic1 could be implemented at this time. As Table 5—5 indicates,
alternative E would allow somewhat less growth than the ‘District Coal’
(alternative F).
As discussed subsequently (5.3.2; 5.3.3) treatment plant expansion is not
necessarily a critical factor controlling the probable environmental impacts
from growth of the resort complex, especially if that growth Is no more than
the District goal.
..2 Absolute Limits to Growth
There are three potential barriers which might set an absolute limit to
a ’elooment in Twining: economic, physical and legal.

Based on Table 6—7. Total population equals ticket sales + non—skier visitors +
employees. All gallon figures rounded off to nearest 5,00(1. See footnotes for
explanation of assumptions. OSS on—site systems .
Ticket Total 0ve T TSt Capacity
Alternative; Hookups Sales Population Capacity gal./day
A Existing hookups only; no high— 4050 4725 1225 70,000
density growth; cabins use OSS
B Extend hookups to Kandahar and 4050 4725 1225 80,000
5 cabins; no high—density growth;
most cabins use 055
C Existing hookups plus skier limit 4800 5550 1695 80,000
raised; no major new overnight
facilities; most cabins use 055
0 Extend hookups to Kandahar, 5 4800 5550 1695 85,000
cabins; skier limit raised; no
major new overnight facilities;
most cabins use 055
E Similar to 0 but some expansion 4800 - 5580 2185 95,000
of overnight facilities
F Similar to E Out even more over— 4800 5610 2625 105,000
night facilities; ‘District Goal
C ‘Maximum’ development; all cabins 4 O0 5660 3550 150,000
hooked up; actual growth could
exceed this amount if all vacant
land is developed
Many assumptions must be made in order to convert a population number into a
treatment plant capacity; see Table 6—7 for major assumptions made in this EIS. The
most important factors are: for existing facilities day visitors are assumed to
contribute a sewage flow of 10 gallons per day while Overnight visitors/residents
contribute 50 gallons per day; far new facilities these values are assumed to be 33
percent less due to the use of water conservation measures such as no—flow toilets;
it is assumed that the existing infiltration problem will be solved prior to
completion of any new treatment facilities; hookup policies vary as indicated in the
table; and it is assumed that peak weekend flows would be stored in equalization
basins and tta plant designed to accommodate the average flows far the busiest week
of the winter season.
a. 715 persons in cabins (Including 460 new pillows) would be served by OSS for
alternatives A_F; these people would be served by the central treatment plant for
alternative 0.

Economic Constraints . Land prices in Twining are among the highest in New
Mexico, demonstrating that there are strong economic forces for the expansion
of the resort (see 6.6.1). In recent years actual construction of high—
density lodges and condominiums has stopped because of TWSD’s moratorium on
sewer hookups and the desire of developers to postpone construction until
reasonably priced hookups become available. However, in 1980 some developers
announced their intention to construct condominiums without waiting for new
hookups; these builders propose to independently install and operate small
wastewater treatment plants of extremely advanced design, capable of producing
nearly pure water. These facilities would be similar to those discussed for
treatment alternative 13 (see section 5.2).
The cost of building independent facilities is high, perhaps $10,000 per
condominium unit (Wilson, 1981). However, this represents about five percent
of’ the selling price of the units and in itself is not considered to be a
constraint on development. Clearly there may be a saturation point beyond
which the economic benefits of further development (I.e. the price at which
units can be sold) will not warrant expenses of this magnitude. This satura-
tion point cannot now be identified; persons familiar with the area believe
that growth to at least the amount indicated by the District’s desired popula-
tion is economically feasible (Wilson, 1981).
Physical Limits . Factors such as soils and terrain will influence the
location and character of development in Twining. However, there is ample
vacant, buildable land within the District to accommodate even the largest of
the population projections (see section 6.6.2). Many area residents believe
that growth of the resort complex is limited by physical changes downstream of
Twining. These changes reflect considerations of growth policies (see section
5.3.3) rather than any specific physical threshold or regulatory mandate.
Legal Barriers . County land use regulations and zoning laws would provide
a firm legal basfs for managing development and (If appropriate) limiting
growth in Twining. While some county planning has been done, there is no time
frame for adoption of land use regulations. The rules which do exist — such
as for subdivisions — either do not address commercial development or can be
complied with readily if project engineering is adequate. Similarly, state
water—rights laws can be met if economic incentives are sufficient. That is,
purchase of water rights on the open market and transfer of the rights from
downstream Irrigation to upstream domestic use is practicable where the value
of’ the newly developed land is high. Public opposition to such transfer Is
common in Taos County, but based on precedent the transfers are normally
approved unless there are unusual hydrological or legal conditions.
The wastewater management. authority of TWSD is substantial and the Dis-
trict could at least partially limit development by using Its powers to allow
(or disapprove) hookups and independent treatment plants. These powers can be
exercised for ‘health and sanitary purposes’, but have never been subject to
judicial review in New Mexico (Rubin, 1981). Given economic Incentives for
development In Twining, it is possible that persons affected by any TWSD
policy against new hookups and independent plants would Institute litigation

to determine if’ the District’s policy was within their powers. One possible
policy which might fit the requirements of’ ‘health and sanitary purposes’ is
discussed in section .5.4.9, sub—section on hookup policy.
At this time District policy is to exercise its authority only as neces-
sary to meet state or federal water—quality regulations. The current
moratorium on hookups was imposed for that reason. The policy of the District
toward new development is as follows (Stagg, 1981):
— TWSD will not interfere with private property rights to develop land
except as necessary to comply with water—quality regulations;
— TWSD will encourage new development to hookup to the central treatment
plant so long as capacity is available and standards will not be exceeded;
— TWSD will consider short—term limitations on hookups during periods in
which plant performance and standards compliance are being verified;
— As these interim limitations are periodically raised, TWSD will
allocate new hookups on a priority basis (see Section 5.4.9 for
- TWSD will attempt to provide at least the capacity associated with the
‘District Goal’ population (105,000 gpd), but will discourage growth
beyond that point;
- TWSD will not resist independent treatment plants, provided that all
regulations can be met and there is no hookup capacity available at the
central plant.
A key factor in the aii ount of growth is the relationship between
development and water—quality standards. Stream standards are the basis of
establishing the maximum amount of pollution (effluent limitations) which may
be discharged to the Rio Hondo (Table 4-1). As growth increases, the amount
of raw sewage increases; there is a lIii it to the extent to which treatment can
clean up the raw sewage. Eventually growth must stop or there will be too
much contamination of the river and the standards will be violated.
The history of problems at the existing facilities may suggest that the
contaminant limit has been reached already. However, the analysis of the
facilities planning engineer is that these problems result from inadequate
system design, construction and operation and not from inherent limitations in
treatment technology (Leyendecker, 1981). When the Twining situation is
analyzed using ‘standard’ concepts of sanitary engineering, the conclusion
reached is that Twining can grow somewhat without exceeding the water-quality
limits imposed by the state regulations; the actual amount of allowable growth
depends on many assumptions about how such growth would affect the river.
The concept of a water—quality limit to development is critical to under-
standing growth—related issues in Twining and is presented in detail below.

The discussion is not intended to argue for or against a given amount of
growth or a given amount of contaminant discharge, but only explains how the
regulations are likely to work. As will be shown, the regulations Ji
limit to development in Twining over the short—teim, but it is a ‘soft’
threshold rather than an absolute barrier to growth.
The calculation of a maximiiii allowable pollutant discharge is known as a
wasteload allocation . Section 6.2.2 and Appendix B.4 explains how EID has
calculated TWSD’s wasteload allocation for phosphorus, which is the critica]
pollutant potentially limiting plant capacity. The principals of the
wasteload allocation are as follows.
1. EID allocates phosphorus wasteload on a first come, first served
basis. In the case of the upper Rio Hondo, 100 percent of’ the phosphorus
wasteload is allocated to TWSD, assuming that TWSD chooses to use the
entire allocations. (Note: this does not result in total allocation of
the downstream phosphorus wasteload; see Appendix C.7.)
2. The maximum discharge of pollutants allowed from TWSD is established
so that stream standards will not be exceeded during very low—flow periods
when the river has minimal dilution capacity. (The specific period is the
driest week in ten years.)
3. Very conservative assumptions are made about: a) the impacts of’
non—point source pollution; and b) the treatment efficiency of an advanced
wastewater treatment plant. The wasteload allocation is based on a
‘worst—case’ analysis specifically intended to protect the Rio Hondo even
if the growth of’ Twining greatly increases the total amount of pollution
which needs to be controlled.
4. The discharge from a central treatment plant must not be so large as
to exceed the wasteload allocation. If’ a plant such as described by
alternatives 1, 2 or 12 were built, a discharge of more than 95,000
gallons per day would contain more pollutants than allowed by the
allocation, and could cause violation of the stream standards during
low—flow periods. Thus, at this time a 95,000 gpd plant is the largest
feasible facility. For an alternative such as number 13, which provides
much more clean—up of wastewater, the allowable discharge could be five or
ten times greater.
5. The limit on total pollutant discharge to the river is relatively
fixed so long as the stream standards remain unchanged. However, TWSD can
expand the total gallons discharged by either cleaning up the effluent
from the central treatment plant, or cleaning up pollution from non—point
sources, or both. Because the initial calculations are based on a worst—
case analysis, the prospects for such clean—ups are good. (For example,
EID assumed increased pollution of the river by on—site systems; the
simple extension of sewers to the Kandahar condominiums would help clean
up the river and possibly allow a central. plant to increase its discharge
to well beyond 95,000 gpd.) Thus 95,000 gpd is not necessarily a
permanent limit to the size of a treatment plant in Twining. It is only a

(non—binding) estimate of the maxirrum size of plant which, based on permit
conditions and a worst-case analysis, would not cause violation of the
stream standards.
Another way of viewing the wasteload allocation is to observe that the
stream standards for the upper Rio Honda will be met so long as the discharge
of phosphorus into the river does not exceed about 2 pounds of phosphorus per
day. Presently, non—point sources contribute 0.5 pounds per day and the TWSD
treatment plant discharges 3 or 4 pounds per day; thus, the standards are
exceeded. EID has assumed the non—point source component will increase to
about 1.1 pounds per day because of extensive development using septic tanks.
This leaves 0.9 pounds per day which will be allowed from the TWSD treatment
plant. The existing facility cannot meet that requirement, but once advanced
treatment facilities are built (e.g. alternative 1 or 12), even routine
operation would be expected to produce an effluent with no more than 1 mg/l of
phosphorus. If the total wastewater flow does not exceed 95,000 gpd then the
facility would comply with the 0.9 pounds per day limit. There is no physical
reason why TWSD cannot comply with the regulations.
A plant larger than 95,000 gpd could comply with the regulations if any of
the following occur:
— control of non—point sources to less than 1.1 pounds per day (each 0.1
pound decrease would permit approximately a 12,000 gpd increase in
— better than routine operation of the new facilities so that effluent
concentration is consistently less than 1 mg/l phosphorus (each 0.1 mg/i
clean—up would permit approximately a 12,000 gpd increase in capacity);
— the combined effect of the above factors could allow a 150,000 gpd plant
(alternative G in Table 5—5) if non—point sources were held to 0.5 pounds
per day (the present level) and the effluent quality consistently was
better than 0.8 mg/i;
— construction of a ‘super’ plant (alternative 13; effluent should contain
0.4 mg/l phosphorus or less, and a capacity of 375,000 gpd would not
violate regulations, assuming that other parameters were controlled, such
as by reduction of ammonia—nitrogen).
On the basis of the wasteload allocation, there will be a legally enforce-
able limit on the phosphorus discharged from any new treatment plant built by
TWSD; to ensure compliance with the regulations, the maximum plant capacity
would be 95,000 gallons per day if alternative 1, 2 or 12 were selected.
Although the effluent restriction is not a direct limit on growth, it has the
practical effect of forcing TWSD to proceed with special caution before
expanding the plant beyond 95,000 gpd. Because EID has allocated the entire
wasteload to TWSD, independent discharges to the Rio Hondo in the Twining area
would not be allowed unless the effluent were of such high quality that it
produced no addition of phosphorus to the stream, which would be a difficult

requirement to meet. This does not preclude independent discharges of
effluent to ground water (as from septic tanks) which are covered by separate
sets of regulations.
As shown in Table 5-5, a plant of 95,000 gpd would allow an increase in
the TWSD population of 750 skiers and about 560 overnight residents. This is
in addition to growth (460 overnight residents) which could occur through the
low—density spread of’ cabins which use septic tanks (since, as noted above,
EID’s worst case allows for greatly increased pollution from such non—point
Summary . Water-quality regulations are the only existing legal limit to
growth in Twining. The regulations set a limit on phosphorus discharge which,
in the short—term, would limit plant capacity to 95,000 gpd (compared to
present base—area flows of 80,000 gpd). Over the long—term the regulations
require only that any larger capacity not cause violation of water—quality
standards; these standards do not impose any specific limit on gallons
discharged and thus provide no firm obstacle to considerable expansion of
sewage facilities and considerable growth of the resort complex.
5.3.3 Growth Policies
Even though growth in Twining apparently is not constrained by economic,
physical or (over the long—term) existing regulatory factors, there are many
who believe that some limit should be placed on new development in order to
protect the local and regional environment. Many citizens consider that the
optimum population has already been reached or exceeded; others believe that
the resort could double in size and still be ‘small enough’. The debate over
the proper amount of growth has concentrated on several issues: water
resources; the overall environment of the Hondo valley; the economy of the
Taos region; and social and cultural changes.
One way to focus the debate is to compare the impacts of alternative B
(80,000 gpd) and E (95,000 gpd). Table 5—6 suninarizes the major differences
between these two capacities; the analysis is based on more detailed state—
rnent made in chapter 6, as referenced in the table. There are three major
implications of the information presented in Table 5—6. First, there is the
potential for considerable impact (both beneficial and adverse) from the
expansion of the ski valley resort complex, even without any increase in
sewage treatment capacity. Second, substantial economic benefits would be
associated with a larger treatment plant; these must be balanced against
changes in environmental quality in the Rio Hondo watershed. Third, as in the
pa :t, positive and negative impacts will not be equally shared. On balance
the impacts suggest that disagreement will remain as to whether the
development is desireable or objectionable.
Underlying much of the discussion which follows is the distinction between
p ak and total use of the resort complex. Peak use reflects the maximum
population of skiers, lodgers and other visitors/residents who may occupy the

Insacts fran Alternative B relate to: no increase In skier limit (remains at 4050); Increased visitation during off—peak periods
(winter); small increase In sumiler; 470 new pillows in 94 new cabins (added to 295 existing pillows); no increase in cociwnerc ial
facilities (remain at 931 pillows); see Tables 6—7, 6—8, 6—9. In reality, inpacts associated with alternative E would probably
also occur from alternative B, but serviced by on-site systems rather than a central treatment plant.
Impacts from alternative E would include all changes listed for alternative B, Increase in skier limit from 4050 to 4800,
proportional (20 percent) increase in off-peak use; expansion/construction of lódg s and condos to provide for 50 percent sore
overnight capacity in comercial facilities of base area (489 new pillows added to 931 existing) .8/. As stated above, all these
changes could occur under alternative B; however, alternative E would facilitate these changes. Irrpacts marked with asterisk (*)
could occur outside Twining If skier limit is increased, but overnight capacity is not (symbolically this should be achieved by
alternative 0).
F actor
Populations; see
Tables 6—7, 6-8, 6-9
Water Resources;
see Section 6.2.7
Alternative B (80,000 d) -—__________
Peak day remains at 4705
overnight capacity increase from 1226 to 1696
Annual visitation increase from 275,000 to 520,000
Reduce pollution due to Inproved wastewater treat-
ment; increase in potential non—point source pol-
lution from cabins (but may be controlled — see
5.4.2); potential decrease In other non—point sources
(see 5.4.7)
Need for 11 acre—feet/year of water rights (includ-
ing expanded snowmaking); can be obtained from
rights already held by TSV, Inc. and/or IWSO
Alternative E (95,000 gpd)
Peak day Increase to 5579
Overnight capacity increase from 1696 to 2l85
Annual visitation increase from 520,000 to 615,000
If half new jobs in Twining taken by existina
residents, then 38 persons would immigrate to
region because of increased employment
Reduce pollution due to improved wastewater treat-
ment (but, If plant should fail, pollution would he
greater than from B); potential Increase in non-
point source pollution from cabins (but may he
controlled — see 5.4.2); more potential for con-
struction impacts* (see Table 6—1); potential
decrease In other non-point sources (see 5.4.7)
Need for 4 additional acre—feet of water rights
beyond impacts of alternative B; of these 1 AFY
would be for the skier limit Increase and 3 AFY
would be for the increase in overnight capacity;
can be obtained from rights already held by ISV,
Inc. and/or TWSD
Increase in annual visitation would require an
additional 5 acre—feet of rights outside of TWSD
(e.g. Amizette, Valdez, Arroyo Seco or wherever
the skiers are lodged)
Could reduce the demand for regional water rights
from 5 to 2 AFY because skiers Stay in Twining,
not elsewhere*
Traffic, Air
Quality, Noise
(See Section 6.5,
Table 6-8, 6—9)
Peak traffic Stays at 1650 cars/day
Total traffic Increase from 104,000 vehicle—trips
per year to 196,000 vehicle trips per year 8/
Air emissions, noise end energy use increase
proportionally but standards not violated
Peak traffic increases by 310 cars to 1960/day
Total traffic increase from 196,000 to 255,000
vehicle trips per year
Air emissions, noise and energy use increase
proportionally but standards not violated
Economics £‘
(See Table 6—8, 6—9)
Increase in revenues from $27.5 million to
$52 million/year; jobs remain at 1560
Increase in revenues from $52 to $61.5 million
per year; 190 additional jobs (total 1750)
Culture; Sensi-
tive Resources
(See Section 6.5,
(See Table 6—1;
Section 6.7, 6.6.7)
Growth/impacts part of complex factors which in-
fluence changes in traditional agrarian society;
significance of impacts widely debated
Possible Increase in use of wilderness area end
trespass on Indian lands (but small compared to
problems if area becomes s umner resort)
Construction on 94 cabin lots; lirprovemerits in
ski area as described in U9S (1981) and Table
6—6; construction at treatment plant; investment
of energy, chemical and money to improve waste—
water treatment; much higher sewer rates than at
Similar to B but: more tourist influx and cash
flow; greater portion of tourists lodge in TWSD*
Similar to B, but slightly greater because of
more skiers and overnight residents”
Similar to B except: addtional construction
on 3 — 5 acres of base area”; increase in rates
more widely shared
a. If the District were to so allow, some or all of this change could occur in high—density development using independent
treatment systems.
b. Assunes no benefits from shuttle service or from reduced ctinnutlng which may result from expanded lodging In Twining.
c. Values are for a good ski year and, as discussed in Table 6—9, more than half occur in Taos region, not in Twining.
The historic decline in stremnflow in the Rio Rondo would not be significantly affected by either
alternative because it is caused by reforestation of the watershed and reduced snowfall, and not by
development at the ski valley

area during the busiest periods. Peak use has a strong influence on such
things as the capacity of facilities (from sewage plants to ski lifts to
parking lots), and does influence some key environmental factors (most notably
the number of’ jobs associated with the resort and the peak level of traffic,
which affects air quality, road congestion and safety).
In contrast, annual use reflects the total yearlong activity at the resort
complex, which will be some percentage of the peak. Currently the annual use
in winter is less than half the peak, while summer use is very small; but
these proportions could change, and indeed, average winter use (as a per-
centage of the peak) can be expected to increase simply because of the plans
to limit that peak. Most of the environmental impacts of growth in Twining
reflect changes in the annual use . These effects include the total water
pollutants discharged; water rights needed; total traffic (thus energy use and
total discharge of air pollutants); and revenues. Increased annual use
requires absolutely no additional wastewater treatment capacity, which is one
reason why the concept of ‘no-growth’ cannot be applied to any of the capacity
Expansion Without Additional Treatment Capacity (Alternative B) . Table
5—6 indicates very substantial economic and environmental changes resulting
from an 80,000 gpd sewage treatment plant. Thus, alternative B is properly
considered as a ‘no—hookup’ capacity (providing for no increase in high—
density development) rather than as a no—growth option. Three types of
changes can occur without expanded central treatment capacity. The most
significant change relates to increased visitation in off—peak periods, which
increases total use of the area. It is difficult to predict the extent to
which off—peak use of the area will grow; Table 5—6 assumes an approximate
doubling of total annual visitation, even if peak capacity is unchanged.
Impacts on water rights, traffic and revenues would double also.
The second change which does not require central treatment capacity is the
construction of cabins on 94 vacant lots designated for that purpose in the
Pattison subdivision. These cabins, which could use an—site systems as do
most existing cabins, would add an estimated 470 pillows to the overnight
capacity of Twining, an increase of nearly 40 percent compared to present
conc tions.
Both the above changes would occur with or without expanded treatment
capacity; that is, the impacts are associated with either alternative B or
alternative E. The third change would be expected only if alternative B is
chosen and TWSD has no new hookups to offer. Giver 1 existing development
pressures, it is likely that there would be some construction of small—scale
high—density units or cammercial facilities in the base area, using advanced
on—site systems or independent treatment plants which discharge a very high
quality effluent to ground water. For example, this could include triplex or
urplex condos; commercial facilities (including increased skier capacity
using up—mountain restrooms); and expansion of existing lodges and condos. It
is difficult to predict the extent of’ such development. Ultimately the
effects could approach, equal, or even surpass those associated with a 95,000

gpd plant. For purposes of this analysis, the effects are assumed equal to
those of a 95,000 gpd plant, and thus are the same as those listed under
alternative E. This approach has two implications: it suggests that
virtually all of the effects of a 95,000 gpd plant may occur from an 80,000
gpd facility; and it allows the table to highlight (as the effects of
alternative B) those parts of the TWSD expansion which absolutely do not have
even a hypothetical relationship to the choice between the capacity
Note that Table 5—6 assumes no major expansion of the resort in sumer.
Were Twining to become a major yearround recreation area, many of the impacts
listed for alternative B might again double, without requiring any increase in
sewage treatment capacity.
Additional Impacts of Alternative E . Expansion of’ the treatment plant to
95,000 gpd would allow large—scale expansion/construction of lodges and condos
in the TWSD base area, and fully accommodate the intended increase in skier
capacity. Such development would produce incremental growth beyond that
described in the previous sub—section (although, as noted, much of the incre-
mental growth might occur using on—site systems). The growth would increase
peak use of’ the area by some 20 percent during the day and 50 percent during
the night; annual use would increase in similar proportions.
In general, the impacts listed in Table 5—6 directly parallel the amount
of growth. Thus, factors which relate to skier visitation (both peak and
annual) would increase on the order of 20 percent, while factors which relate
to high—density overnight capacity (both peak and annual) would increase on
the order of 50 percent. Note that most of the direct economic benefits of
the industry (revenues and jobs) relate to skier visits; once off-peak use
approaches the limit of 4800 there would be minimal additional growth In
economic benefits from the resort. Also, if the skier limit is Increased
without expansion of overnight capacity, there would be a corresponding
expansion in the lodging industry somewhere in the Taos area; if the growth
does not occur in Twining it could still occur in the Hondo Valley (Amizette,
Valdez) or along the road to Taos (Arroyo Seco, El Prado).
The Sharing of Beneficial and Adverse Impacts . A first glance at Table
5—6 might suggest that the economic benefits associated with ski industry
growth are so large as to fully justify such growth, especially when the
adverse impacts are not projected to violate any regulations. However, an
important aspect of the benefits is that they are concentrated in the
commercial sector of the economy. Although the revenues certainly benefit the
entire region, a good portion can be identified as flowing through the hands
of some of the more affluent members of the community (comparatively
speaking), including property owners in Twining. In contrast, not all area
residents share in these revenues directly and many do not want the service
jobs which could provide such a direct share.
Adverse impacts are also not equally shared. Those who most benefit do
incur some adverse effects; this is especially true of existing residents of

Twining, many of whom do not welcome the prospect of resort growth. However,
many of the adverse effects are concentrated in the lower portions of the
Hondo valley and/or along the Twining—Taos road where there is no special
concentration of the economic gain. Although in many cases the size of the
adverse impacts may seem relatively small (as compared to environmental
standards or the total resources available), the effects are generally very
visible and involve changes to elements of the environment which some area
residents consider to be highly sensitive because of their importance to the
maintainance of culture and tradition.
It appears that the distribution of effects, as well as the total effects,
may account for much of the controversy over growth in Twining. Many local
citizens see the economic benefits of skiing as very positive, while the
adverse effects of tourism are small, acceptable and not necessarily in
conflict with traditional values. These people include (but are not limited
to) many (but not all) members of the business sector of the community.
In contrast, others consider the tourist economy to provide ‘money without
value’ and to be detrimental to the native culture. They find no reason to
support expansion of the ski area. Many persons who hold this position live
in areas where the cultural traditions are the strongest, the adverse impacts
of tourism are visible, and the economic benefits of the industry are least
evident. This includes (but is not limited to) many (but not all) residents
of Valdez, Arroyo Hondo, Arroyo Seco and Taos Pueblo.
Like any analysis which deals with human attitudes, this discussion is too
simple. For example, some persons support a larger treatment plant not be-
cause of economic issues, but because development is viewed as the right of
property owners and inevitable given pressures In Twining; It Is considered
common sense to plan accordingly and build a facility which will accommodate
the change that is bound to occur. Conversely, not all of those with an
economic interest in tourism are enthusiastic about growth In Twining; there
are residents of the District who do not relish the possible lifestyle changes
which could result from resort expansion. While a cost—effectiveness analysis
does consider who may gain or lose from certain actions, the absolute
balancing of benefits is not required.
Summary . The clearest Implication of Table 5—6 is that the effects of
growth in Twining are large, regional and deserving of community attention.
However, the analysis does not definitively answer the question of what should
occur. Indeed, because the conflict Is often stated In terms of economics
versus culture, and because there are strong interest groups representing
different perspectives on the conflict, It is by no means certain that the
question can be fully and finally resolved. It is clear that effective
soution of the issues will require decisions at the community level, through
participation in a democratic planning process. Moreover, given the intensity
of the debate, very substantial research and analysis would be needed for a
:umprehensive growth policy for even an area as small as Twining. Refer to
Moser and Peterson (1981) for a summary of how one Austrian ski village
(ioc ated in a scxnewhat more sensitive alpine setting than Twining) dealt with

the “Limits to growth” question through studies performed by 80 scientists
over a period of 10 years.
Even with an adopted plan, the probable policy would be one of controlled
growth. For example, it would be difficult to limit the increased use of the
resort in off—peak periods; rather, this may be a ‘given’ which influences
policies toward other types of growth. Control of peak skier activity would
be possible (and in fact is to be implemented by TSV, Inc.). Controls as to
commercial facilities in and near the resort would likely govern the location
and type of development, so long as the demand for facilities is strong.
Public participation in preparation of this [ IS provides a major forum for
discussion of these three types of development, but not for the larger ques-
tions of economic development and cultural evolution of Taos County. Even
though the direct impact of treatment plant capacity on development may be
minimal, plant size is certainly symbolic of that part of the growth debate
which concerns tourism (see 5.3.4 for further discussion of this point).
Thus, some members of the public may consider decisions made by EPA as a vote
in support of or against different growth policies. However, the EIS is too
narrow a document to resolve all (or even most) of the issues which concern
local citizens. Further, it is doubtful that the citizens would desire or
profit by growth directives imposed by a federal agency. Thus, while growth
issues certainly bear on EPA’s evaluation as to the best approach to waste—
water management in Twining, it is not the intent of’ the EIS to provide
definitive guidance as to how Taos County should manage its future.
5.3.4. Evaluation of Alternatives
Table 5—6 indicates the dimensions of change which are associated with two
of the seven capacity alternatives. Based on discussions in the previous
section, it is difficult to decide which capacity is most cost—effective. At
this time, EPA has not made such a decision. This section reviews the major
factors which will be considered; additional information is provided in
chapter 6. In particular, sections 6.2.7 (water resources) and 6.6.6 (social
and economic impacts) contain much of the supporting data for the analysis
which follows. Although substantive matters are important in the discussion,
much of the public controversy has a philosophical basis. Thus, the
plant—capacity decision can be viewed (in part) as a symbol of the community
debate over the changing environment.
Comparison of the Seven Alternatives . Although Table 5—6 deals with only
two of the seven alternatives listed in Table 5—5, it provides the basis for
comparing all seven, as follows.
— Impacts from alternative A (70,000 gpd) would be identical to those
from alternative B (80,000 gpd), except that the former would have less
water—quality benefits because it would not improve the management of
wastewater from the Kandahar condominiums.

— Alternatives C and D (80,000 and 85,000 gpd) would have the same
impacts as alternative E, except that the effects of’ increased overnight
capacity would occur outside of TWSD rather than inside; also, alternative
C would have the same lack of water—quality benefits as alternative A.
- Alternative F would have impacts in proportion to those listed for
alternative E; all the incremental effects of increased overnight capacity
listed in Table 5—6 would approximately double if this larger facility
(105,000 gpd) were built. (For example, water rights would increase by
another 3 acre—feet per year.)
— Alternative G (150,000 gpd) would increase all the overnight impacts
enormously; very roughly the effects would be five times as large as the
overnight—capacity impacts of alternative E.
On the basis of these comparisons, four of the alternatives are unlikely
to be very cost—effective. Alternatives A and C fail to meet widely accepted
goals of providing optimum wastewater management in the area. Alternatives F
and C exceed the size defined by the wasteload allocations.
Alternatives B and E are characterized in Table 5—6, and are discussed in
the next section. Alternative D can be considered identical to E, except that
the impacts of overnight capacity listed in the table would occur outside
Twining rather than within the District.
Alternative B or Alternative E ? Public discussion of the 80,000 and
95,000 gpd plants has revealed some agreement that, regardless of what label
is assigned to the facility, TWSO should meet stream standards for existing
wastewater flows before any expansion is contemplated. Section 5.4.9 outlines
methods of such a phased expansion. If this approach is assumed valid, then
the two major capacity alternatives are:
build a facility which allows some growth (95,000 gpd); however, actually
treat only existing flows until the facility fully complies with the
effluent limitations, and then gradually allow new hookups (development);
provide the capacity only for existing flows (80,000 gpd), and once the
plant is in compliance, gradually expand the plant and the discharge.
A variation on alternative B, to build an 80,000 gpd facility and never expand
it, has not been accepted by the District. Even if the District chose to
limit the plant to this size permanently, the legal constraints discussed
earlier would not necessarily preclude construction of additional treatment
plants by other entities. The issue of independent plants is discussed in
5.4.9 (sub—section on hookup policy).
It is difficult to choose among these options on the basis of environ-
mental impacts alone because: a) substantial environmental change is
predicted with or without an expanded treatment facility; and b) the changes

are not uniformly good or bad, but include both substantial economic benefits
and small but real adverse environmental effects which will be highly visible
and judged by many as representing a substantial threat to traditional
The problem of selecting the ‘best’ plant size is compounded because, from
an engineering point of’ view, a sewage treatment plant of 80,000 gpd capacity
is virtually identical to one of 95,000 gpd capacity. That is, the hardware
is about the same in type and size, and operations don’t change much. What
does change, of’ course, is the number of hookups allowed and the extent to
which growth is accommodated through a central treatment plant versus inde-
pendent systems.
The debate about capacity has many symbolic aspects, which of’ necessity
must be simplified here. At the most basic level, support for a larger treat-
ment plant is generally considered as support for (or acceptance of) growth in
Twining, while support for a smaller treatment plant coincides with an en-
dorsement of a no—growth (or low—growth) policy. More specifically, the two
alternatives symbolize the following attitudes (individuals favoring one or
the other options may endorse only some of these attitudes, and indeed may
support some conflicting principles).
Alternative 8 (80,000 gpd) . In general, proponents of a small plant (or
opponents of a large plant) favor a no—growth policy for Twining; often this
policy extends to other types of tourism and to all types of non—traditional
development. It is observed that protection of the Rio Hondo is most easily
accomplished by never causing any problems with the river in the first place.
For these individuals the benefits of growth (economic) are not worth the
price (environmental and cultural). Some identify tourism and skiing as major
threats to their water resources and agrarian lifestyle, and thus incompatible
with fundamental traditions, ethnic identity and economic survival. Others
acknowledge some benefits from the ski industry, but believe there has been
enough development of this type.
Some of those who favor no—growth believe development can be stopped by
some means; others recognize that some development will occur but do not want
to encourage or support it in any way. The endorsement of a small plant (even
if’ it may soon be enlarged) represents this resistance to changes which may
adversely impact water resources and local culture. Ideally the position is
viewed as actually slowing growth, but even if it does not do so directly, it
serves as a message to all concerned that there is a community concern about
development. The specific message to EPA is that funding should be limited to
the smaller facility. Grant funds should not encourage undesireable
development; if growth does occur, all costs should be borne by those who
benefit. The message to IWSO is that the commitment to a larger facility
should occur only after the initial facility is in full compliance with the
regulations. Because of past problems, and as a matter of equity, a larger
plant cannot be justified unless and until TWSD demonstrates both good faith
and actual competence in management of a smaller facility.

Alternative E (95,000 gpd) . In general, proponents of’ a larger plant
believe that the revenues and jobs associated with skiing have been a major
factor stabilizing and improving economic conditions in the Taos area; this
development has represented real progress and made it possible for at least
some Taosenos to sustain their rural traditions. They recognize the urgent
need to correct existing pollution problems in the Rio Hondo and believe that
once this is done the adverse effects of additional growth would be small and
acceptable if managed properly. Often, growth is viewed as the inevitable
result of the free enterprise system and private property rights. It is con-
sidered common sense to plan for such development; construction of a plant
which is smaller than ultimately needed is viewed as an invitation to repeti-
tion of past wastewater treatment and water—quality problems. Thus, they
reason that the stresses on the watershed are unavoidable and the key is to
use appropriate technology to control these stresses and minimize harm.
The specific message to EPA is to fund a facility which will solve the
real wastewater management needs of Twining, especially since a decision to
the contrary will not actually stop (or even slow) development. Persons
concerned with facility financing point out that, the hookups allowed by a
larger capacity will allow TWSD to assess treatment costs to new development,
provide for a wider sharing of the expenses of a new plant, and reduce the
burden on existing residents. It is also noted that TWSD can respond fully to
concerns about water—quality by building a larger facility but phasing in
hookups in response to demonstrated successful plant performance.
In summary, there are two quite different points of view, each with
supporting evidence. Despite some overlap in attitudes, the issues are often
construed as ‘progress’ versus ‘tradition’; economics versus culture; using
technology to mitigate environmental stress versus minimizing the stress
itself. Similar issues are often debated at the regional, national and even
global scale; they are not easily resolved but this in no way diminishes the
intensity of the debate.
The DEIS and EPA’s public hearing will solicit further input on this
subject. A decision as to the most cost—effective capacity will ultimately be
made; however, it is by no means certain that the choice will be unequivocal,
and Tt may be based as much upon considerations of changing federal policies
and funding levels as on a determination that one or the other of the above
arguments is ‘better’. Certainly, In itself, the decision will not resolve
fundamental conflicts of’ progress vs. tradition, et al. (See also part B, p.
The development of a complete wastewater management system requires
consideration of many factors beyond basic treatment concepts and plant
capacity. This section discusses methods for addressing the remaining
components of an effective facilities plan (1
the planning effort developed a single ‘most effective’ approach, because of
the general need to provide the best practicable treatment works in Twining.
5.4.1 Collection System
The existing collection system experiences a severe infiltration problem
(see Appendix A. .2 and BLL, 1981). Approximately 20,000 to 25,000 gpd of
natural ground water must be treated at the plant in winter during a wet year,
accounting for 20 to 65 percent of all inflow. In addition to increasing
wastewater volume and treatment costs, the infiltration interferes with the
efficiency of treatment because it dilutes the raw sewage and lowers its
temperature substantially.
According to the draft facilities plan, the lowest—cost solution to the
problem is to rehabilitate the collection system. The District has received a
step 1 grant increase to study the problem in detail and to undertake a
solution. The initial action will be to survey the existing system using
television equipment. Then “slip—lining” will occur where possible (new pipe
will be inserted inside the old) and replacement sewers will be required where
deterioration was found to be excessive. The rehabilitation is estimated to
cost approximately $150,000 and should reduce the rate of infiltration to no
more than 1,600 gpd. Rehabilitation would have local construction impacts
(see Table 6-1) but would eliminate interference with the treatment processes
and thereby increase the reliability of the facility.
Because of high costs ($2,000 or more per connection plus the expense of
treatment plant expansion), no collection line extensions are proposed in the
draft facilities plan. Service lines would be extended from existing collec-
tion lines to the Kandahar (a short distance) and to a few existing cabins
close to the river. Remaining cabins would continue to use on—site systems.
5.4.2 On—site Systems
Although on—site systems (055) are not considered an effective overall
solution to TWSD wastewater management (see alternative 3, Section 5.2), they
can be used in some circumstances. Two distinct alternatives can be con-
sidered. One approach would be to defer to EID regulations and have that
agency continue to have full jurisdiction over new systems. This choice would
simplify TWSD management and help contain costs; however, it might not fully
address problems of phosphorus (and other) pollution from OSS because EID
regulations are sanitation oriented, not water—quality oriented. The
wasteload allocations take this impact into account and violations of stream
standards would not be expected; nonetheless, optimum protection of the river
would not be accomplished. Also, this alternative would accomplish little of
the flow reduction which could be obtained from a more active approach.
The other alternative is for TWSD to choose to become involved in at least
some and perhaps all aspects of OSS management. One of the major steps would

be the requirement that new development use dry or extremely low flush toilets
(see Section 5.4.6). This would both reduce total wastewater flows (to the
treatment plant and to oss) and reduce total pollutant loadings. A second
major step would be to become actively involved in the management of 055. One
aspect of this effort would be to provide guidance on the best types of
systems; this would touch both upon the need for good sanitation (the conven-
tional concern and main focus of EID regulations) and the need for water .-
quality protection (TWSD’s specific mandate). Appendix B.5 summarizes the
alternative technologies which might be considered; these alternatives are of’
value because soil and slope conditions present severe limitations to the use
of more conventional technologies (such as septic tanks and drainfields). In
addition to identification of appropriate technology, TWSD’s management
effort.s could include: special remedial efforts to correct surfacing of
wastewater; periodic inspection of advanced systems; and specialized main-
tenance of advanced systems. The cost of providing such services is estimated
at about $7500 per year for a part—time sanitarian (who could be a part—time
treatment plant operator). To the extent that these alternatives would reduce
wastewater flows and improve river quality, the investment would ultimately
allow the District to provide a greater number of new hookups.
5.4.3 Specific Plant Site
A large number of plant site alternatives were considered in section 5.2.
Alternatives involving a major change in location have many disadvantages (see
section 5.2). The existing site is considered suitable for any of’ the ‘semi-
final’ alternatives (Table 5—4); no reasons have been identified for incurring
the expense of relocation. Thus, no additional siting alternatives have been
5.4.4 Sludge Management; Disinfection
The draft facilities plan determined that sludge stabilization can be
accomplished effectively by sand—bed drying, without special processing.
Sludge would be stored in an aerated basin during winter months (maximum 180
days) and dried on five sand beds in the warmer months. Two additional sand
ueds greenhouse—covered) would be available for winter drying as needed.
Dried sludge would be disposed of’ by hauling to the Taos municipal landfill;
because of the small volume of material, no adverse effects would be
expected. Alternative methods of disposal, such as reuse, were not considered
in the draft facilities plan because of minimal benefit and possible
environmental contamination from pathogens (see also section 5.4.5).
Of the many possible disinfection alternatives, use of Iodine and
ultraviolet radiation were considered excessively expensive. Chlorination,
The most conventional choice, has several adverse impacts: it may produce
r’ :cinogenic trihalomethanes; if effluent is overchiorinated, the resulting
n lorine residuals can be toxic to aquatic life in the Rio Hondo; delivery of
chlorine requires transport of a hazardous material through downstream

communities; and chlorine is relatively ineffective in killing viruses and
parasites, pathogens of concern to downstream residents.
Ozonation (using ozone produced on—site) would overcome the disadvantages
of’ chlorination and help reduce the oxygen demand of the wastewater effluent
(Chappell et al., 1981). Its main drawbacks are high costs, energy require-
ments and operational complexity. However, because of the water—quality,
safety, odor control, and other benefits to downstream residents, ozone is the
disinfectant recommended in the draft facilities plan.
The proposed process of phosphorus removal (lime precipitation followed by
sand filtration) is also an effective disinfection technique. In combination
with ozone, the anticipated effectiveness of new facilities is expected to be
approximately 99 percent or better for bacteria, viruses and pathogens. This
is much better than generally accomplished by conventional chlorination,
especially for viruses and parasites.
5.4.5 Energy Conservation
All of the available treatment alternatives utilize significant amounts of
energy; substantial energy conservation is not practicsble if the strict
treatment requirements are to be met. The principal technique available for
reducing energy use is to cover and/or insulate sensitive facilities so that
solar energy is trapped and air/ground cooling does not adversely affect
treatment. The draft facilities plan proposes the use of greenhouse
structures over the sludge drying beds which would be used in winter; other
facilities are expected to function properly without this assistance. A
second technique is insulation; the four aeration-chambers would have
insulated foundations so that they would not be affected by winter ground
cooling. The building housing the filtration, recarbonation and disinfection
units would also be insulated.
Except for alternative 12, the draft facilities plan indicates that it is
more cost—effective to dry undigested sludge than to digest it; if dried
undigested there would be no methane generated at the plant and the energy
value of’ the sludge would be lost.
5.4.6 Flow Reduction
Appendix A.4 outlines existing :reasures which have already been put into
effect to reduce flow; rates of water use in TWSD are low and probably can not
be reduced substantially. However, conservation education (as done by the
District in the past) is certainly worthwhile since costs are low. Also, two
techniques could accomplish such substantial reductions without unacceptable
adverse effects. Elimination of the infiltration problem will reduce flow by
at least 20,000 gallons. Requirements for the use of dry or extremely low
flush toilets in all new construction (and remodeling) would reduce water
demand and sewage flow by approximately 33 percent. Specific options for the

use of dry or extremely low flush toilets are discussed in Appendix B-5; a
scenario for implementing their use is discussed in section 5.4.9.
5.4.7 Control of Non—point Source Pollution
The major sources of non—point source pollution in Twining would be
addressed effectively if: a) TWSD implements a comprehensive management
program for on—site systems (section 5.4.2); and b) Taos Ski Valley, Inc. and
the Forest Service successfully implement programs to control constituents in
runoff from fertilized ski trails, the parking lots and disturbed areas.
Plans for control of runoff’ from ski trails and parking lots have been
developed and are in the TSV, Inc. 30—year master plan EIS. In addition to
these mitigations, site—specific environmental assessments (EA5) will be
conducted by the Forest Service prior to development of parking lots and ski
trails; the EAS will specifically evaluate runoff—control needs for each
project (USFS, 1981a and 1981b). Additional major efforts are not required
for purposes of water-quality protection; however, as discussed in section
6.1, the District has the option of taking some additional steps at
construction areas.
5.4.8 Rate Design
Table XIII of the draft facilities plan projects the total and monthly
costs which TWSD must pay to build a new treatment plant, correct the
infiltration problem, and accomplish other necessary wastewater management
measures. The table shows that these costs range from $7,000 to over $15,000
per month (for alternative 1), depending on the amount of federal and state
funds (if’ any) which are granted to support facility design and construction.
Based on input from TWSD and the public participation process, the general
principal of cost—recovery developed in the draft facilities plan was to
design sewer rates so that those who benefit from new facilities would pay for
them. In particular, this means that skiers and other visitors should bear
the brunt of’ the expense. Another objective was to sustain an operating
reserve fund for emergency use; such a fund reduces the need for special
assessments to TWSD members at times when cash may be scarce (e.g. winters
with poor ski conditions).
The design developed in the draft facilities plan Is as follows.
1. The funds needed per hookup would be estimated on the basis of flow.
For example, if federal/state funding provides 50 percent of construction
costs and none of the operational costs, TWSD would need to recover about
$1.50 per year for each gallon of’ treatment capacity provided. This
equates to about $15/year to provide treatment capacity for each skier (or
$15 x 4800 = $64,000/year total) and $75/year for each ‘pillow’ ($75 x 470
= $110,250). (These numbers are approximate; for comparison, the 1980
budget was $1.08 per gallon per year.)

2. The bulk of this money would be recovered from a surcharge placed on
room tariffs and lift tickets. Roughly, this would add 25 cents to the
price of each lift ticket and $1.00/night for each overnight guest.
3. The surcharge would fully pay for all TWSD costs (and even produce a
surplus for the operating/reserve fund) in a good ski year, but might fall
short of’ providing enough money in off years.
4. New hookups would be sold at market value and the funds added to the
operating/reserve fund to assure adequate funding in off years. (If no
new hookups are available, costs to existing residents would be oreater.)
5. If on—site system maintenance was undertaken, on—site system owners
would be charged for services.
6. Finally, property owners would be assessed an annual ‘service charge’,
projected according to the treatment capacity they require as measured by
water meters. This assessment would be used to build up the operating!
reserve fund in good years; once the fund reached an adequate amount,
further assessments would be waived until the fund was depleted.
The proposed rate design appears practical in the context of TWSD’s
economy. Refer to the draft facilities plan for additional information on the
5.4.9 Quality Assurance
A major issue identified in the public participation process was concern
that, no matter how good the facilities plan, the wastewater problems in the
Rio Hondo will not be resolved. Because of the long history of non-
compliance, there is concern by some that TWSD could not (or would not)
implement the plan and that EPA, EID and/or USFS could not (or would not)
enforce compliance with the regulations. While it may not be possible to
eliminate all sources of human and mechanical error, it is possible to reduce
the risks of non—compliance to a minimum; this is the concept of quality
Quality assurance alternatives fall into three broad categories:
technology; TWSD management; and government enforcement. The concept of a
hookup policy is a sub-category of TWSD management and has been a topic of
particular public interest. As background to part of the discussion, it is
useful to examine the nationwide experience of municipal wastewater facil-
ities. As described in many. references (e.g. Hadeed, 1981; Feliciano, 1980;
Nordliflger, 1980) the history of Twining is not unusual; in fact, more
municipal plants are in violation of their NPDES permits than are in
compliance. Causes of this problem include (but are not limited to): 1)
inadequate design capacity; 2) equipment deficiencies; 3) unsolved
infiltration/inflow problems; and 4) operation and maintenance deficiencies.

Technology . Although many agencies are involved in the design and
construction process, the owner may have no one to turn to if a completed
plant has problems. Thus, it is important that plans and details be carefully
reviewed pfjor to final approval (Feliciano, 1980). A special type of
intensive review, designed for the purpose of quality assurance and cost—
control, is value engineeripg . Specialized consultants review project plans
and designs prior to construction to verify that the processes used will work
as intended and that the treatment system is fully cost—effective. Value
engineering is not a routine part of’ all facilities plans, but can be included
in the step 2 grant program where appropriate.
Special EPA review programs exist which deal with the construction and
operation stages. Implementation of’ these would document and provide a
positive demonstration of proper performance on the part of TWSD and its
agents. Such extra steps toward quality control - if successfully accom-
plished in an open forum — would help reverse the long—standing antagonism
between the resort and downstream residents. As one specific requirement
(others can be identified during design) for the construction phase, the
grantee must hire a competent resident inspector; in addition, the Corps of
Engineers makes periodic inspections. Inspection requirements are particu-
larly appropriate for a situation such as Twining, where the grantee lacks
in—house technical/engineering expertise. Had such assistance been available
in the past, many of the existing problems might not have occurred.
Assuming a facilities plan is well—conceived, value engineering should
refine but not drastically alter the system design. To help judge whether or
not the proposed alternatives are likely to work, the EIS research has in-
cluded a survey of wastewater treatment technology in Alaska (johnson, 1978)
which emphasized the following as being appropriate or reliable cold climate
technology: the use of lime for disinfection; use of waste heat for sludge
drying; modular designs for fluctuating populations; the use of surge tanks or
equalization basins to steady the loading rate and thereby improve treatment;
the use of the extended aeration process as a consistently reliable method;
and an emphasis on good operation and maintenance. All of the these, except
using waste heat for sludge drying, are key parts of the TWSD draft facilities
plan. (It was determined that there would not be enough waste heat from
sources such as sludge pumps to be used beyond helping to heat the main
Similarly, a review of phosphorus removal technology by the U.S. Army
(Ryczak and Miller, 1977) recommended chemical removal as the most flexible,
consistent, reliable and economical method, which also provides for higher
suspended solids removal. The report also notes lime to be especially
appropriate for use with low, alkalinity waters such as the Rio Hondo. Thus,
the proposed facilities are consistent with the best available technology for
phosphorus removal.
ihe same conclusion applies to the disinfection methods. The literature
cite ; ozone as a powerful oxidizing agent, second only to fluorine (Rabosky,
19/2; Heckroth, 1974). It will react rapidly with almost any oxidizable

compound and has the potential to reduce BOO, COD, turbidity, color, odor,
taste, refractory organics, bacteria, and virus levels. In water ozone
decomposes to form molecular oxygen, adding to dissolved oxygen levels. Ozone
is more effective than chlorine in removing or reducing odors from wastewater
and has been found to be very effective in removing airborne odors, even more
so than activated carbon filters, chemical masking agents, or organic chemical
deodorants. However, the presence of suspended organic materials in the
wastewater can be an obstacle to highly efficient ozone disinfection, and it
may be difficult to treat secondary effluent with ozone and consistently meet
bacteriological standards. Therefore, either longer contact periods or prior
tertiary treatment, such as filtration, may be necessary. The draft facili-
ties plan proposes that filtration precede ozonation.
TWSD Management . Inadequate provisions for operation and maintenance
(O&M) are commonly cited as problems leading to non—compliance by treatment
plants. Specific problems can include lack of trained personnel, lack of
routine maintenance, insufficient laboratory equipment, an inadequate spare
parts inventory and an inadequate budget. All of these problems have occurred
in Twining in the past (see Appendix A.4) and all have been addressed to some
degree in response to past enforcement actions (see Appendices A.l and A.2).
Specifically, the District has retained the services of a full—time Class IV
operator — the highest rating - though State regulations only require a Class
III operator for Twining. (The District also has a full—time Class III
operator and a full—time administrative assistant.) The District doubled its
budget from 1979 to 1980, purchased a 100 percent spare parts inventory and
has equipment adequate for full self—monitoring. As a result, routine and
remedial maintenance activities have increased significantly (see Appendix
All of these O&M improvements go a long way towards insuring a more con-
sistent high quality effluent. The NPDES permit provides the principle incen-
tive for proper 0&M in the future (see subsequent discussion of enforcement).
Hookup policy . Any policy which TWSD may adopt toward the granting of new
hookups is of major interest because it appears that the demand for hookups
will exceed supply; thus the allocation of hookups may determine the costs of
new high-density development. Of equal importance, because of the history of
non—compliance of the present facility there is a need to ensure that any new
plant is not overloaded and rendered ineffective.
The existing hookup policy may be termed a conditional moratorium, where
hookup is not considered unless pretreatment is provided and the TWSD plant
already is in compliance with the regulations. Due to past difficulties in
meeting its effluent limitations, the District wishes to maintain a peak
average weekly inflow of 80,000 gpd as untreated wastewater (this peak was
recorded in 1980). As plant hydraulic capacity is 100,000 gpd, this leaves
20,000 gpd of unused hydraulic capacity. Thus, the plant can convey (not
treat) another 20,000 gpd, and If a customer wishes to discharge treated
wastewater to the sewer system, and if plant performance is stable and
reliable, the District will accept it. Wastewater must be pretreated to 30
mg/l BUD and SS, which are the key NPDES limitations (see Table 4—1).

Under the existing policy, if the TWSD plant is not in corrplete, reliable
compliance with effluent regulations then those who need wastewater service
can construct their own independent treatment facility if such facility
produces water of potable quality (i.e. plants similar to treatment
alternative 13). If such a facility is approved by appropriate state and
federal agencies, it will be accepted by the District.
The effects of the policy can be illustrated by the case of Ski Solar
Homes of Albuquerque which has proposed an 18-unit condominium development for
the base area of the resort. Initially the developer stated his intention to
discharge 3,600 gpd of’ pretreated effluent to the District. Solar Ski’s
notice was accepted by EID (EID, 1981c) and the District initially approved it
subject to receipt of the acceptable design information (TWSD, 1981), and with
the understanding that service would be stopped if pretreatment is inadequate
or flows exceed 3,600 gpd. In effect, TWSD offered Solar Ski Homes the use of
its effluent pipe for discharge of already treated wastewater to the Rio
However, because of violation of the effluent standards in the spring of
1961, and reflecting considerable public concern, TWSD deened that its plant
performance, although much improved, is not yet reliable and stable and
decided to deny the new hookups at this time. In response, Ski Solar Homes
proposes to construct an independent treatment plant which would produce
potable water; the effluent from the plant would be discharged to the ground
water through an injection well. This concept resembles treatment alternative
13, discussed in section 5.2. Such an approach would comply with the District
policy and is not in any apparent conflict with state and federal regulations;
there would be essentially no pollution of the ground water or river flows.
Although the proliferation of independent facilities may comply with
applicable requirements, there could be significant disadvantages including
reduced reliability due to the existence of many different plants of
relatively sophisticated design and the substantial increase in the total
costs of wastewater treatment within Twining (thus the increase in the use of
energy and other resources).
The plans of Solar Ski Taos reinforce the point made with respect to Table
5—6, that. an 80,000 gpd plant is not a no—growth facility. If the District
should limit its plant size to 80,000 gpd there would be at least 15,000 gpd
of wasteload allocation available in the Rio Hondo and it can be expected that
independent plants would be constructed to utilize that allocation. Should
such facilities all use very advanced (and expensive) treatment technology, it
woulo be possible for the Twining area to grow subsantially (i.e. to a popula-
tion equivalent of 150,000 gpd or more) without comi ig into conflict with
water—quality regulations.
Future hookup alternatives available to the District, following con—
truction of a new plant, include: 1) continuing the present policy, or 2)
allowing hookups on some type of phased basis. Legal factors may play a role
in this decision, since property owners might well challenge any moratorium
that does not have a sound technical and legal basis. The existing basis is:

the plant has been unable to meet effluent limitations and stream standards at
present flows, is under a legal agreement to do so, and until it can, no new
wastewater should be introduced to the system. Once the improvements are made
and the TWSD is in full compliance, it is uncertain if the District could
unequivocally ban new hookups. However, some type of phased or conditional
moratorium might be imposed which would restrict or deny hookups during the
period when phosphorus removal capabilities are being demonstrated. If the
policy were clearly for ‘health and sanitary purposes’ it is arguable that it
could be within the legal authority of the District.
The District is currently evaluating criteria for determining eligibility
for future tie—ons. Three major alternatives have been suggested. The first
is a possible scenario for phasing hookups; it attempts to reflect a balance
of the concerns of persons throughout the Rio Hondo watershed and is a
compromise between fast—growth and no—growth philosophies.
1. The District proceeds to construct phosphorus treatment facilities
capable of treating 80,000 gpd or 95,000 gpd. This must he done in
conjunction with resolution of the existing infiltration problem.
2. The District, EID and the Forest Service cooperate in setting up
methods for continuing to n nitor stream conditions (example: monitor
non—point sources). If water rights are transferred, the evaluation of
low—flow conditions would be reviewed.
3. Additional water conservation efforts are made to reduce sewer flows
(for example, dry or extremely low flush toilets are required in all new
4. Once the plant is built, the District demonstrates that an effluent
quality of 1 mg/l phosphorus or better can be accomplished. This would be
demonstrated over some as yet undefined time period, sufficient to prove
reliability under varying conditions. The monitoring shows that there is
no major reason to change the wasteload allocations. (That is, the values
of flow, background pollution, etc. used originally still apply. Note
that if monitoring shows problems in this regard, there could be a need
for a continued hookup moratorium.)
5. The District extends service lines to its top priority customers —
existing properties presently experiencing problems (Kandahar and selected
6. Step 4 is repeated.
7. Additional hookups are allowed, first for expansion of existing
development and then to new facilities. These would be allocated in an as
yet undefined amount and schedule, in phases, with step 4 repeated as
necessary until the design capacity of 95,000 gpd is reached. If the
original plant is 80,000 gpd, this would require some physical
modifications at the plant.

8. Step 7 is repeated and capacity expanded so long as the wasteload
allocations demonstrate a virtually zero risk that the stream standards
would be violated.
To summarize, any development resulting from a 95,000 gpd NPDES limit
would be phased in based on plant performance, providing a positive incentive
for good management on the part of TWSD. The capacity of the plant (and the
number of hookups allowed) would depend on the continued verification of the
numbers used in the wasteload allocation (see Appendix 8.4), plus the ability
of the District to produce a clean effluent. Expansion beyond 95,000 gpd
could follow the same strategy except, as noted in section 5.3.2, TWSD would
have the added responsibility of determining that the wasteload allocation
calculations can be revised without violation of the standards. Some members
of the public have suggested that plant design receive a value engineering
analysis prior to approval and implementation.
The alternatives are a slow—growth or fast—growth hookup policy. Under
the slow—growth alternative, TWSD would deny all new hookups until the
District is in full and coriplete compliance with its NPDES permit for some
period. This approach is favored by some downstream residents. The
fast—growth alternative would lift limits on hookups once a new plant is in
place; new connections would be sold on the open market to pay off
construction costs. This option has been suggested by some District
residents, especially if federal funding is not available for a new facility.
Regardless of the hookup policy adopted by the District, developers with
sufficient economic incentive would be able to construct independent treatment
plants with a ground water discharge (as demonstrated by the case of Ski Solar
Enforcement . At the scoping meeting in October, 1979, and in public meet-
ings since then, considerable public concern has been expressed about the
perceived lack of vigorous enforcement of federal and state laws which, on
paper, should have prevented the pollution of the Rio Hondo by the Twining
Water and Sanitation District. Citizens ask whether there is any reason to
believe the future will be better.
The following discussion details enforcement history and current
enforcement policies. It is important to note that any decision on
enforcement actions in the future must be based on all relevant facts and
policies in effect at the time.
U.S. Forest Service . USFS and EPA have agreed that since EPA is the
federal agency responsible for water—pollution control, EPA should take the
lead in enforcing any federal water—quality requirements which apply to
Twining. This policy is not likely to change in the future.
U.S. Environmental Protection Agency . EPA issued the NPDES permit that
regulates the discharges from the Twining plant. EPA is responsible for
enforcing the permit; enforcement options include letters, administrative

orders and referrals to the Department of Justice. In 1976, EPA issued
Twining an administrative order for permit violations. The order required
Twining to take several actions in order to remedy problems at the treatment
plant. Hindsight reveals that, while the actions taken improved plant
performance somewhat, they were not adequate to eliminate the non—compliance
(as evidenced by continued pollution after Twining complied with the order).
In the Clean Water Act, Congress gave EPA two ways (sometimes combined) to
solve pollution problems caused by publicly-owned treatment works (POTWs):
grant funds and enforcement authority. This has produced a ‘carrot—and—stick’
approach to pollution problems. EPA has emphasized the carrot (prioritized
construction grant funds), resorting to enforcement against municipalities (or
sanitation districts) only when the preferred approach does not succeed.
Because the amount of construction grant funds is limited compared to the
demand, EPA’s reliance on the funding approach has resulted in some delay in
eliminating municipal non—compliance. This delay is illustrated by the fact
that, as of July 1, 1977, sixty percent (10,251 of 17,218) of POTWs were out
of compliance with some part of their permits (Feliciano, 1980). Congress
amended the law in 1977 and provided to qualified POTWs extensions of the
deadline by which secondary treatment must be provided.
EPA believes that state governments can identify problems and initiate
enforcement actions. Thus, EPA’s relatively small enforcement staff works
primarily on major problems which are of national or regional concern (for
example, the Houston Ship Channel in Region VI), or those which are brought to
EPA t s attention by the states and which warrant federal attention.
In 1979, EPA announced a new policy dealing with municipal non—compliance,
as articulated in “The National Municipal Policy and Strategy, October, 1979”
(EPA, l979b). The policy was partly in response to changes in the federal
law, changes made because so many plants were not able to meet the original
pollution clean—up schedule in the law. EPA understood two options. First,
the agency could issue a permit to a discharger if it looks as though the
plant could meet final permit requirements by July 1, 1983. EPA would set
both interim and final effluent limitations in the permit and would specify a
construction schedule with milestone dates. These milestone dates would
provide a check on progress; failure to meet the schedule would be grounds for
an enforcement action. For Twining, interim effluent limitations proposed
would be similar to those imposed by EID in the “Assurance of Discontinuance”
(refer to Appendix A.l and Table 4—1). The final limit would reflect the need
to remove phosphorus from the wastewater in order to comply with the proposed
revisions to the state water—quality standards (see Table 4—1).
Second, if it appears that final permit limits would not be met by July 1,
1983, EPA could issue an administrative order in conjunction with issuance of
the NPDES permit. The administrative order would set up a milestone schedule,
which would be followed until 1983 and would also contain interim effluent
limitations. At this time, the schedule for completion of’ the Twining
facility has not been established. Should design begin before the end of
1981, compliance with the permit may be possible by July 1, 1983. If so, a

permit with interim and final limits and a construction schedule would be
issued. Otherwise, the administrative order would govern, with its own
schedule for compliance.
The formalized policy incorporates specific milestone schedules, which
should better define when the carrot approach is not working and enforcement
action is needed. Specifically, once new facilities are in operation (or once
the grant process has been terminated), there should no longer be any basis
for any entity to cite ‘work in progress’ as a basis for deferring action.
New Mexico Environmental Improvement Division . EID has historically
relied upon EPA to correct pollution problems through the construction grants
program or through enforcement actions against municipal permit—holders
(including sanitation districts). States have the option of takinç control
over permits of the type which are issued to Twining (subject to EPA review),
through delegation of the NPDES permit program from EPA. The New Mexico
legislature has chosen not to exercise this option. Therefore EID has taken
the position that full responsibility for the permit program remains with
EPA. Further, until April 1979 the agency was unsure as to whether the
federal law took precedence over state regulations (Pierce, 1980). The State
took no actions against any municipal discharge regulated by a federal Dermit
prior to 1979, leaving all enforcement to EPA.
In April, 1979, EID reassessed the legal relationship between federal and
state law, and determined that the existence of a federal permit did not
preclude enforcement of state regulations (Pierce, 1980). Problems at Twining
were addressed soon after the new policy took effect. The initial result of
state actions, the Assurance of Discontinuance, is discussed in Appendix A.
The violations in early 1981 have led to enforcement actions by the agency: a
complaint against TWSD was filed by the New Mexico Water Quality Control
Commission (NMWQCC). In response to this action, both parties entered into a
Judgment by Consent, which represents an agreement between NMWQCC and TWSD.
Under the terms of the Judgment, the District agreed to pay a penalty of $500
and to expend $3,000 on improvements to the plant. The District also agreed
to sample for BOO and fecal coliforms on a weekly basis (Saturday or Sunday
during the ski season). Results from these samples can be used for
enforcement action under the terms of the Assurance, which remains in effect.
Failure to meet the terms of the judgment amounts to contempt of Court.
EID enforcement activity reflects a revised policy on EID—EPA relation-
ships. So long as the new policy remains in effect (and subject to
limitations in resources), EID is likely to continue to be relatively
aggressive in enforcement activities. However, once Twining complies with the
Assurance of Discontinuance, .EID (like EPA) would rely upon the construction
grants process and milestone schedules before taking further action (Pierce,
TWSD . The Sanitation District (and its predecessors) have generally
followed a reactive approach to the pollution problem. That is, most steps
taken by the District have occurred in response to incentives and directions

from EPA and/or EID. For example, major modifications to the treatment plant
and/or operation of the sewer system have occurred in reaction to EPA’s
Administrative Order and the Assurance of Discontinuance negotiated with EID.
In recent years, the District has looked to the construction grants program as
the principal approach to providing a long—term solution to its contribution
to the pollution problems of the Rio Hondo.
Citizen Action . Action by area residents has played an important role in
past enforcement; for example the Committee to Save the Rio Hondo (see chapter
7) was a party to the Assurance of Discontinuance. In the same vein, the
Committee has indicated its willingness to use appropriate legal remedies with
regard to current and future decisions of the U.S. Forest Service, EPA, EID,
TWSD and others. The committee has notified EPA and TWSD of its intent to
initiate legal action under the Citizens Suit provision of the Clean Water Act
‘to obtain prompt and complete enforcement’ of the TWSD NPDES permit.
Summary of Enforcement Issue . Until 1979, all the agencies concerned with
pollution problems at Twining have viewed EPA’s construction grants program as
the primary means for resolving pollution problems in the Rio Hondo. In
accordance with its National Municipal Policy and Strategy, EPA gives eligible
municipalities extensions for complying with the treatment requirements of the
Clean Water Act. These municipalities are placed under enforceable compliance
schedules. After the construction grants process is completed, the muni-
cipalities must comply with the final limit of its NPDES permit.
EID has followed a relatively strong enforcement policy since 1979, one
which has already resulted in significant reduction of organic matter and
bacterial pollution in the Rio Hondo. It also looks to some type of
compliance schedule for resolution of remaining problems.
In conjunction with issuance of a NPDES permit, which would include final
effluent limitations for phosphorus, EPA will probably establish a strict
timetable for completion of the construction grants process. Failure to meet
the timetable would be grounds for enforcement actions. EID has the option to
take enforcement action for violation of state regulations.
The District will be responsible for self—monitoring, a job it can now do
due to its new staffing and laboratory equipment. Since late April, 1981, the
District has done self—monitoring analyses at Twining. In addition, they may
send samples on an infrequent basis (about once a month) to the State Labs, in
order to obtain a double—check on their own analyses. The State will check
the District’s results and do quarterly sampling on its own for any indication
of violated stream standards and for violations of the NPDES permit. If
violations of the NPDES permit or state regulations are documented, EPA or EID
could take enforcement acton.
Continued Public Participation . The District has the alternative of
continuing the involvement of the public In the wastewater planning, construc-
tion and operation process. Public awareness of District plans could help
avoid future misunderstandings and could, solely by keeping people informed,

transform suspicion into productive interest. The mechanisms for such
participation remain to be examined, but could be as simple as posting public
notices about all EPA, District, EID, and USFS actions (newspaper releases
plus use of a Iling list), and providing some basis for open discussion of
those actions which have an impact outside Twining.
5.4.10 Administrative Measures
Federal regulations for EPA funded wastewater treatment projects require
the District to adopt a sewer use ordinance prohibiting certain discharges
and establishing the requirements for new sewers and connections, and a user
charge system and schedule based on flows and wasteloads. These ordinances
would deal with issues discussed previously: hookup policies; flow reduction
measures; rate design. In addition, the sewer use ordinance could continue
the existing practice which bans the use (discharge) of phosphorus detergents
(see Appendix A.4). In general, TWSD has very substantial powers to ensure
effective wastewater management and appropriate water use (both public and
private) throughout the District.
Additional administrative steps have been suggested during the public
participation process, as for example, requests that the resort community
establish an equal opportunity program and limit water rights purchases to
areas with priority rights (Arroyo Hondo). Some of these suggestions are
outside the scope of the powers of a Sanitation District; others represent
TWSD policies not directly related to wastewater. The public participation
process (including the public hearing on the DEIS) provides a forum for
specific recommendations which, if within their powers, may be considered by
the TWSD Board.
The District (TWSD, 1981a) has stated its preferred alternative as
building a new plant of conventional design (alternative 1, Table 5 .-i) at the
existing site with a peak average weekly capacity of 95,000 gallons per day
(alt rnative E, Table 5—5). The District feels this plant would function
reliably under the variety of flow conditions experienced in Twining, and
would be easy to maintain. An aquaculture plant was noted as being appealing
but not an adequately proven technology considering the climatic extremes of
The District feels that 95,000 gpd is necessary to accommodate a minimal
amount of the expected growth. Approval of’ new hookups would depend upon
performance of the new plant.
The District intends to review its decision in light of discussions
presented in the Draft EIS; this document will also be used as input to the
selection of other alternatives (e.g. approach to OSS management, flow
reduction, rate design and quality assurance).

At this time the Citizens Advisory Committee (see chapter 7) has made no
recommendation to the District with regard to the preferred process and
capacity alternatives. Lack of’ consensus reflects the debate described in
section 5.3.
Region VI of EPA has several options with regard to the funding of the
most cost—effective alternative (which may or may not be TWSD’s preferred
1. EPA may decide to provide no funds for any TWSD project.
2. EPA may fund some percentage of the eligible portions of a project
which will treat only existing flows (this could be chosen even if a larger
plant is determined to be most cost—effective).
3. EPA may fund some percentage of the eligible portions of a project
which provides some capacity to treat expanded flows in the future; this could
be the District’s preferred capacity or another capacity.
4. EPA may attach conditions to any grant awarded to the District.
Upon completion of the facilities plan and public review of’ this Draft
EIS, EPA will have the technical information and the public input to evaluate
the situation in Twining and the impacts of’ each option. At that time EPA
will identify its preferred course of’ action. EPA recognizes that its
decision has both a practical and symbolic impact on the growth debate
described in sections 5.3.3 and 5.3.4. As a practical matter, a decision to
fund an expanded facility will make it more economically feasible to develop
in Twining and thus may encourage growth (or at least have some influence on
the timing and form of development). However, a decision of’ funding for
no—growth would not prevent TWSD from implementing its preferred alternative;
rather, it would require that the District incur all of the costs of’ growth.
Similarly, a decision to provide no further federal funds to TWSD would not
relieve the District of its obligation to make improvements to the treatment
plant sufficient to meet NPDES requirements.
If funding is limited to 80,000 gpd plant the costs of any expansion would
be fully borne by the District and by those who benefit from development in
Twining. If’ funding is severely limited (or denied entirely), members of the
District expect that to make up for lost government funds there would be a
need to raise revenue locally through the sale of hookups, thus resulting in
more rapid expansion of the plant than would occur from the hookup policies
described previously (Stagg, 1981a). Alternatively, if the District cannot
fund plant expansion, there may be additional construction of’ independent
plants of the type now proposed by Ski Solar Homes. In either case, costs of
growth would be borne by those who most directly benefit. To the extent that
federal funds now targetted for Twining are not allocated to the District,

such funds would become available for construction grants awarded to other
municipalities on the New Mexico priority list.
EPA will take growth impacts into account in making its decision; however,
many other agency policies and regulations will bear on that decision. EPA
cannot and will not impose a land use planning mandate on Taos County; the
agency’s decision is not intended to provide either practical or symbolic
guidance on how Taos citizens should plan their future.
The EID has funding alternatives similar to those available to EPA, as
well as enforcement options discussed in section 5.4.9. The agency has a
mandatea responsibility to monitor the water quality and ecology of the Rio
Hondo (in conjunction with the U.S. Forest Service), including specifically
non—point sources. EID and USFS also intend to establish air quality
monitoring (USFS, 1981a and l981b).
Alternatives with respect to ski trails, parking and related facilities
were developed and evaluated by the U.S. Forest Service (USFS, 1981a and
1981b); see Table 6—6 of this document. In general, the USFS decision
approved the proposed facilities with some modifications to reduce stresses on
the existing wastewater treatment plant. A skier limit of’ 4800 per day was
approved subject to compliance with water—quality regulations. In addition,
an interim skier limitation of 4050 per day was approved until such time that
sewage problems have been resolved.
The U.S. Forest Service will face specific decisions with respect to
amending the TWSD special permit, in the event an additional acre of land is
required for an expanded treatment plant. The agency normally utilizes an
environmental assessment to define mitigation measures for site—specific
construction impacts. Also, USFS has the responsibility for implementing or
overseeing a wide range of measures to control non-point source pollution from
the trails, parking lots and other facilities at TSV, Inc. and is undertaking
an evaluation of alternatives for increasing the water yield of’ the drainage
basin (USFS, 198la and l98lb).
The general authority of agencies identified in section 3.3 is one of’
independent action, outside the scope of the facilities plan and EIS. As one
example, the Forest Service can address at least some of the regional
environmental problems in its ongoing forest plan for Carson National Forest;
similarly, the County of Taos can assert extensive control over land use in
the Hondo Valley (and elsewhere) if and when it undertakes and adopts a
countywide land use plan and zoning ordinance.


Chapter 5 characterizes the major environmental impacts of the alterna-
tives. Chapter 6 contains information in support of the impact evaluations.
Three types of information are provided: a description of the existing
conditions; explanations of any of the impact evaluations which were too
complex to present fully in chapter 5; and a summary of the beneficial and
adverse impacts which could result from different alternatives. Chapter 6
contains eight sections. The first seven sections concern individual
environmental components, as follows: earth resources (6.1), water
resources (6.2), air and sound quality (6.3), biological resources (6.4),
archaeological, historical, and other sensitive resources (6.5),
socio—economics and land use (6.6), energy and other resources (6.7). Each
of these sections is subdivided and considers, in turn, existing conditions,
impacts of the no—action alternative, impacts of treatment alternatives,
impacts of capacity alternatives, impacts of other alternatives (e.g. on—site
system management, flow reauction, rate design, quality assurance); and
impacts of EPA and other agency alternatives. Section 6.8 summarizes adverse
impacts which cannot be avoiaed, the tradeoff between short and long—term uses
of the environment, and irreversible and irretrievable commitments of
To help make the EIS a concise and useful document, the level of detail is
consistent with the decisions which must be made by TWSD, EPA and others, as
— Descriptions of each environmental component are generally brief with
the exception of sections 6.2 (water) and 6.6 (socio-economics), which are
the principal subjects which bear on prospective decisions and which
relate to issues identified as significant in the environmental review
— The no—action alternative cannot be accepted because it fails to meet
mandatory water—quality objectives; therefore, impacts of this option are
presented in summary.
— Regarding treatment alternatives, several environmental issues were
critical to decision—making and are explained in detail (for example, the
water—quality impacts of snowmaking or the water-supply impacts of
regional alternatives). However, in many respects the environmental
analysI shows no major difference between treatment plants; in such cases
the impacts are presented in summary.
— The major impacts of capacity alternatives can be identified by dis-
cussion of alternatives B (80,000 gpd) and E (95,000 gpd), while the
effects of other options can be summarized through comparisons to these
two alternatives. The assessment focuses on broad issues of growth policy
and community perceptions about prospective development. The growth
analysis considers expansion of Twining as a winter resort, with some

small, related growth in summer use. Should Twining become a major summer
resort, impacts could be much greater than presented here.
— In general, alternatives presented in section 5.4 are intended to
improve the wastewater management system; some have no major environmental
impacts while others have special benefits. The discussions in chapter 6
summarize such benefits and are expanded only when there is a particular
environmental consideration which may influence decision-making (for
example, the water-quality and safety benefits of ozone, which may justify
the higher dollar cost of this approach to disinfection).
— The main decision facing EPA and other agencies is the approval/funding
of specific treatment and capacity alternatives. The impacts of’ these
decisions are described in the specific sections on treatment and capacity
alternatives and are not repeated in detail in the section on agency
Earth resources include terrain, climate, geology and soils.
6.1.1 Existing Conditions
Terrain . Twining is situated in the Sangre de Cristo Mountains near the
head of the Rio Hondo drainage basin (see Figures 3—1, 4—1, 5—1). Terrain is
among the most rugged in New Mexico, consisting primarily of steep mountain
slopes and deep canyons. Numerous live streams exist throughout the area. A
very limited amount of moderately sloping bottom land exists along the river.
Elevations range from about 9300—9400 feet in Twining to 13,161’ feet atop
Wheeler Peak (the highest mountain in New Mexico).
The North and Lake Forks of the Rio Hondo join in the Twining base area to
form the main river. The Lake Fork is the larger stream; it descends north-
ward from Wheeler Peak in a bowl—shaped valley which is less than 1,000 feet
wide. The narrower North Fork enters the main valley from the northeast.
From Twining to Valdez (a distance of 8 miles) the river generally flows
in a narrow, steep—sided canyon, although it widens somewhat near Amizette
(see Figure 5—1). The drainage area above the mountain front is 36 square
miles; the elevation at this point is about 7650 feet. From Valdez to the Rio
Grande (9 miles) the river is cut into the broad, sloping piedmont surface
which adjoins the mountains. Near Valdez and Arroyo Honda the entrenched
valley is relatively wide, while elsewhere it is a small but narrow canyon.
The Rio Hondo joins the Rio Crande at Dunn Bridge; the drainage area at this
point is 76 square miles, and the elevation is about 6500 feet.
Figure 5—1 illustrates the steep terrain within the Twining Water and
Sanitation District (Twso). Slopes range from five percent In the lower
village to over forty percent on the valley sides. Most commercial estab—

lishments are in the lower village on moderately sloping hard ground. Most
condominiums and cabins are either east of Lake Fork Creek on steep, rocky
mountainsides, or are adjacent to Lake Fork. Steep slopes increase
construction costs but generally have not limited development.
Climate . A detailed description of Taos County’s climate is available in
Wilson (1978). Precipitation is highly variable, and in the Twining area
averages 30—35 inches per year, about half of which occurs as summer thunder-
storms. Annual snowfall is 100—200 inches, equivalent to 40—45 percent of the
annual precipitation. Temperatures range from 30°F to 80°F in summer and
from —25°F to +45°F in winter. The frost-free season is normally less
than three months. Sunshine is plentiful, averaging 3,000 hours a year, or 70
percent of the possible hours; measured radiation is nearly 90 percent of that
which would occur under continuously clear skies. Winds tend to be channeled
along the valley, moving up slope as the ground warms in the morning, then
down slope as the ground cools at night. Due to the mountainous terrain,
there is essentially no potential for local temperature inversions.
Geology . The geology of the area is complex. In the mountains the
bedrock is dominated by fractured crystalline rocks such as granite and
quartzite. The valley bottom contains thin, highly variable alluvial
sediments deposited by the present—day stream and/or by Pleistocene glacial
meitwaters. Schilling (1960) contains a detailed geologic map of’ the Twining
area; see also Brown (1971). Mineral resources (mainly gold and copper) occur
in or near TWSD, in the Rio Honda Mining District; the most recent activity
was in 1956 at the Frazer Copper Mine east of TWSD (Schilling, 1960). Because
of the low grade of the ore, there is apparently no active interest in the
near—term development of these resources.
Underlying the mountains west of the area is a sequence of’ alternating
lava flows and alluvial or lake sediments, all of late Cenozoic age. Young
alluvium occurs throughout the wider portions of’ the Honda Valley. For more
information on the geology of the lowlands refer to Wilson (1978).
Soils . Detailed soils data are available from USFS (1971). Soils in the
Twining area are mostly coarse to rocky in texture and tend to be acidic. The
soils are loamy on sloping areas and alluvial in drainageways. Rock outcrops
are common. Figure 6—1 locates the major soil types and slopes. Soils
occuring adjacent to drainageways are of the Cryoborolls subseries (mapped as
CSC) or of’ the Presa—Cryaquolls Association (PYF). These soils are mixed
alluvium up to five feet deep and are slowly to moderately permeable; water
will be readily transmitted through the substrata or underlying bedrock.
Shallow water tables create problems for pipe laying, foundations and on—site
Adjacent to the valley soils, on steeper slopes, is a Marosa—rock
outcrop—rhyolite complex. Sixty percent of this unit is a cobbly loam; the
rest is steeper and consists of granite/rhyolite stoney land. Permeability is
moderate and the underlying substratum or bedrock is relatively impermeable,
resulting in seeps and springs being common. Steep slopes result in a high

Buildings #1,
Creeks & Rivers ...—- -‘
20 - 100%
Figure 6 I
Source: USFS, 1971

potential for erosion if vegetative cover or litter is removed, and they
present a difficult enviroment for construction.
Erosion rates in the Twining area are generally less than two tons per
acre except in disturbed areas (USFS, 1969, l98la and l9Blb). Disturbed areas
include the following:
— burned-over areas, principally at the head of East Gavilan Canyon, which
contains shallow, rocky, highly erodible soils in which some gullying has
— graded areas, such as the Twining base area, which erode at rates of up
to five tons per acre depending on slope, revegetation and other factors;
— road cuts along the Honda Canyon, where steep canyon walls slide or fall
onto the road (especially during freeze—thaw periods) and cause debris to
move directly into the river; road grading contributes to the transport of
material to the stream.
Stream turbidity is adversely affected by all these sources of sediment.
However, the available data (see Table 6—2 and Figure 6—3) indicate no major
turbidity problems in the river; thus, the effects of erosion are probably
episodic rather than chronic.
Revegetation is one means of controlling erosion and is practiced on new
ski trails. Deficient levels of nitrogen and phosphorus have been identified
frequently in the affected soils, and fertilization with these two elements
has been a common practice. Application rates by Taos Ski Valley,
Incorporated (ISV, Inc.) have been approximately 600 pounds per acre of
16—20—0 fertilizer (USFS, 1981a and l981b).
6.1.2 Impacts of the No—Action Alternative
There would be no new impacts on earth resources under the no—action
alternative, except those which may occur as a result of the TSV, Inc. master
plan which is evaluated in a separate EIS (USFS, 1981a and l981b) and which
may occur from cabin construction (see section 6.1.4). Mitigation measures to
minimize impacts on earth sources are discussed in the master plan EIS. Cabin
construction would occur on private land, and so Impacts from this source may
be largely uncontrolled.
6.1.3 Impacts of Treatment Alternatives
Most regional alternatives would involve major construction impacts at new
plant sites and along pipeline routes; several hundred acres would be affected
by implementation of’ alternatives 6, 7, 8, 10, or 11. Table 6—1 characterizes
these Impacts, including effects on soils, terrain, air quality and geology.

* Indicates effects which may be kong—term.
I. Sewer construction
A. Obtaining easements and
B. Site clearing/construction
of access roads*
C. Trench excavation, pipe
laying, and trench backfill
0. Site restoratlon*
E. Other activities
1. Onslte storage of equipment,
pipe, excavated soil
2. Equipment travel to and from
3. Security and safety
4. Support activities
(dust control)
I I. Sewage treatment plant construction
A. Obtaining easements,
rights—of—way, and
acquiring site*
B. Site clearing and access
C. Construction of facilities*
O. Site drainage and grading*
E. Site restoration*
r. Other activities
1. Safety fenclng*
2. Support activities
(dust control)
3. BypassIng sewage
Change In land values; change in land use
Surface change; vegetation change; soil removal and
disturbance; change in visual quality; waste
disposal; equipment operation; traffic
rerouting; possible archaeological and historic site
Surface change; soil removal and disturbance; change
in visual quality; dewatering; blasting; equipment
operation; traffic rerouting; possible
archaeological and historic disturbance; utility
disrngtion or relocation
Surface change; vegetation change; change in visual
quality; waste disposal; equipment operation; traffic
Surface change; change In visual quality
Equipment operation; traffic rerouting
Surface change; change in visual quality; traffic
Change in visual quality; soil treatment; equipment
Change in land values; change in land use;
Surface change; vegetation change; soil removal and
disturbance; change in visual quality; waste dis-
posal; equipment operation; possible archaeological
and historic site disturbance
Surface change; soil removal and disturbance; change
in visual quality; dewatering; blasting; equipment
operation; possible archaeological and historic site
disturbance; waste disposal; equipment operation
Surface change; vegetation change; soil removal and
disturbance; change in visual quality; waste
disposal; equipment operation; possible archaeolo-
gical and historic site disturbance
Surface change; vegetation change; soil treatment;
change In visual quality; equipment operation
Change in visual quality
Soil treatment; equipment operation
Normally not permitted; if required, special facili-
ties constructed
Source: W1150fl U98l).

For most other alternatives, construction of treatment facilities in
Twining would have an impact on only the plant site. For alternative 12
(rehabilitation) the effects would be concentrated on the existing acre of
already altered land (part of three acres of National Forest land used by TWSD
under a permit granted by USFS). For alternatives 1 or 2 the layout of
facilities would require an additional acre of National Forest land which
would have to be acquired through a modified permit. This acre would be
converted from forest land to a building site, through construction of new
wastewater facilities. The impacts of construction at the plant would be
similar to (but much smaller in scale than) those noted in Table 6—1.
Alternatives involving on—site systems would involve more substantial
construction, either outside existing and new dwellings where t.here would be
excavations (alternatives 3, 9), or inside existing dwellings where there
would be major remodeling (alternatives 4, 14).
6.1.4 Impacts of Capacity Alternatives
Alternative B (80,000 gpd) would not preclude considerable new
construction, primarily of cabins; there would be local and small—scale
construction impacts of the type described in Table 6—]. A total of’ five to
ten acres would probably be affected (that is, a few thousand square feet at
each of 94 lots). In addition, most of the impacts associated with the TSV,
Inc. master plan would occur, such as erosion from remodeled parking lots and
from clearing for ski trails and lifts. These impacts are identified in USFS
(l98la and 198lb); soil erosion would increase on up to 69 acres of trails,
5.4 acres of lift corridors, 2 miles of access roads, and 5 acres at the
parking lots. The effects are projected to be a temporary increase in soil
loss from less than 2 tons per acre to perhaps 5 tons per acre; revegetation
and other control measures would reduce erosion to background levels within
three years.
Alternative E (95,000 gpd) would increase these impacts by supporting
additional base—area construction; assuming typical high—density development
two to five additional acres might be affected. (The same impacts could occur
from alternative B if the developers use on—site systems.) IWSO has indicated
an intention to mitigate impacts by requiring proper construction methods and
scheduling, including the following measures: a) use excavated soil to
construct a temporary dike upslope of any exposed areas, so that the runoff
can be diverted around the bare construction site; b) use excavated soil to
construct temporary darns downslope from exposed ares, so that the runoff from
these areas can be contained and de—silted; c) schedule construction so that
earth—moving is not premature, but begins immediately before actual building
of’ the facilities; d) where appropriate, regrade and seed the altered area
Immediately upon c pletion of construction.
The principal earth—resource impacts of additional development in TWSD
would be short—term land disturbance and a temporary inctease in the potential

for turbid runoff’. No permanent or large—scale changes in land stability,
watershed behavior or river ecology would be expected to occur as a result of
the construction.
During the public participation process the question was raised regarding
possible impacts of’ TWSD development on climate; this concern related in part
to a letter by Joan Price, Director of the Colorado Plateau Project, regarding
development in Arizona’s Snow Bowl (Price, 1979). The letter cited studies
which presented evidence of slight temperature rises due to urbanization in
St. Louis, and which discussed a possible impact on electrical and moisture
cycles along with lightning and associated ion movement from timber clearing,
new parking lots and the like in the Snow Bowl area. The state—of—the-art on
climate change is not sufficiently advanced to permit evaluation of this
impact. However, as a general statement it is likely that the effects of
growth in Twining would be negligible at most (and probably zero) and would be
impossible to detect. One ski resort cannot have the effects of urban areas
such as St. Louis, nor can it produce possible global changes in climate such
as may result from fossil—fuel combustion or volcanic eruptions.
6.1.5 Impacts of Other Types of Alternatives
host of the remaining components of’ a complete wastewater system have
little or no effect on earth resources. Impacts from on—site systems and
sewer construction are identified in Table 6—1. Reuse of sludge within the
District could benefit soil fertility, pH and texture; however, runoff of
phosphorus—rich sludge could negate water—quality improvements resulting from
construction of’ an advanced treatment facility. Non—point source management
programs which use fertilizer to promote vegetation growth benefits the
control of erosion but may also add nutrients to runoff; see section 6.2.2.
The use of lime to increase soil pH could also affect water quality
(particularly by enhancing the solubility of phosphorus and increasing the
proportion of unionized ammonia); however, unlike the fertilizer contribution,
calculations indicate this effect would be quantitatively insignificant
(Wilson, 1981).
6.1.6 Impacts of EPA and Other Agency Alternatives
The principal impacts on earth resources would relate to treatment plant
construction - which cannot be avoided if the pollution problem Is to be
solved — and from area growth — which can occur with or without expansion of
plant capacity. Thus, the impacts associated with all of’ EPA’s alternatives
re essentially identical, except as to the scale and location of treatment
plant construction (which would be much greater for regional alternatives).
Also, if EPA were to fund plant expansion, the Impacts associated with new
development in some sense would be encouraged (or at least accepted).

The treatment plant is on National Forest land and TWSD has a special use
permit from the U.S. Forest Service (see Table A—i, Appendix A). If some new
land is required, the permit will need an amendment. USFS will require the
mitigation of construction impacts from plant construction. Based on the
master plan EIS, the agency would require an environmental assessment be
completed prior to construction; the assessment would contain specific plans
for soil stockpiling, revegetation, runoff control structures and other
appropriate measures (USFS, 1981a and 1981b).
6.2.1 Existing Surface Water Quantity
The headwaters of the Rio Hondo have an average elevation of approximately
11,400 feet; thus, annual snowfall and spring runoff are large. Appendix C.l
summarizes streamflow data obtained at U.S. Geological Survey gauging stations
in the watershed. For the period of record the annual runoff from the moun-
tain portion of the basin (above Valdez) has averaged 25,650 acre—feet or 13.3
inches. Figure 6-2 illustrates the seasonal flow pattern in which more than
half the annual stream flow occurs in response to snowmelt from April through
There has been a significant (25 to 40 percent) decrease in the flow meas-
ured at the Valdez gauging station in the last 20 to 30 years (Wilson, 1978;
U9S, l981a and l98lb). Virtually the entire reduction has occurred during
the spring snowmelt period. Analyses of available data have identified
several potential causes of the change. Appendix C.2 summarizes the studies
which have been done, and indicates that revegetation of National Forest lands
is responsible for the bulk of the change. Long—term drought conditions have
also contributed to the decrease. The reduction in flows has had a signifi-
cant adverse impact on downstream farmers. In particular, there is now often
too little water in spring to fully irrigate the soil; in the past such heavy
spring irrigation could mitigate the Inevitable shortage of water in late
summer. These problems are not unique to the Hondo drainage, but occur
throughout northern Taos County.
There Is considerable public Interest concerning the Impact of development
in TWSD on the physical supply of water in the drainage basin. The evidence
indicates that this impact is insignificant and, if anything, on balance a
positive one. The consumptive use of water within the District has been off-
set by retirement of downstream irrigation rights; also, the consumption
occurs primarily in winter, when there is minimal downstream irriqatjon.
While water rights transfers do protect stream flow, they have potential
socio—economlc effects; see section 6.6.6.
Snowmaking by Taos Ski Valley, Inc. may actually improve water supply,
since water that normally would flow downstream in winter instead becomes part
of the spring runoff which is available to Irrigators. The clearcutting of
trails also increases runoff because open areas accumulate more snow than

I I I I I I I I I. I —j—:—
28 —
I U- I I I I I I I I I I
Figure 6-2. Runoff Patterns, Rio Hondo,
New Mexico

areas with tree cover and because there is a reduced transpiration
requirement, due to the tree removal. Trail grooming compacts the snow and
delays runoff slightly. USFS (1981a and 1981b) indicates that the positive
benefits of ski trails are too small to te measured at the Valdez gauging
The 100-year flood hazard zone for Twining has been identified by the
Corps of Engineers (Cunico, 1980) on a map on file at the Forest Service
Supervisor’s office on Cruz Alto Road, Taos. The map indicates that neither
the existing treatment plant nor any occupied dwelling is in a flood hazard
zone. The extent of development compared to the size of the basin makes it
extremely unlikely that the resort has had any effect on downstream flood haz-
ards. A detailed evaluation of low—flows was performed by EID as part of the
wasteload allocations; the results are summarized in Appendix 8.4.
o.2.2. Existing Surface Water Quality
Stream Standards . Stream standards are set by the New Mexico Water
Quality Control Commission, (and must be approved by the State Attorney
General and by EPA). The purpose of the standards is to protect the stream
for particular designated uses. Some standards are general for New Mexico and
are qualitative (e.g., the stream shall be free of objectionable oil, scum and
grease). Other standards are set for particular stream reaches and are
numeric for specific parameters (e.g., pH shall be within the range 6.6 to
Designated uses for the Rio Hondo (and almost all other perennial streams
in Taos County) are: domestic water supply (but disinfection is required
prior to drinking); fish culture; high—quality coidwater fishery (trout);
irrigation; livestock and wildlife watering; and secondary contact recreation
(boating, but not swimming). The numeric standards are listed in Table 4—1;
Table C—2 also lists the standards, along with the stream uses each is
designed to protect and the rationale behind each specific value.
The stream standards were recently revised by the New Mexico Water Quality
Control Commission (1981); however, the standards have not been certified yet
by the New Mexico Attorney General, nor has EPA approval been given. The
changes are:
Old Standards New Standards
Ammonia nitrogen was limited Un—ionized ammonia not to exceed
to 0.2 mg/l. At pH’s of’ the 0.02 rng/l (as N).
Rio Honda, this standard should
keep un—ionized ammonia (the
toxic form) to less than
0.02 mg/i.

Nitrate—nitrogen limited to No nitrate standard. Total
0.8 mg/i. Combined with total inorganic nitrogen not to
ammonia standard, this would exceed 1.0 mg/i.
keep total inorganic nitrogen
less than 1.0 mg/i.
The fact that a stream is better in quality than permitted by the star—
dards does not justify allowing the quality to deteriorate. The official
State policy on such degradation is as follows.
“Degradation of waters the quality of which is better than the stream
standards established by the New Mexico Water Quality Control Com-
mission is not reasonable degradation and is subject to abatement
under the authority granted the Commission by the New Mexico Water
Quality Act, as amended, unless it is justifiable as a result of’
necessary economic and social development. Existing instream water
uses shall be maintained and protected.”
Wasteload Allocations . Under the New Mexico Water Quality Management
Plan, certain streams are designated as “water—quality limited”. The Rio
F -londo has received this designation. When a water—quality limited stream is
being considered for point—source discharge, the New Mexico Water Quality
Control Commission, via EID, does a “wasteload allocation”. For a particular
pollutant, it is determined how much of that pollutant may load (be discharged
to) the stream (at low—flow conditions) before the stream standard is
violated. The effluent limit assigned to the point source discharge is then
set so that the allowable wasteload is not exceeded. For example, the
phosphorus standard for the Rio Hondo is 0.1 mg/i. For low—flow conditions at
Twining, this translates to about 2 pounds of phosphorus per day. Stream
sampling indicates that as much as 1.1 pounds may be contributed by non—point
sources; thus, 0.9 pounds are “left” for the treatment plant discharge. This
means that a 95,000 gpd plant must have an effluent containing no more than 1
mg/l of phosphorus. (Appendix B.4 presents this calculation in more detail;
see also EID, 198ld.)
Wasteload allocations are not necessary for all parameters for which there
are stream standards. For example, a violation of the Rio Hondo dissolved
oxygen standard has never been observed, even when the treatment plant has
been out of compliance. Therefore, it is not considered necessary to do a
dissolved oxygen allocation. Also, as discussed in the next sub—section, EID
has determined that no allocation is needed for nitrogen.
“Secondary treatment” is defined as treatment which removes nearly all
floating solids from wastewater and which reduces each of BOD (biochemical
oxygen demand) and TSS (total settleable solids) to less than 30 mg/i.
because the wasteload allocation has determined that Twining must remove
pL:sphorus, the treatment required is more stringent than secondary, but not
to “advanced waste treatment” levels (BOD and TSS less than 10 mg/i each
and/or 50 percent removal of total nitrogen). Therefore, the treatment level

required in this case is referred to as advanced secondary treatment (AST), in
accordance with PRM 79—7, as revised June 20, 1980 (EPA, 1979e). Under PRM
79—7, any facility plan involving a treatment works providing treatment more
stringent than secondary requires additional review by EPA to ensure treatment
is necessary and will have water quality benefits.
Limiting Nutrient Concept . The purpose of the phosphorus and nitrogen
standards is to prevent excessive algal growth. Some algal growth is
beneficial to a river, since these plants are part of the food chain and
contribute to fish production. But an overabundance of algae can cause odors
and unsightly algal mats (slime) and, in the extreme, deplete dissolved oxygen
and result in fish kills. Algae require a number of nutrients for growth,
including nitrogen and phosphorus. Generally, nitrogen and phosphorus are in
low supply relative to other nutrients such as carbon. Therefore, either
nitrogen or phosphorus usually will be the “limiting nutrient” to algal
growth. If phosphorus is in short supply there will be little algal growth,
no matter how much nitrogen is available, and vice versa. In most water
bodies phosphorus is the limiting nutrient. Municipal wastewater normally
contains a lot of phosphorus; thus it is common for rivers to be algal-rich
downstream of discharge points. In such cases the key to pollution control is
wastewater treatment to remove phosphorus; such treatment is comparatively
easy to accomplish. Where a river is phosphorus—limited the nitrogen loading
is irrelevant (with regard to algal growth) as long as phosphorus loading is
minimized. This is fortunate since treatment to reduce nitrogen is difficult
and much more costly than phosphorus removal. For these reasons, the new
state stream standards state that:
“As the need arises, the State shall determine, for specified stream
segments or relevant portions thereof, whether the limiting nutrient for
the growth of aquatic plants is nitrogen or phosphorus. Upon such a
determination, the waters in question shall be exempt from the standard
for the nutrient found to be not limiting.”
The method for determining whether a stream is nitrogen or phosphorus—
limited consists of a test termed “ algal assay” . To date, ElD has performed
19 such algal assays for the Rio Hondo (Tague, 1981). Most of the tests were
done on water samples taken at HON3 (above the treatment plant), and all
definitely confirm that phosphorus is the limiting nutrient. A series of
assays was also conducted at other stations above Valdez. These showed that,
under present conditions of excessive phosphorus loading, the stream is
temporarily nitrogen—limited just below the treatment plant. At all other
stations the stream was phosphorus—limited. Thus, under the new stream
standards, the Rio Hondo is exempt from the total inorganic nitrogen standard.
Based on these assays it is clear that to reduce algal growth in the Rio
Hondo and improve water quality it is necessary for TWSD to reduce the amount
of phosphorus discharged to the river. The control of nitrogen would provide
no additional benefits yet would raise costs substantially (about one—third;
see Table B—2); it is cost—effective to require only phosphorus treatment and

no nitrogen removal. Thus the wasteload allocations on which plant design are
based involve phosphorus (see Appendix B.4, section 5.3.2, and EID, l981d).
Another cost—saving aspect of the wasteload allocation for Twining is the
seasonal permit (see Table 4—1). The 1 mg/i effluent limitation for
phosphorus is based on winter conditions, when the stream flow is low and
sewage flow is high. However, in the summer stream flow is high and sewage
flow low; therefore, the effluent phosphorus concentration can be higher
without overloading the stream (i.e. the dilution factor is greater). With
this in consideration, the permit requires less phosphorus treatment in the
summer, which means that less money would be spent on operation and
maintenance for phosphorus removal. (The seasonal permit assumes that Twining
will not become a summer resort area.)
Water-Quality Data . Table 6—2 summarizes all available data regarding
water quality in the Rio Hondo watershed. Figure 6—3 illustrates the results
of the most detailed surveys described in the Table. The figure shows that
violations of stream standards occur most frequently at HON8, about 300 yards
downstream from the treatment plant. More than a third of the HON8 samples in
the ‘74—’75 survey and one—quarter to one-third of more recent samples showed
violations of bacteria, phosphorus and ammonia standards. Violations of these
standards are also seen at HON1O, 1.5 miles below the plant, but at HONI2, 6
miles below the plant, no violations have been observed. Some violations of
bacteria and nutrient standards have occurred in the lower reaches of the Rio
Hondo, presumably due to contributions from agriculture, livestock and on-site
systems. At all stations, values for temperature, pH, conductivity and
dissolved oxygen have all been in compliance.
The results of the EID surveys are also illustrated by Figure 6—4, which
shows graphically how different parameters vary in a downstream direction.
HON6, which is the treatment plant outfall, is included on the graphs for
comparison, but stream standards do not apply to that station. Generally,
nutrients and bacteria increase immediately below the treatment plant, then
return to background levels by station HON12, and finally increase somewhat as
the stream passes through the more populated and cultivated lower valley.
Figure 6—4a compares average values for summer (May through October) and
winter (November through April) and shows that the Influence of the treatment
plant is greatest in the winter; nearly all violations of stream standards
occur during the winter months. In contrast, in the lower Rio Hondo higher
f’ecal coliform counts occur in the summer. Figure 6—4b compares average
values for the ‘74—’75 survey against those for more recent sampling.
Generally, water quality at HON8 has been better during the more recent
sampling. This improvement may be attributed to: 1) higher stream flows
providing more dilution of’ the effluent; 2) smaller effluent flows; and 3)
improved sewage treatment. Collectively, the data indicate that at the mouth
of’ Hondo Canyon, except for a small elevation in phosphorus levels, there is
no evidence of the effluent discharged by TWSD.

This table lists data sets which have been gathered regarding the quality of surface or ground water in the watershed, and iden-
tifies major conclusions which can be reached from the data. See also Figures 6—3 and 6—4. Actual data are available from
sources cited or can be obtained from Lee Wilson and Associates, Inc., P.O. Box 931, Santa Fe M l 87501. Most data are contained
In reports on file at depositories listed in Chapter 7.
A. 1974/1975 Survey
EIA (1975) surenarizes an extensive survey of Rio Hondo water quality which was conducted In 1974 and 1915; Appendix C.3 des-
cribes the sampling stations. Major conclusions of the study are illustrated in Figures 6—3 and 6—4 and can be summarized as
1. At most stations the stream standards are not violated.
2. The most notable exceptions occur at station HON—8, which is 300 yards below the outfall of the Twining treatment plant.
There, violations of stream standards occurred about one—third of the time for fecal coliform, chlnrine resIdual, ammonia and
phosphorus. Also, one sample was in violation of the total organic carbon standard.
3. A few violatIons of ammonia and phosphorus standards occurred at station HON—b, 2.4 miles below the treatment plant.
Three fecal coliform violations were found at station HON—b, and one violation each at HON—14 and HON—16.
4. HON—2 and HON-A, both above the treatment plant, experienced violations for ammonia, phosphorus, and total organic car-
5. Average values for temperature, conductivity and pH increase downstream, which is normal.
6. NutrIents, turbidity and fecal coliform all increase significantly at station HON—B, which is only 300 yards below the
treatment plant outfall; however, by station HON—b or HON—l2, the average values are back to levels comparable to those
found above the treatment plant.
7. Possible impacts from agricultural activity in the lower valley are indicated by relatively high values for total
Kjeldahl nitrogen (ammonia and organic nitrogen) at station HON—l6, and elevated fecal coliform levels from station HON-14 on
down. This could reflect higher human and cattle populations along that stretch.
8. Figure 6—4a compares Rio Hondo water quality in the summer and in the winter. Stream quality in the mountain reach is
much pocrer in winter than sumer, as would be expected because of greater sewage plant discharges and lower stream flows,
Station HON—2, above the treatment plant, also shows higher levels of constituents in the winter months. This station Is at
a point in the midst of’ the ski valley, and so probably receives the impact of Increased winter populations (automotive ex-
haust, litter, etc.).
9. All stations showed some high nitrate values; however, nearly all these high values were from samples taken on the same
two dates and are labeled “suspect”. One low dissolved oxygen concentration is reported at station HON—20; it Is also la-
beled “suspect”. These values were not utilized in calculating the averages shown In Figure 6—4.
10. Dissolved oxygen, nitrate, r*I and COD levels remain relatively constant along the length of the Rio Hondo.
B. Mre recent EID Data
EID took a few samples in winter of 1978 and spring of 1979, and since November of 1979 they have taken samples on nearly a
monthly basis. A few changes were made In the sampling program (compared to the ‘74-75 survey). Because It was felt that HON1
and HON2 were too affected by ski basin activities, those stations were dropped; a new station, H0N3, was established on the
North Fork, with the belief that this station more truly reflects background levels. Stations HON1A and HON16 were dropped, and
no analyses were done for turbidity, chlorine residual, total organic carbon, phosphate, or chemIcal oxygen demand.
Figure 6—4b compares ‘74-’75 average values and more recent values for fecal coliforms, dissolved oxygen, phosphorus, and
ammonia. Generally the same pattern is seen in both periods, with values spiking up at HON8, just below the treatment plant,
and then returning to near—background levels. However, the more recent data show the river (and the effluent) to be of better
quality than in 1974—1975. The percentages of samples showing violations of stream standards has decreased somewhat (Fig. 6—3).
C. USGS Data .
Three samples from the stream at State Highway 3 (Hcf l8) were taken by the USGS in 1956 and 1957; analyses were done for sev-
eral inorganic parameters. Samples taken from near Valdez by USGS from 1962 to 1965 provide some conductivity and Suspended
sediment data.
0. USFS Data .
The Forest Service took samples in ‘67, ‘68 and ‘69 from the same site (HON1B) and analyzed for several inorganic constitu-
ents. When these data and USGS data are compared to more recent records there is no apparent change in stream chemistry.
USFS took samples from the upper Rio Hondo (HOt 12 to H0N12) on eleven winter dates from January 1978 to January 1979. These
samples were analyzed for turbidity and fecal colifores; on one date, counts were also done for fecal streptococci. Few bac-
teria were detected above the treatment plant, relatively high numbers were seen at HON8 and HON1O, and numbers were again small
at -4ON12. There was one violation of stream standards for fecal coliforms at Hc 8, and three violations at I-4OtJlO.

F. HIM Data .
In October of 1978, the Bureau of Land Management started a monthly sampling program on the Rio Rondo usf above its con-
fluence with the Rio Crande (HON2D). The data are stored by USGS as station 08268500 (Arroyo Rondo at Arro n 1Ondo). Snalyses
have been done for a large number of parameters, Including major cations and anions, metals, nutrients, and dissolved gases.
One or two violations of stream standards have been observed for turbidity, pH, ammonia, nitrate, phosphorus, total organic car-
bon, and fecal coliforms. Several zinc values have been over 0.05 mg/I, the recommended limit for drinkino water.
In the early fall of 1979, Cramer, Callahan and Associates collected sarv les at stations HON4, Hf 8, H l2, H1 ’ (l4, -W ll8 and
110N20 for the TWSD. The samples were analyzed for ROD, total phosphorus, pH, fecal and total coliforms, and Suspended Solids.
Values were highest at HON8 for all parameters except pH and suspended solids. The stream standard for phosphorus was violated
at these stations.
C. Metals Data .
On April 8, 1980, EID analyzed sa’nples for arsenic, barium, cachniun, chromium, lead, mercury, selenium, and silver. All val.-
ues were below detectable limits, except two cadmium and one lead, which were right at detectable limits (0(101 mg/i and 0.005
r ig/i respectively, which are below recommended criteria).
Since September, 1980, samples have been collected on four dates by the Forest Service and analyzed by Moiy ( orp for iron,
manganese, zinc, molybdenum, copper, lead and cadmium. t’cst values have been below detectable limits. The most notable excep-
tion is zinc. Except for the September 2 sampling date, nearly every zinc value at every station has been above EPA criteria
for protection of aquatic life (0.01 mg/i), and many have been above the criteria for drinklno water (0.05 mg/I). Two or three
excessive values have been observed for each of iron, manganese, and lead. Natural weatherlnn of minerals (e.g. in ore
deposits) Is the probable origin of these metals; the reported levels are not unusual In u.S. rivers. High zinc concentrations
could be a factor limiting the reproduction of cutthroat trout in the stream (Wilson, 1981).
H. Drinking Water .
Records are on file at ElD for the community water systems in Twining, Des Montes, Valdez, and Arroyo liondo. Except for
Iwining, these systems pump their water from wells, so that the data reflects ground water quality, which is generally very good.
Lee Wilson and Associates collected eight samples from private wells in Valdez and Arroyo Rondo for the Taos County Future
Water Issues report. Six of these samples were positive for total and fecal coliforms, possibly due to contamination from on-
site systems.
1. Other .
There are no data on several types of contaminants. These include viruses and parasites, both of which are probably present
to a limited extent, as indicated by the slightly elevated levels of bacteria. Surfactants, reflecting detergent discharges,
have never been measured; EID has noted no evidence that this type of pollution is significant In the basin (Tague, 1951).
Trace chemicals - such as trihalomethanes - have not been measured and would not be expected to occur unless from natural
sources; while trihalomethanes are produced by chlorination of fresh water, they are not an important product of wastewater
chlorination (WIlson, 1981).

HON 10
r74-’751oIoJo1 j
17475 10 1013 Ii- 1
I’798 1 10 101010 ]
[ 14-’75 0 0 7 3
Er -Tho 000
f 4-’7513I 0 42 381
179-81125 0 253 j
r74-75 2 0 16 6
I 7 -8I00I55
HON 12
Jii -si 0 0 001
HON 14 L74’751 5 1 0 I 4 1 01 NOTE: Numbers indicate the percentage
of samples which showed violations
HON 16 174-’751 5 1 0 1 0 I oj
HON 18 [ 4-’75 0 0 ofol
1-79-’8 1 14 0 7 1141
H0N2og4 9 g
IC IoTöl
I o 16 lo 1

2, 0 10
I? IS 16 8 zo
-o .___ -•
0 I? II. 6
— 0.6
: : :
14014 HON
6 0 I I 2
6 8 20
The spacing of stations on these graphs is riot proportional
to their actual distances(see figure 6-3).
= 0.8
- 0.7
14010, AMIIONIH .00015 ARE 10201
UN-IONIZED 01410010 lEVELS W00t0 BE
.4 lOS
I 2 5 6 0 10 12 IS 16 IA 20
IA 20
._ —v

•N\ \• /
6 8 ID I? 4 6 ID TO
. . .
, .-
,.2 —

..-. $
I 3 2
lO ll
— — — U— — — — —
.—. ----.----- -
I 3 7 5 F Ill I’ II I 16 8
I 3 2 4
The spacing of stations on these graphs is not proportional
to their actual distances(see figure 6-3).
HON 6 is treatment plant effluent:The data for it summarized
here is EID surveillance data, not compliance data.
3 31 a
6 0 0 12 IS IA
ID 20
_. .._.,.. ...4__1 97 L _ 75 data
..i—S—I-1979’81 data
I 3 2 4
TOTAL 11110 1 1 1A
U -

Impacts of Existing and Past TWSD Effluent Discharges . Residents
downstream of the treatment plant have expressed concern that Twining’s
effluent may be degrading the Rio Hondo so that it is less suitable for
irrigation, drinking, recreation, livestock watering, and support of fish and
wildlife. Complaints have been made that: the river ecology has been harmed;
irrigation water does not penetrate into the ground as quickly as it used to,
and more frequent watering of the fields is necessary; health problems,
associated with drinking water, have been experienced; cattle deaths and horse
illnesses have occurred; both recreation in the river and irrigation using
river water are less pleasant and/or feasible due to slime and suds; dead,
sickly, and bad—tasting fish have become more common in the last few years;
ducks and geese are seen less frequently along the river; and riverside
vegetation is dying.
All complaints were investigated as fully as possible. Three types of
impacts were either definitely or presumably tied to Twining’s effluent. 1)
Significant degradation of Rio Hondo biology occurs for a distance of about
two miles below the plant; this impact is discussed in section 6.4.1 and does
not extend into the lower reaches of the I io Honda. 2) Algal growth
stimulated by nutrients from TWSD and by nutrients from other sources has a
nuisance impact on recreation and farming throughout the length of the river;
this impact is also discussed in section 6.4.1. 3) While specific
water—related health impacts were not verified, they are certainly possible
for any persons who drink surface water without adequately disinfecting it.
To the extent that TWSD contributes pathogens to the river, this impact would
be increased; however, TWSD’s contribution would not be the sole cause of this
None of the other problems could be attributed to the effects of TWSD’s
sewage plant. Possible explanations for these problems are given in Appendix
C.4. On balance, the major impacts of TWSD effluent have been to interfere
with the ecology of the river. There has been unacceptable degradation of the
quality of a high—mountain stream, as reflected by major changes in aquatic
biology below the treatment plant and as shown by algal nuisance problems
further downstream. No evidence has been found that there have been
significant economic or public health impacts from this pollution.
Significance of Non—Point Sources . Nutrients, salts and other
constituents enter the Rio Honda from many diffuse sources, as well as from
TWSD’s treatment plant. Such ‘non—point’ sources include runoff from
agricultural areas (containing fertilizer nutrients, livestock pathogens and
even pesticides), sediment from disturbed areas, and ground water containing
septic tank effluent. These sources play an Important role in determining the
overall quality of river water and must be evaluated in order to determine the
extent to which clean up at a central treatment plant will benefit the
enviroment. Appendix C.5 provides a general discussion of these sources in
the Honda Valley; see especially Table C—4.

The impact of non—point sources on phosphorus levels in the upper Rio
Honda (within TWSD) was explicitly considered in the wasteload allocation
process described in this section, in section 5.3.2, and in Appendix B.4.
Non-point sources of phosphorus within the District are summarized in Appendix
C.6; see especially Table C—5. The background level of phosphorus is about
0.005 mg/i. As the river flows through the base area, phosphorus increases to
0.02—0.03 mg/i; thus, non—point sources have at least a four to six—fold
impact. The principal sources of this pollution (which is 20 to 30 percent of
that allowed by the stream standards) Include: runoff from natural forest
land; runoff containing fertilizers used on ski trails; runoff from parking
lots and developed land in the base area; and effluent from septic tanks. The
effect of the latter has been noted during ElD field surveys, which have found
algal growths in the Rio Honda at approximately the point where the effluent
from the Kandahar septic tank and dry well enter the stream. Collectively,
the existing non—point sources of phosphorus and other pollutants are
responsible for significant degradation of the river as it passes through the
resort complex; this is reflected by a deterioration In stream ecology (see
section 6.4.1).
Similar Impacts occur in the lower Hondo where livestock wastes and
on—site systems are probably a significant source of contamination. The data
in Figures 6—3 and 6—4 suggest that these sources already approach a magnitude
capable of threatening or exceeding the stream standards for some parameters.
The specific question of downstream phosphorus problems is discussed in
section 6.2.6.
6.2.3 Ground Water Quantity and Quality
Wilson (1981) discusses ground—water conditions throughout Taos County.
Ground water occurs in two types of’ aquifers in the Twining area: in the
fractures of the bedrock; and in the pores of the valley alluvium. In the
bedrock, aquifer flows may be significant where the rock is extensively
fractured, but quite commonly the rock is tight and yields little flow. In
the alluvium, the varied nature of the material provides a moderately
effective medium for water storage, and small to moderate—yield wells can be
developed in many parts of the area. For both aquifers rates of recharge are
high because of the Infiltration of snowmelt. The high recharge rates are
reflected by a high water table, which in turn accounts for the problem of
sewer line Infiltration; building construction is also hampered because of wet
conditions on most sites.
The natural flow path Is toward the Rio Honda; any ground water not
intercepted by wells eventually reaches the river and becomes part of the
stream flow. The close relationship between surface and ground water has been
demonstrated by analyses made for this EIS (jenkins, 1981). Standard
techniques were used to calculate the effects of discharges to or pumping from
the aquifer. The analysis Indicates that the ground—water flow in the area
averages between 10 and 15 feet per day, which is quite rapid due to the steep

water—table gradient. Any wastewater (such as septic tank effluent) which
reaches the water table would flow rapidly to the river, reaching it between 1
week and 3 months of discharge (depending on whether the discharge was 100 or
1000 feet from river). Similarly, pumping of the aquifer results in very
rapid transmission of the effects to the river, effectively diminishing stream
flow by 90 percent of the amount pumped within a few weeks. The remaining 10
percent would be reflected by diminished stream flow over a period of up to 1
year after the pumping.
In effect, the aquifers serve as a rapid ‘flow-through’ system by which
some snowmelt and rainfall reaches the river. The impact of septic tank
discharges or well pumping is rapidly transmitted to the river; the effects of
discharge or pumping on the aquifers are relatively small and localized. The
water table in the mountain area has not declined as a result of development;
this is shown by the fact that there has been no decrease in stream flow in
late summer and fall (see Figure 6—2), a time in which most or all of the
river water originates as ground—water discharges.
In the lower Hondo Valley the aquifer system is different, generally being
much better in terms of water yields, but lacking the high rates of recharge.
The effects of discharges to or pumping from the aquifer are directly felt at
the river, but over periods of several months or years (depending on
distance). Thus, while the water table may drop slightly as well pumping
increases, the main effect of ground—water diversions is to reduce stream
flow. The historic decline of runoff may have caused the water table in the
area to decline slightly. However, a major regional decline in the water
table would never occur so long as river flows remain significant.
Ground—water quality . The limited data on ground—water quality (mostly
for community water systems) indicates that the resource is in good
condition. However, Wilson (1980) reports bacterial contamination of several
private wells in Valdez and Arroyo Hondo; these are presumed to be caused by
site—specific contamination from livestock wastes or on—site systems.
6.2.4 Water Supply and Water Rights
Runoff in the Rio Hondo is the source of the TWSD water supply and is used
extensively in the lower valley for irrigation purposes. The stream is also a
high—quality fishery. Within the upper Hondo Canyon some domestic wells tap
the alluvial aquifer to provide a domestic water supply. In the lower valley,
ground water is the source of virtually all domestic water, through individual
wells and community water systems.
Twining Water System . Most of the resort complex obtains water from the
community system owned and operated by TWSD and the Pattison Trust. Those few
residents who are not hooked up to the system are served by domestic wells.
Appendix C.4 contains information on the community system, which takes surface
water from the Rio Hondo. The system has one unusual feature — large

diversions are made for the purpose of keeping pipes full of flowing water
during winter, thus avoiding freezing. This so—called bypass flow is
apparently discharged back to the river directly or indirectly, without any
human use.
Water Use . There are three major categories of water use at TWSD:
domestic (for the commercial facilities and cabins); by—passes; and
snowmaking. Complete records on the amounts of use are not available,
although In the last two years the New Mexico Water Resources Division (WRD,
also known as the State Engineer) has investigated this matter, required
improvements in metering, and made an estimate that in 1980 the total water
diverted was 141.1 acre—feet (Cooper, 1981). Independent estimates of water
use in the District were developed as part of the facilities planning process,
based upon information supplied by Twining residents and measurements of
sewage flow. The methods used for this work are described in Appendix C.8.
The results can be expressed in teniis of’ the per capita water use and sewage
flow, as follows:
Diversion Use Return Flow
Day skiers and 14 4 10
Overnight residents 71 21 50
and employees
When these numbers are used in conjunction with population data, the annual
use is estimated to be 31.1 acre—feet/year (AFY) for diversions, of which 21.8
AFY Is returned as discharges from the sewage plant and on—site systems and
9.3 AFY is consumed (see Appendix C.8).
Bypass flows may be as large as 532 AFY, mostly for the cabins (see
Appendix C.8). However, based on the WRO study, in 1980 the bypass could not
have been much greater than 105 AFY. Further study by WRD is expected to re-
solve this apparent conflict. Water use for snowmaking can be estimated based
on the operational characteristics of the equipment used. In a typical year,
about 5 AF would be diverted (SEO, 1980); 10 to 30 percent of this, or 0.5 to
1.5 AFY, would be consumed (see Appendix C.8).
All together, the water use is estimated as follows (all values in AFY):
Domestic By—Pass Snowmaking Total Water Use
Diversions 31.1 105 — 500 5 141.1 — 536.1
Return Flow 21.8. 105 — 500 3.5 130.3 - 525.3
Consumption 9.3 0 1.5 10.8
Water Quality . The TWSD water supply is of good quality, reflecting the
basic good quality of the Rio Honda. However, as with all water supplies,
complete disinfection is sometimes a problem. On four occasions in 1978 and

1979, bacterial non—compliance (levels more than 5 per 100 milliliters) was
evidenced in the monthly water samples. EID has noted possible increas d
problems associated with the on—site system which serves the Schwendi facili-
ties, upstream from the public water supply. A Separate problem was experi-
enced in September, 1980, when runoff from a nearby disturbed area (active
trail construction work) carried sediment into the system, causing excessive
turbidity levels.
Water Rights . Water rights for the Twining water system are leased from
their owner, the Pattison Trust; prior to purchase by the Trust the rights
were used for irrigation in the lower valley. These water rights are consi-
dered secure, assuming continued renewals of the Pattison Trust lease. In
1976, the District Court issued a partial final decree in the adjudication of
water rights on the Rio Hondo. The Court Order allows the Pattison Trust to
divert 218.2 acre—feet per year (AFY) from the Rio Hondo and to consume 10.91
AFY. This decision is somewhat unusual because dorrestic use of water normally
consumes at least 25 percent of diversions, and return flow (sewage dis-
charges) is less than 75 percent of diversions. However, the Court Order ac-
knowledges a different ratio: because most of the water used in the District
is by—pass flows, which return directly to the river, it is assumed that only
5 percent of water diverted is actually consumed. The Pattison rights are
junior in priority to rights such as those in Arroyo Hondo. According to New
Mexico law, during a water—short year, those with senior rights should obtain
a full water supply and those with junior rights should bear the shortage.
However, the only mechanism for enforcing this rule is for the state to
appoint a water—master; this has not been done in the Hondo watershed.
Based on the WRD study, 1980 diversions and Consumption for domestic and
by—pass use are within the limits of the permit. The studies made for the EIS
concur with the possible exception that by—pass diversions may exceed the lim-
its. At present there is no formal permit for snowmaking operations, and di-
versions for this purpose have been stopped by order of the State Engineer
dated February 11, 1981 (see Appendix C.8).
Taos Ski Valley, Inc. (TSV, Inc.) owns two parcels of land with irri-
gation water rights on the Rebulse ditch which diverts from the Rio Honda.
These parcels, which for now remain in cultivation, are 10.9 acres and 4.25
acres, and collectively have consumptive use rights of 18.94 acre feet per
year. If TSV, Inc. can demonstrate to WRD that its use is allowed by the
existing Pattison permit, then consumptive use authorized under that permit
would amount to 10.8 AFY, just below the allowable limit. Otherwise, TSV,
Inc. can be expected to apply for a separate permit to divert Rio Hondo water
for snowmaking; this will require transfer of at least some of the irrigation
rights (and retirement of the existing use to exactly balance the new use).
The transfer is subject to administrative procedures of the State Engineer;
owners of other water rights in the watershed have legal standing to protest
the permit. The impacts of this retirement are discussed in section 6.2.7.

TWSD has been allocated 15 AFY of San Juan—Chama Project water. The
rules for use of this water are complex, but basically they could be used by
Twining only in the winter, and only if TWSD can demonstrate that river flows
in this period are in excess of the needs of Irrigators in the lower Hondo
Valley. The rights probably could be used for snowmaking, so long as all
diversions were outside the irrigation season which would have an impact on
the river throughout the spring and summer snowmelt period.) The alternative
of physically punping the water from the Rio Grande to the Ski Valley would be
extremely expensive and is not considered practical.
If project water cannot be used in Twining, it is certain that there will
be a need to obtain and retire irrigation rights in order to accommodate ex-
pected growth and increased water use (see section 6.2.7). TWSD would have to
obtain such rights in the marketplace; the District lacks municipal powers to
condemn water rights. Small amounts of water rights held by the Forest
Service for grazing purposes would not be available to the District (LaSalle,
Proposed Upgrading . TWSD is proposing to upgrade the water system by
regular maintenance of’ the main water meter, complete metering of all indivi-
dual users, replacing the Beaver Pond infiltration gallery, placing the exist-
ing 50,000 gallon storage tank into service, adding a 200,000 gallon fire
protection tank, repairing or replacing some connecting pipes and burial of
bypass lines to at least a 5 feet depth (BLL, 1980). The development of a
ground water source Is being considered, either at a location just below the
Schwendi restaurant or along the river above Beaver Pond. Further development
of’ Schwendi infiltration gallery has been proposed, since it has proven to be
the most reliable surface water source.
Downstream Use . In the Rio Hondo basin twelve Irrigation ditches (ace—
qulas) have 6,836 acre—feet of diversion water rights for 2,735.7 acres of
land; consumptive use rights are 3,424 AFY in a full—supply year. To meet
this demand the Rio Honda would need to sustain a flow of 15 to 20 cfs at the
Valdez gage. As shown by Figure 6—2, flows of this size have never been
common late in the irrigation season and the situation has worsened consider-
ably due to the overall reduction in stream flow. A water storage project of
some type would be required to accommodate all irrigation needs of the valley
(Wilson, 1978). Small amounts of surface water are used for domestic pur-
poses. Some domestic supplies come from six mutual domestic water systems
(Including the Twining System) which collectively divert about 190 AFY and
consume about 57 AFY. The remaining, larger portion of the domestic supply is
provided by individual wells, which are estimated to account for a diversion
of about 342 AFY and consumption of 103 AFY. Miscellaneous water uses, such
as for stock watering, fish and wildlife, etc., divert 19 AFY, 18 of’ which is
consumed. Total diversion Is thus 7,387 AFY with consumption calculated at
3,602 AFY. Irrigation accounts for 95 percent of’ total consumptive use. The
total water needs of the area are significantly less than runoff in the Rio
Honda, even In a dry year. The main problem is, as shown In Figure 6—2, that
too much of the runoff occurs in too short a time and there is not enough

water late in the irrigation season. The only practical solution to this
problem is construction of a storage reservoir above Valdez; such reservoir
was evaluated and rejected (for reasons of geology and economics) in a study
made by the Bureau of Reclamation (Wilson, 1978).
Additional data regarding water use are given in Wilson (1980). This
reference projects future uses in the area. The major change is expected to
be an increase in domestic use amounting to 18 additional acre—feet consump-
tive use from domestic wells and a 10 Afl’ increase for mutual domestic
systems. These numbers are only approximate, but do indicate that even with
expected growth (and possible additional retirement of water rights), irriga-
tion will still account for 94 percent of the authoriLed consumptive use in
the basin.
6.2.5 Impacts of the No—Action Alternative
The no—action alternative would provide no improvement in water quality;
this is the principal reason why it is considered unacceptable. Most and
perhaps all of the impacts of growth (see 6.2.7) may occur with or without any
improvements to TWSD’s wastewater management system. Implementation of the
ISV, Inc. master plan would have substantial potential effects on non—point
source pollution, which would be offset by mitigation measures to be enforced
by the Forest Service. Additional trails would increase runoff slightly
(nearly 80 AFY in the long—run).
6.2.6 Impacts of Treatment Alternatives
This section emphasizes two subjects: water—resource impacts which were
a major cause for the rejection of many of the treatment alternatives and
which were not fully explained in section 5.2; and the impacts which relate to
those alternatives still being considered.
Regional Alternatives: Water—Rights Impacts . Most regional alternatives
would remove TWSD’s wastewater from the watershed; the District would need
water rights to offset this impact and ‘keep the river whole’. Based on the
calculations made here, approximately 22 AFY of consumptive use rights would
be needed if all existing return flows were eliminated. This negative impact
is a major reason why public testimony opposed the regional options.
Snowmaking: Water—Quali4i Impacts . The water—quality impacts of snow-
making (alternative l5A) are difficult to analyze. The assumption is that the
effluent from a treatment process such as alternative 1 would be very clean,
containing only small amounts of pollutants such as phosphorus. If Twining
remains a typical ski resort, the major discharge of effluent would occur In
winter (December—March). If effluent is used for snowmaking, the discharge
period would change to the spring melt/runoff season (March-June). The impact
of this change depends on the rate of runoff during the spring melt season.

If the effluent—snow melts slowly, the pollutants will be adequately diluted
by river flows and there will be no violation of standards. If the melt is
fast then pollutants may reach the river too rapidly (that is, faster than
would be allowed by the standards).
To evaluate water quality conditions, a worst—case analysis was
performed, with the following assumptions:
1. 40 acre—feet of’ wastewater would be used for snowmaking during the
winter (this represents a year of reasonably good business);
2. due to its relatively low elevation and greater solar exposure, the
snow containing the wastewater will melt off early in the runoff sea-
son (specifically over a 60—day period in March and April);
3. there is no phosphorus removal during runoff.
Calculations made on the basis of these assumptions show that stream standards
would be exceeded (Wilson, 1981). The same conclusion is reached for another
worst case, in which the runoff occurs in wetter months (May or June), but
over a 30—day period instead of sixty days. In short, if a winter’s worth of
phosphorus reaches the stream during a relatively short period in the runoff
season, there will be too much phosphorus in the river. By definition a
worst—case analysis may overstate impacts; for example, snowmaking snow is
used as a base and has a tendency, because of its density, to melt slower than
natural snow. However, the analysis suggests that it would be extremely
difficult to guarantee success in the use of a large-scale snowmaking alter-
native. In particular, there is a significant probability that the phosphorus
from four to five months of resort activity might reach the river in one to
two months of runoff.
Snowmaking: Water—Supply Impacts . Snowmaking has three separate effects
on water supply.
1. About 40 AF of wastewater would be discharged during the spring runoff
season instead of the winter low—flow season. If the runoff occurs in a
30—day period (see assumptions in water quality discussion) and if that
30—day period was the driest runoff month in recent history, then the
effect of snowmaking would be to increase the water supplies available
downstream by 2 percent, a small but not trivial amount. In a more typical
(median) year, the effect is somewhat less than 1 percent. In most years,
not all of the early runoff is diverted downstream and there would be few
if’ any benefits from the increased runoff.
2. A portion of the snow would evaporate (or sublimate) prior to runoff.
This would reduce the amount of water available in the Rio Hondo late in
the irrigation season. TWSD would have to obtain and transfer water rights
in order to offset this effect; as discussed previously, such transfers are
considered to have a significant adverse soclo—economic impact.
3. In very wet years, the effect is to increase what may already be exces-
sive (flood flows). The actual size of the effect would be on the order of

0.2 percent, an amount so small that there should be no increased flood
All these effects occur from conventional snowmaking (using fresh river water).
Total Recycling: Impacts on Water Supply . Total recycling (alternative
13) is often viewed as a technique to promote water conservation. However, it
actually does not change river flows as the following chart shows. (For con-
venience, the chart assumes a water need of 100 AFY; this arbitrary number is
not intended to be a projection of actual water requirements).
Normal Water System Recycling System
1. Water needed 100 100
2. Recycled water (=8) 0 70
3. Diversions (1—2) 100 30
4. Water available (2+3) 100 100
5. Consumed (assume 30% of 1) 30 30
6. Wastewater (4—5) 70 70
7. Returned to stream 70 0
8. Recycled to system (6—7) 0 70
9. Diversions — Returns (3—7) 30 30
10. Decreased stream flow (=9) 30 30
Both water systems decrease stream flow by 30 acre—feet. The only difference
is that total recycling eliminates the water—quality effects of water use.
Impacts of Total Recycling on Public Health . EPA and EID regulations and
policy prohibits the direct recycling of treated wastewater into a drinking
water system, on the basis that it poses unacceptable risks to public health.
Thus, alternative 13 could not be implemented. Citizens have questioned why
the same logic does not apply to discharge of the wastewater to the river,
where it may become a drinking water supply downstream. This question is
difficult to answer, for as a recent EPA-sponsored project has shown, the
water—resource community applies a double standard when it comes to defining
the safety of drinking water (see EIS on the Northeast El Paso Wastewater
Facilities, EPA, 1980). The most critical problem of direct recycling Is that
virus survival and infection may be higher if reclaimed water Is put directly
into a water system and consumed shortly after the wastewater was treated than
if the same water is discharged to a river and not consumed for many hours or
several days. Otherwise, differences in the regulation of direct recycling
versus use of a river which receives some wastewater are based largely on
psychology. This difference in attitude is widely described in the water-
resource literature. Increasingly, it is stated that a single standard for
‘safe’ water is needed, which would probably allow direct recycling (if virus
removal can be assured), since any other standard would render unacceptable
the many water supplies which divert rivers which contain some wastes.
Impacts of Improved Treatment on River Quality . The alternatives still
considered potentially the most cost—effective (numbers 1, 2 and 12) all

produce effluent of similar quality, capable of meeting the standards listed
in Table 4-i. If the facilities are properly designed, built and operated
there should be no violations of the stream standards as a result of TWSD’s
There are three major improvements in water quality which can be expected
from the new facilities. First, there are many contaminants which should be
controlled by the existing facility, but for which violations occur due to
limitations in facility design, construction and/or operation. A new (or re-
modeled) facility should virtually end these violations and in general produce
a better quality and more consistent effluent than the present plant. Second,
the improved disinfection processes should significantly improve stream
sanitation, through a more effective bacteria, virus and parasite kill.
Third, the present violations of the phosphorus standards should end.
However, because: a) non—point sources are significant; and b) the stream
standards do not mandate pure water, the river would not be completely clean.
The improved water quality should produce an improved stream ecology with-
in one or two years. The ecology of the river below TWSD would improve but
remain somewhat degraded when compared to natural conditions (see section
6.4.3). This degradation results from the presence of the resort complex and
could be ended only by complete control/treatment of all runoff from all de-
velopment in the area. Algal growth in downstream areas would be reduced but
not eliminated. Complete elimination of such growth, if possible at all,
would require not only complete controls of pollution within TWSD, but com-
parable controls downstream. However, complete algal suppression is not
desirable, since algae are a food source for fish and other organisms. Some
algal growth is beneficial. Even with the very major improvement in river
sanitation, the river will be a safe source of drinking water only if it is
properly disinfected. Similarly, direct contact recreation would still pose a
very small risk of health impacts.
A major concern of downstream residents Is whether or not the reduction in
phosphorus discharged from TWSD is sufficient to protect the lower part of’ the
river, if and when there is growth In that area. EID has assessed this point
by estimating the ‘unused phosphorus wasteload allocation’ which will be
available In the lower valley once new facilities in Twining are in compliance
with the regulations. The results are given in Appendix C,7. It appears that
25 to 50 percent of the downstream phosphorus allocation has in effect been
allocated to Twining. EID concludes that this allows for considerable
downstream development before there Is a threat to the stream standards
(Tague, 1981). However, as noted in the Appendix, a worst-case analysis sug-
gests that if downstream wasteloads are not carefully controlled, there could
be significant deterioration in water quality in the lower Rio Hondo within
several years, possibly to the point that standards would be violated. In
particular, the present policy of not requiring phosphorus control on new
point sources (e.g. Hacienda condominiums) could use up the waste assimilation
capacity of the river very quickly.

6.2.7 Impacts of Capacity Alternatives
Water Quality . Development in Twining increases the total volume of sew-
age which must be treated. With increasing volume comes: increasing costs of’
treatment; increasing need for reliable technology; and increasing impacts if’
treatment is ineffective. However, the basic premise of the water—quality
regulations is that enforcement will assure that the costs are paid, that
reliability is an accomplished fact, and that the impacts do not occur. For
this reason, the probability is that plant size will not directly influence
water quality.
Development will increase non—point Source loadings, however, which could
cause deterioration of water quality. The control programs (such as runoff
management) discussed in section 5.4 would be intended to minimize this
impact. If they are implemented and work as intended, the quality of the Rio
Hondo should improve over and beyond the effects of having a better treatment
plant. If the programs don’t work, there would be degradation of’ the river
(see 6.4.3). However, in the case of the most critical pollutant, phosphorus,
this impact would not exceed the degradation allowed by the state stream
standards. This is because the wasteload allocations (Appendix B.4) are based
on a worst case and assume a doubling of pollution from non—point sources as
well as a plant no larger than 95,000 gpd.
One special non—point source is lead and other contaminants In vehicle
exhausts. Section 6.3.4 indicates that traffic levels along Highway 150 may
double over the next several years (mostly because of off—peak traffic, not an
enlarged treatment plant). This would double pollutant loadings which might
reach the Rio Hondo (although this would be partly offset as a higher portion
of the cars have modern pollution controls). While the change is adverse,
based on the existing impacts of traffic (see Appendix C.5), lead and related
types of contaminants would still be at barely detectable levels in the river,
and not at concentrations for which health or ecological problems are of con-
Water Supply . The water—supply needs of Twining, and especially water
rights requirements, are certain to increase as a result of Increased off—peak
visitation, cabin development, and (if alternative E is adopted) an increase
in the skier limit and commercial overnight facilities. Expansion of snow-
making would also have a signIficant impact if and when it occurs. Adoption
of water—conservation measures (see 5.4.6) is the primary means of mitigating
the impact.
The following chart indicates future water rights requirements (in
acre—feet per year) of TWSD and/or isv, Inc. if: a) development occurs to the
level compatible with a 95,000 gpd plant); b) snowmaking efforts double as
compared to present levels (and WRD does not change Its position that
snowmaking has a 30 percent consumptive use); c) water conservation is
extremely effective, nd all new development requires one—third less water
than existing development; and d) there is no major increase in water used for
by—pass (this might be true if pipes are buried sufficiently).

Domestic By-Pass Snowmaking Total Water Use
Diversions (AFY) 75.5 105 — 500 10 180.5 — 580.5
Return Flow (AFY) 52.9 105 — 500 7 158.4 — 558.4
Consumption(AFY) 22.6 0 3 25.6
The total increase in consumptive use would be from 10.8 acre—feet per year at
present (including snowmaking) to 25.6 AFY. Of this, 4.9 AFY would be avoided
if alternative B (80,000 gpd) Is selected Instead of alternative E (assuming
that somehow this choice would prevent growth). That is, most of’ the Increase
is due to off—peak visitation, cabin development and snowmaking; relatively
little is caused by increases In the skier limit and expanded overnight
capacity. On the other hand, should Twining become a yearround resort, water
consumption could be 5 AFY more than Indicated above.
The State Engineer will not allow this increased consumptive use unless:
a) it Is accomplished by individual domestic wells which have an inherent
water right of 3 AFY; or b) It is offset by the transfer (retirement) of’ sur-
face water rights in an amount equal to the effect. TWSD does not propose to
use domestic wells, and therefore must transfer water rights. The increase In
domestic consumptive use Is less than the quantity of San Juan-Chama Project
water rights held by TWSD. The Increase In total consumptive use is less than
the calculated value of ISV, Inc.’s water rights. Thus, there are two ways of
offsetting the increased use.
1. The Increased consumption of river water could be offset by full use
of San .Juan—Chama Project water only In winter, when there is no shortage
of water downstream. Summer use would have to be offset by a small
retirement (transfer) of the TSV, Inc. rights, amounting to two to three
acres of irrigated land along the Rebulse Ditch.
2. Or, the increased use could be offset by transfer of essentially all
18.94 AFY of TSV, Inc.’s consumptive use water rights.
Either approach is likely to be protested by one or more owners of Rio Honda
water rights. Based on principles of water—rights management established by
the State Engineer, both methods are likely to be approved (and the second one
is virtually certain to be approved). In either case, If TWSD is successful
in implementing water conservation measures (dry toilets or extremely low—
flush toilets), there would be no need to acquire additional water rights in
the Honda Valley so long as growth does not exceed that which is allowed by
alternative E. This situation could change if a water-master Is appointed and
the rights available to the District are found to be junior to those in Arroyo
Honda. In such a case, the District might need to obtain and retire rights
from Arroyo Honda in order to be assured of a full water supply in years of
limited runoff. The impacts of retiring irrigated lands are discussed In
section 6.6.6.
Considerable public comment has been expressed because of the uncertainty
about exactly which water rights might be used in the resort area and the

prospect that potential transfers might not be approved by the State Engi—
fleer. Also, the above projections assume that TWSD continues to use the
Pattison water right; if use of this right is •lost then the need for water
rights would increase by 10.91 AP?. The principle concern is that, if there
are problems in use of any of’ the existing rights, IWSO, ISV, Inc. or others
might become aggressively involved in the acquisition of new rights and the
retirement of additional irrigated land.
There would be no additional impact if TWSD shifts from surface to ground
water as its source of supply. As discussed in section 6.2.3, pumping effects
are transmitted to the river very quickly; hydrologically, the two types of
diversion are very similar. Because the well use is balanced fully by reduc-
tions in Rio Hondo river flows it does not have a signifjcan effect on the
regional ground—water table or on river fI s or lake levels in other basins.
Thus, for example, pumping in Twining would have no impact on water levels in
Blue Lake (see section 6.5).
If the skier limit Is raised to 4800, there would be some additional
overnight development outside TWSD; it is estimated this would require about 1
to 2 AFY of consumptive use somewhere in the Taos region. (If the limit is
raised but there is no new overnight capacity in TWining, the impact outside
the District would total 6 or 7 AFY.) The water—rights impact of this devel-
opment would vary depending upon location and type of facility. For example,
if motels in Taos expand to accommodate the additional skiers, the town’s San
Juan—Chama rights could provide all of the needed supply. If development is
outside Taos, there could be a need to retire a few acres of irrigated land
(the basin affected would depend on the site of the new lodge/condo etc.).
Or, the facilities might use the domestic water right of 3 AFY, in which case
no irrigated land would be retired; rather, there would be a depletion of
stream flow up to 3 AFY.
Just as past development in Twining is not the cause of the decline in
river flow, future development on any of the scales discussed here would not
be a factor controlling future amounts of runoff. Any solution of this prob-
lem — or of’ problems such as the protection of farmland against water—rights
transfers could occur only through comprehensive planning directed at the
local level and Involving appropriate state and federal agencies.
6.2.8 Impacts of Otherjype Alternatives
Major impacts from the other types of alternatives would include the
following: a) Any efforts to upgrade Oss management are likely to be
reflected in improved ground and surface water quality. b) The superior
disinfection processes proposed will definitely benefit stream sanitation. c)
Water conservation measures are essential If TWSD is to maximize its
development within the lItil]-tS of wastewater plant capacity and available water
rights. d) Quality assurance measures would be expected to improve the
Probability of compliance with the stream standards. e) Measures such as a

continued ban on phosphorus detergents would benefit plant performance and
river quality.
Programs to control non—point sources (primarily those described in USFS,
1981a and 1981b) have the potential to significantly improve river quality by
reducing pollutant loadings from ski trails, parking lots, the base area and
construction sites. However, it must be recognized that these sources are one
cause of degradation. Unless the programs reduce loadings to well below
existing levels, it can be expected that the river will show the continued
ecological changes associated with resort development. These impacts would
include elevated levels of most pollutants as the river flows through the base
area, and possible occasional violations of the turbidity standard if runoff
is not adequately controlled from areas of disturbed soil. The extent of
these effects will be reduced in direct relationship to the success of’
mitigation measures.
6.2.9 Impacts of EPA and Other Agency Alternatives
EP.A funding of new treatment facilities would benefit the quality of the
Rio Hondo; otherwise, EPA ’s choice of funding alternatives would have no
identifiable impact on water. Assuming that a new facility works as Intended,
the decisions of other agencies may actually have a more important effect on
the long—term water resources of the area. The watershed management programs
of USFS may be able to have a small influence on runoff and possibly stabilize
or Improve downstream water supplies. Comprehensive protection of water
rights for the land would require countywide programs with this objective.
Provided that the non—point source control programs of USFS (and TWSD) work
well, the upper reaches of the river would be expected to show long—term
improvement compared to existing conditions. Possible violations of stream
standards in the lower reaches are appropriate for consideration in future EID
decisions regarding NPDES permits, on—site systems regulations, and the
general subject of non—point source controls.

6.3.1 Existing Conditions
Air Quality . The USFS EIS (USFS, 1981a and 198lb) evaluates present and
future air quality impacts associated with expansion and other modifications
of Taos Ski Valley, Inc. The analysis and conclusions apply to this EIS and
are presented here in summary form.
Taos County has naturally very clean air hich is potentially affected by
vehicle exhaust emissions, dust from various sources, and wood smoke. Limited
data on air quality are available for the area; the data indicate the only
existing problem is excessive suspended particulates, attributed to wind—
storms. Strict federal and state regulations are intended to prevent any
major change in the existing conditions. The Wheeler Peak Wilderness Area
(see chapter 6.5) is designated a Class I air quality area in which no
significant deterioration of existing air quality is allowed. The remainder
of the county, including TWSD, is Class II, which allows some deterioration
(12 percent of the standard). Baseline data for Twining and downstream
communities does not exist. However, air quality modeling done for the Forest
Service EIS indicates that most standards are not now exceeded or will be
exceeded in the near future. Total suspended particulate levels (dust) are
often exceeded in New Mexico due to natural conditions. Ambient air quality
standards are listed below.
Federal Federal Existing
New Mexico Primary Secondary levels at
Standard Standard Standard Twining
Total Suspended Particulate (TSP)
1. 24-Hour Average 150 ug/m 3 260 ug/m 3 150 ug/m 3
2. Annual Geometric Mean 60 ug/m 3 75 ug/m 3 60 ug/m 3
Carbon Monoxide (CO)
1. 8-Hour Average 8.7 ppm 9 ppm 9 ppm -
1-Hour Average 13.1 ppm 35 ppm 35 ppm .19 ppm
Non-methane Hydrocarbons (HC)
1. 3—Hour Average .19 ppm n/a n/a .0074 ppm
New Mexico Ambient Air Quality Standards are as set forth in section
niinber 201 of the “Ambient Air Quality Standards and Air Quality Control
Regualtions.” Federal Ambient Air Quality Primary and Secondary Standards are
provided by the National Ambient Air Quality Standards (NAAQS) as established
by the Environmental Protection Agency. State and federal annual standards
re not to be exceeded at all, while federal short—term standards are not to
be exceeded more than once a year.
Definitions of federal ambient air quality primary and secondary standards
are as follows:

“National primary ambient air quality standards define levels of’ air
quality which the Administrator judges are necessary, with an adequate
margin of safety, to protect the public health. National secondary
ambient air quality standards define levels of air quality which the
Administrator judges necessary to protect the public welfare from any
known or anticipated adverse effects of a pollutant.”
There are no significant sources of air pollutants generated at the
existing sewage treatment plant. Plant odors have not been a major problem,
at least partly because of the remote location of the facility. Impacts from
traffic are well below the standards; see 6.3.4,
Noise . There are no persistent or unusual sources of noise in IWSD or
along Highway 150. Residential noise levels in TWSD and the Hondo Valley
would be expected to be typical of rural areas, on the order of 35 to 45
decibels (A—scale) and perhaps a few decibels higher near the highway (EPA,
1978). The equipment at the existing sewage treatment plant is typical of a
relatively quiet facility, and is thus about 40 to 50 decibels at the property
6.3.2 Impacts of the No—Action Alternative
Air pollutant emissions and noise would increase due to increased off—
peak travel to TWSD. These impacts are discussed in section 6.3.4.
6.3.3 Impacts of Treatment Alternatives
New treatment facilities would be generally similar to the existing
facilities with regard to generation of air pollutants and noise, except: the
addition of a stand—by generator (to be used in the event of power failures)
would add one new source of exhaust and noise, and the air blowers for
aerating the activated sludge are relatively noisy; however, they would have
silencers and would be housed inside the plant building. The impacts of this
equipment would be detectable only In the immediate vicinity of the plant and
are considered minor.
Short-term impacts on sound and air quality would occur from construction
and will differ according to which alternative is selected (see Table 6—1).
Alternatives which involve piping sewage from Twining would affect the largest
area and greatest number of people. Alternatives which call for construction
at each cabin and lodge (e.g. composting toilets) would have the greatest
impact on sound and air quality within the ski valley.
6.3.4 Impacts of Capacity Alternatives
Mountain valleys are often sensitive to air pollution (Reeser and Kirkpat-
rick, undated), although in the Hondo Valley the wind regime appears to be

favorable to the dispersion of pollutants. A major potential impact on air
quality is increased exhaust emissions from increased vehicle traffic. USFS
(l981a and 198lb) presents the results of two ‘worst—case’ modeling studies
which predict the increase in carbon monoxide and hydrocarbon pollution along
Highway 150 as a result of projected increases in traffic to and from the
resort complex. The magnitude of the traffic increase is comparable to that
identified in section 6.6 of this EIS. Average traffic levels are expected to
increase approximately 88 percent even if ticket sales are limited to current
levels (alternative B, 80,000 gpd). If alternative E (95,000 gpd) is
selected, average traffic is expected to increase by 123 percent and peak
traffic by 20 percent.
The impact of traffic on air quality can be considered in two aspects.
“Average” pollutant concentration will be related to average traffic flows, of’
the total number of’ vehicle trips over a long period. “Peak” pollutant
concentration will occur during rush—hour conditions — relatively short
periods in the morning and in the evening when large numbers of’ cars are on
the road. Such peak concentrations are much higher than the average pollutant
concentration. Using the traffic numbers given in Table 6—8, average air
pollutant concentration during the ski season would increase by 88 to 123
percent. Peak concentration would increase by no more than twenty percent.
However, the modeling presented in USFS (1981a and 198lb) indicates that even
under worst—case conditions (peak traffic, low wind speeds) the increased
traffic would produce concentrations of carbon monoxide and hydrocarbons that
are well within limits established by state and federal standards. (These
projected increases assume a linear relationship between vehicle numbers and
pollutant emissions; however, the increase will probably be less due to
emissions controls placed on newer automobiles), Some of the pollutants may
be washed into the Rio Hondo and could affect water quality; as Illustrated by
calculations for lead (see Appendix C.5), this inpact would be very small.
Rornero (1978) analyzed air pollution in the ski resort of Vail, Colorado,
and found possible visibility and health irTpacts from fireplace emissions.
The population at Vail is much greater than In Twining, and the cause—effect
relationships between air quality and wood smoke were not well—established.
The principal implication of this study is that fireplace emissions could
become a concern in Twining if population increases toward the upper limit of
the projections presented in Table 6—7 (148,000 gpd plant).
There would be an increase in noise along the highway due to the traffic
increase (see Table 6-8). The increase at 100 feet from the road would be 1
to 3 decibels, averaged over 24 hours (Wilson, 1981). There would be
short-term impacts on both noise and air quality from construction activities
associated with development In the ski basin (see Table 6—1). Such Impacts
would be somewhat greater for the larger capacity alternative.
6.3.5 Impacts of Other Alternatives
Construction activities associated with each alternative would have
short—term Impacts on noise and air quality (see Table 6—1). Section 6.1.3

discusses the relative magnitude of construction activities for the various
Ozone, which would be used for disinfection under alternatives 1, 2, 12
and 15, is a toxic gas. However, it would be generated on—site in small
quantities for immediate use; therefore, the accidental release of a large
amount of ozone would not be expected. The ozone generator and dosing chamber
are closed systems which should contain all ozone. If any leaks occur, they
would be detected by the characteristic ozone odor, which is noticed at levels
below the toxicity concentration. In general, the hazard to the community of
ozone use are considered less than for the alternative, chlorine.
6.3.6 Impacts of EPA and Other Agency Alternatives
The major impact on air quality and noise would be from increased vehicle
traffic. Some deterioration of air quality is likely regardless of what
funding decision EPA may make but in no case is it projected that air quality
standards would be exceeded. Actions by other agencies to require or en-
courage use of a shuttle system could lead to improved air quality.
6.4.1 Existing Conditions
Terrestrial biology . Animal species that are likely to reside in Taos Ski
Valley or adjacent areas are listed in Appendix 9 of the U.S. Forest Service
ElS (USFS, 1981a and l981b). The mountains support a good variety and
population of many mammal, bird and other species, including mule deer,
mountain lion, black bear and mountain sheep.
The principal vegetation in the base area is a forest of quaking aspen and
dense spruce—fir trees with small stringers of riparian vegetation along the
stream courses. Up—mountain, a dense spruce—fir forest covers the landscape,
with mixed stands of aspen overstory and spruce—fir understory. Alpine tundra
occurs above timberline (approximately 11,800 feet). Large areas of rock
outcrop and talus slopes are devoid of vegetation. Mountain meadow and sub-
alpine grasslands, both natural and man—caused, are interspersed throughout
the forest. Appendix 3 of USFS (l98la) provides a plant checklist.
Approximately 281 acres of ski trails are vegetated with a mixture of
native and introduced grass and forb species. Because vegetative cover has a
prime value of stabilizing and reducing soil loss from erosion, efforts have
been made to revegetate lift corridors and trails. Fertilizers have accel—
lerated the recovery time of the vegetative cover and reduced the potential
soil loss.
Aquatic Biology . The Rio Honda is an important cold—water fishery which
contains a variety of fish species. These include brown trout, which in the

past have been predominant in the lower sections of the river; cutthroat
trout, mostly in upper sections; rainbow trout, which are stocked every year;
brook trout and dace. There are also a number of hybrid rainbow—cutthroats in
the river. These fish feed on a variety of lower—life forms, especially
relatively large invertebrates which dwell on the river bottom. Appendix C.8
provides a checklist of these benthic macroinvertebrates. Much of the river
is considered a high—quality ecosystem; however the portion of the river in
and near Twining has been degraded by effluent from the resort complex (see
Historic Impacts of TWSD and Taos Ski Valley . In 1979 EID began to sample
benthic macroinvertebartes in the stream bottom of the Rio Hondo in order to
evaluate the ecologic impacts of effluent from the TWSD treatment plant. The
studies determined the relative abundance of two types of’ organisms: rela-
tively good food sources which require a clean stream for reproduction
(example: mayflies and stonefiles); and less satisfactory food sources which
are tolerant of a somewhat mucky stream bottom (example: true flies). Unless
sewage is well—treated, it stimulates algal growth and contributes settleable
solids which can damage a clean, rubble stream bottom and lead to a change in
ecology from the first type of species to the second. (The change may
actually produce a greater abundance of aquatic organisms; the impact is one
of quality of’ biomass, not quantity). A second aspect of the study was the
measurement of chlorophyll a, which indicates the relative growth of’ algae and
is thus a direct measure 6? whether or not the river is overfertilized (too
many nutrients).
EID has taken biological samples at three stations: HON4, HON8, and HON12
(see Figure 6—3). This provides information on the aquatic habitat above and
below the treatment plant, and at a point 10 kilometers (6 mIles) downstream
of the treatment plant but still within the mountain segment. Samples have
been taken in the spring (after the stream has received the greatest concen-
tration of sewage effluent), in the summer (after the spring scour), and in
the fall (before the beginning of the ski season).
The data from the samples have been analyzed by Dr. Gerald Jacobi of EID
using the biological community index (BCI). The BCI was developed sped—
fi 41y for high mountain streams as an indication of their biological
health. Calculation of the BCI involves comparison of what is actually found
in the stream to what should be there (based on stream gradient and water
chemistry). using this approach, the results for the Rio Hondo can be
summarized as follows (see Figure 6—3 for location of stations):
March, 1979 Good Poor Good
July, 1979 Good Good Good
November, 1979 Moderate Moderate Good
March, 1980 Moderate Poor Good

Algae samples were also taken by EID from rocks at stations HON3 through
HON12 and analyzed for chlorophyll a in November 1979, March and May, 1980.
The highest levels were found at HON8 in March and at HON1O in November.
The results of the sampling show that during the ski season, nutrients and
solids from the treatment plant seriously degrade the Rio Hondo immediately
below the treatment plant (Jacobi, 1979; Jacobi, 1981; Jacobi, et al., 1980).
The spring scour cleans away the accumulated pollutants and the aquatic
biology is able to recover. The data show that some degradation is occurring
above the treatment plant due to non—point sources, especially during low—flew
periods. The high levels of chlorophyll a at HON1O prior to the ski season in
November suggests that algae, fed by nutrients from the sewage plant, grow in
the stream right below the plant through the winter and are then carried
downstream after the spring flows scour out the area. However, the low
chlorophyll a levels at HON 12 neither confirm nor deny theories that this
scour may have an impact in the lower Valley area.
The data for more recent samples are still being analyzed; generally the
same patterns have been seen. Conditions at HON8 were particularly poor this
past winter (1981); all organisms were virtually eliminated, apparently due to
over—chlorination by the treatment plant.
Although the stream biology has been able to recuperate each year after
the spring scour, EID is concerned about what might happen in a low-flow year
in which there is no scour. In such a case, the degradation of the stream
might spread further down, and the environment might be stressed past its
ability to be easily restored to high—quality conditions.
The New Mexico Department of Game and Fish has expressed concern over the
potential problems in the Rio Honda due to Twining’s discharge. It is
believed that under historic conditions the river has been becoming a marginal
stream for the cutthroat trout, a sensitive species considered to be
“threatened”, by the State of New Mexico (but not on the Federal Threatened
and Endangered Species list), which requires pure, cold water. Further
degradation of the Rio Hondo due to non—point sources and/or sewage discharge
may make the stream unsuitable for the sensitive cutthroat. There is already
evidence for increased cross—breeding between cutthroats and rainbow trout;
such cross—breeding is indicative of stressed conditions (McNall, 1981).
Brown trout, which are more tolerant of polluted streams, and which even feed
on the cutthroats, have invaded the upper portions of the Rio Honda as high as
one mile above Valdez. It is the position of’ Warren J. McNall, Assistant
Director over Fisheries Research and Management, that continued violation of
the discharge permit at Twining would eventually render the upper Rio Honda
unsuitable for native fishes and possibly even for the planted rainbows
(McNall, 1980). However, the converse is not necessarily true; restoration of
a clean stream would not in itself’ assure survival of the cutthroat against
the pressures of other species.
The Department has received increasing numbers of complaints that there
are fewer fish in the river than in previous years, that dead fish are more

frequently seen, and that the fish that are there taste bad, look sick and
slimy, and have skin lesions. It has also been noted that ducks and geese are
seen less frequently and that vegetation is dying along the river. Algal
growth in the river has reportedly become a nuisance for downstream recrea-
tional and farming activities. These complaints have been investigated, but
with the possible exception of the algal growth, no relationship to TWSD
sewage discharge has been found. (See also section 6.2.2 and Appendix C.4.).
Threatened or Endangered Species . In accordance with Section 7(c) of the
Endangered Species Act, as amended, EPA requested that the U.S. Fish and
Wildlife Service identify any plant or animal species in the area that is
listed, or proposed for listing, as endangered. The FWS list was provided to
EPA on October 12, 1979, and is as follows (USD1, l979a).
Bald eagle ( Haliaeetus leucocephalus) : May be found as a winter resident
and or migrant along the Rio Grande and tributaries. Also recorded in the
Sangre de Cristo Mountain area in summer. This water—oriented eagle feeds
largely on fish though also takes waterbirds and mammals.
Peregrine falcon ( Falco peregrinus) : This species, a summer resident of
the area, typica1l iJiunts waterways for food. Nest sites are associated
with cliffs and bluffs of gentle terrain.
Information provided by the Forest Service (USFS, l979a) indicates that
the bald eagle has been sighted in the canyon twice in three years; therefore,
it. is unlikely that the bird is greatly dependent upon this habitat. The
Forest Service suspects that it is transitory and only uses Honda Canyon in a
fa5hion similar to a fly way (USFS, 1979).
The peregrine falcon has been observed hunting in the near vicinity of the
Rio Hondo, but there has been no direct observation of peregrines or evidence
of breeding documented in the watershed itself. Prey ranges from swallows to
ducks, geese, and herons, and in New Mexico they commonly feed on jays, wood-
peckers and band-tailed pigeons (EPA, 1980b; Dick-Peddle, 1978). Breeding
takes place in mountainous areas relatively near water on cliffs or other high
structures. The Forest Service feels there is a strong possibility that the
birds use the drainage for hunting; however, it is doubtful that they are
wholly dependent on this habitat (USFS, l979a).

The cutthroat trout was listed on the Federal endangered species list in
1962. Although it has since been taken off that list, it is considered a
sensitive species in the state of New Mexico. Two state—threatened animals
suspected of occurring in the area are the white—tailed ptarmigan and the pine
martin, although no sightings of the pine martin have been reported in recent
NO threatened or endangered plant species occur within the boundaries of
the District. However, several species regarded as “sensitive and rare” by
the New Mexico Heritage Program have been found in the area (USFS, 1981b;
Isaacs, 1981). The bunchberry, Cornus canadensis , is found within District
boundaries, which is one of only two locations known for this species in New
Mexico. The stiff club moss, Lycopodium annotinum , is found along Lake Fork
of the Rio Hondo and is the only known location for the species in the state.
Possibly within District boundaries may be found the pale coral root,
Corallorhiza trifida , another sensitive species. None of these plants are in
areas of present or planned development.
6.4.2 Impacts of the No—Action Alternative
If no attempts are made to improve the water quality of the Rio Hondo
there will be no change in the existing aquatic conditions, in which degrada-
tion is already evident below the treatment plant. With or without changes in
the wastewater treatment system, some further growth is anticipated in the
resort. Such growth would be expected to substantially increase non—point
source pollution from on—site systems and therefore cause continued
deterioration of the stream ecology. As mentioned above (6.4.1), there is the
fear that a low—flow year with no scour would prevent the restoration of’ high
quality aquatic conditions in the spring and result in increased degradation
further downstream.
6.4.3 Impacts of Treatment Alternatives
Improvement in the treatment facilities at TWSD should virtually eliminate
stream standard violations and produce a better quality effluent, as discussed
in 6.2.6. This would have a favorable impact upon stream ecology; however,
because of non-point sources of pollution from the resort complex, and the
fact that meeting the stream standards does not guarantee a pristine river,
biological conditions would be expected to improve only from poor to moderate
at HON8 in the spring and perhaps from moderate to good in the fall. Algal
growth downstream would be reduced but not completely eliminated.
6.4.4 Impacts of’ Capacity Alternatives
Non-point source loadings would increase with further development in
Twining and could contribute to deterioration of water quality. This impact
should be minimized by the on—site system management program (see 5.4.2),

which, if successful, has the potential to improve Rio HOndo water quality and
ecology beyond the improvements expected from a more efficient treatment
plant. If unsuccessful, however, further degradation of the river would occur.
6.4.5 Impacts of’ Other Types of Alternatives
Any type of upgraded OSS management would result in improved water qual-
ity, which will have a positive impact on stream biology. The use of ozona—
tion in place of traditional chlorination for disinfection would eliminate the
possibility of chlorine residuals which are toxic to aquatic life.
6.4.6 Summary of Impacts on Endangered and Threatened Species
The bald eagle ( Haliaeetus leucocephalus ) feeds primarily on fish and
could potentially be effected if the quantity or quality of fish in the river
is diminished due to lack of improvements in water quality. Also, continued
increases in the tourist flow to the area could result in a very small decline
in the size and value of the bird’s habitat. However, because the effected
area would be small and would not involve essential habitat, these impacts
would not be significant.
The impacts on the peregrine falcon ( Falco peregrinus ) probably would not
be significant either, since their presence in the area 1s questionable. Any
decline in the wildlife (primarily avian) population could cause a decline in
their habitat, but as in the case of the eagle, it Is unlikely that these
birds are greatly dependent upon this habitat.
The cutthroat trout may well be effected by the no—action alternative,
since these fish require cold pure streams. Continued Twining discharge could
cause significant reductions in the cutthroat population.
A decline in the wildlife population in the area could potentially cause a
decline in the habitat of the pine marten; however, comparable habitats are
generally widely available in the region, so the impact on this species is
probably insignificant. Ptarmigan are birds of the alpine tundra and
timberline habitats; therefore, impacts on this species would not be expected.
Since the plant species considered to be sensitive and rare do not occur
in any developed areas or in areas of planned or potential development, no
impacts would be expected from the no—action alternative (nor from the
treatment, capacity or other alternatives).
6.4.7 Impacts of EPA and Other Agency Alternatives
EPA will support the biological upgrading of the Rio Hondo to the extent
that funding is granted for treatment of existing or expanded future flows.

The non—point source programs of USFS (and TWSD) must be successful to assure
improvement of biological conditions.
The Twining area contains a number of environmentally sensitive resources
of both natural and cultural origin. These include historic/archaeologic
resources, existing and potential wilderness areas, a wild and scenic river,
sacred Indian lands, and a highly aesthetic visual resource. Figure 6—5 shows
the location of many of these resources.
6.5.1 Existing Conditions
Historic and Archaeologic Resources . Historic and archaeologic resources
in the Twining area are discussed in USFS (l981b). In summary, the continuous
presence of Pueblo Indians has been evidenced in the TWSD area for at least
the last millennium. It was not until the beginning of the 17th century that
the Spanish began to settle in the vicinity and the 19th century before the
first Anglos arrived. The town of Twining was established around 1900 by the
Frazer Mountain Copper Company and a mine developed in the TSV area. Both
Twining and the copper mine were abandoned in 1910 due to financial
difficulties of the Frazer Company. Population was estimated to be between
500 and 800 during this decade. Presently a few buildings remain at the
abandoned mine site. According to the New Mexico State Historic Preservation
Officer, no properties registered, nominated or determined eligible for
nomination to the Register of Historic Places lie within or adjacent to the
treatment plant site (Merlan, 1981). See letter in Appendix E.
Compared to other regions in the state, there is a relatively low
probability of archaeologlc site occurrence in the TWSD area due to high
elevation and steep slopes. If such sites do exist, they are likely to be
seasonal hunting camps used by Archaic or Pueblo peoples between 5500 B.C. and
A.D. 400. The sites would be simple in nature, consisting mainly of isolated
stone tools or projectiles and would be easy to excavate (Schaafsma, 1981).
Wilderness . The Wheeler Peak Wilderness adjoins the TSV, Inc. permit area
to the south and west; an additional part of the wilderness lies to the east
of the area but does not border it. The New Mexico Wilderness Bill, passed
Jan. 31, 1981 expanded the 5,127 acre tract to its present 19,800 acres and
added rugged canyons and gentle subalpine meadows to the previously included
alpine zone. The area is open to use for recreation and grazing and, until
the end of 1983, mining and prospecting. At present, use is almost entirely
for recreation and is heavy during the summer and light during the winter.
Visitation in winter is limited due to steep slopes and avalanche hazards;
however, there is some cross—country skiing and mountaineering, hiking,
backpacking and winter camping (Moehn, 1981). One of’ the major trailheads to
the Wheeler Peak Wilderness is the Bull of the Woods trail originating in

es Pèedras
El Rito
WIll!017?S Lake
— BIui Lake
5 lOmj$
6-L 1+

Columbine-Honda (46,050 acres) lies to the north of TWSD and was
designated as an area for further study in the 1981 New Mexico Wilderness
Bill. It is an extensive alpine and subalpine area which provides important
habitat for deer and elk; use is light at present (Moehn, 1981).
Wild and Scenic River . The Rio Grande from the Colorado state line to the
confluence with the Rio Pueblo de Taos (48 miles; see Figure 6—5) was the
first river to be designated as part of the National Wild and Scenic Rivers
System created by Congress in 1968. This pristine reach of the stream is
primarily managed by the Bureau of Land Management with the objective of’
maintaining it in its natural state. A portion of the Rio Grande runs through
the southwest corner of Taos Indian Pueblo land and is administered by the
Pueblo in a manner consistent with the National Wild and Scenic Rivers
Use of the Rio Grande Wild and Scenic River area is restricted to
recreation only with no development permitted. Most recreational activities
occur during summer months and include camping, fishing, hunting and rafting.
Winter use is extremely light. The confluence of’ the Rio Hondo and Rio Grande
(Dunn Bridge) is a heavy use area as this is a major entry point for river
rafters. Other sensitive areas in Taos county include Uracca Wildlife Area,
Tres Piedras Wildlife Area and Red River Trout Hatchery. These areas are
shown in Figure 6.5.
Sacred Lands . Taos Pueblo Indian land lies to the south of TWSD, forming
the southern border of the Wheeler Peak Wilderness Area. Although Taos Pueblo
lana is not adjacent to TWSD, the people of Taos Pueblo are generally
concerned about trespass intrusion and other problems which may occur as the
result of development in Twining. They are especially interested in protect-
ing water resources, including the Rio Lucero (the basin adjacent to Rio
Honda) and Blue Lake, which is significant due to its sacred nature.
The Taos Pueblo people have a history of defending and preserving their
land. They regard their land and all water sources as a gift from God and
thus sacred. These sacred entities are protected by the American Indian
Religious Freedom Act (1979) which guarantees access, preservation and
protection for all religious properties held by Native American tribes. In
the past, Taos Indians have had some problems with trespass violations and
land disputes in border areas. It is especially important that sacred land
remain in its natural state since the spiritual well—being of the site is
believed to be dependent on its physical condition. It is also important that
privacy be maintained to avoid disturbance of sacred rites. Appendix E
contains a letter from Paul Bernal, Taos Pueblo Tribal Council Secretary,
elaborating his concerns in relation to development in the Twining area.
Visual Resources . USFS (198la; Appendix 8) contains a detailed analysis
of visual resources in the Twining area. Briefly, the base area has been
characterized as resembling a Swiss alpine village comprised of’ natural and
man—made features including:

1. aspen tree trunks and buildings with pitched roofs, both creating
strong vertical lines;
2. natural building materials with rough textures and earth colors;
3. long, narrow, well—defined spaces (usually for vehicle and pedestrian
USFS uses a methodology called Visual Management System to assess the
visual impacts of major projects. Under this system, the U.S. Forest Service
has determined a visual quality objective for ISV, Inc., based on scenic
attributes and the extent to which the area is visible to the public. Any
modifications made to the ski area must comply with this objective.
Basically, the objective permits management activities to TSV, Inc. which are
not visually evident. Texture, color, line and form must be a repetition of
what already exists in the characteristic landscape. ‘Critical viewpoints’ is
one criterion evaluated in the Forest Service Visual Management System.
Figure 5 of’ the U.S. “Z” document (USFS, 1981a) shows locations of critical
viewpoints in the central base area. The sewage treatment plant is located to
the west of’ the central base area off the main road. It is below other
development thus out of sight from most recreational activities, but a limited
view of it is present from the main road.
Agricultural lands . EPA has established a policy to protect environ-
mentally significant agricultural lands wherever they may be impacted by
agency programs. The policy is intended to minimize impacts which may induce
conversion of agricultural land unless the proposed activity serves an
essential public need (see Table 3-1). The irrigated lands of the lower Hondo
valley can be considered as significant agricultural lands due to their
importance to the traditional lifestyle of the area (see section 6.6.2).
6.5.2 Impacts of the No Action Alternative
Continued pollution of the Rio Hondo and waters downstream, possibly
including the Rio Grande Wild and Scenic River area, would result if TWSD’s
discharges are not cleaned up. An outcome of increased population in the
Twining area would be greater potential of trespass impacts to both sensitive
Forest Service lands (especially Wheeler Peak Wilderness) and sacred Indian
lands. In addition, potential visual impacts and possible archaeologic site
disturbance impacts could result from growth—related activities such as cabin
construction. The trespass, visual and archaeologic impacts are discussed In
6.5.3 Impacts of Treatment Alternatives
Construction of a new treatment plant at the existing site (for example,
alternatives 1, 2, and 13) would involve acquisition of’ an additional wooded
acre of Forest Service land. Cutting of trees would result in much more

visual exposure of the treatment plant. An archaeologic survey would be
necessary prior to construction; salvage or even relocation might be needed if’
important resources are found. Should any sensitive historic or archeologic
resources be located during construction, work would stop pending notification
and decision of the State Historic Preservation Officer. Alternatives 1 and
13 call for construction of greenhouse—covered sand drying beds for sludge.
Similarly, alternative 2 requires construction of a greenhouse—covered pond.
Neither the pond nor drying beds would conform structurally to the
characteristic landscape as described in the Forest Service Visual Management
System (USFS, 198la). Although this would be a potential visual impact, it
would be nominal due to the low visibility of the plant area which is below
all other development.
Any of the alternatives suggesting pipeline construction (6, 7, 8, 10, 11,
14) would have a greater visual impact and potential for disturbance of
historic or archaeologic sites. The large holding ponds discussed in
alternatives 6, 7, 9, and 14 would create a permanent visual impact in
downstream areas. Construction of a pipeline to the Rio Grande (alternative
8) would cause additional problems due to the river’s Wild and Scenic
designation. Possible odors, solids and algae would create conflict due to
the recreational nature of the Rio Grande at Dunn Bridge. Bureau of Land
Management approval would be necessary prior to implementation of this
Alternatives 3 and 9 involve more clearing and thus greater potential for
visual impact.
6.5.4 Impacts of Capacity Alternatives
No known archeologic sites or historically significant structures exist
within the TWSD area. The few remaining buildings located at abandoned mine
sites would not be affected by construction activities. New construction
(cabins, condos, etc.) have some small potential to affect archaeologic sites
on private land.
Any capacity alternative which supports greater visitation to TWSD during
the winter season would Increase the potential for use of the wilderness
area. Due to hazardous winter conditions, however, increased usage of
sensitive Forest Service areas such as Wheeler Peak Wilderness is unlikely.
No adverse impact as a result of’ ski resort development is anticipated for the
Rio Grande Wild and Scenic River area. Water quality of the Rio Grande would
remain unchanged so long as a central plant complies with the standards.
Taos Indian Pueblo lands and TWSD are separated by the Wheeler Peak
Wilderness Area. Carson National Forest staff have characterized this
wilderness tract as an extremely light use area during winter due to steep
slopes and potential avalanche dangers (Moehn, 1981). As influx of visitors
to TWSD is primarily a winter phenomenon, the potential impact caused by
trespass and desecration of Indian lands is considered remote. Additionally,

none of the alternatives described in Chapter 5 affect the quality or quantity
of waters on Indian lands, including the sacred Blue Lake. Refer to section
6.2 for further discussion of water resources.
Proposed modifications to TWSO beyond those discussed in USFS (1981a)
would include construction of approximately 94 cabins to the east of the base
area and addition of several large structures within the central base area.
Construction in the base area and to the east would meet the Forest Service
visual quality objective as long as the texture, color, line and form repeated
those of already existing structures and the Swiss Alpine village appearance
was retained. Many people have expressed a desire to preserve this Swiss
village character of the area (USFS, 198la). As most of TWSD is private land
there is no guarantee that designs would be in compliance with Forest Service
visual quality standaras. Peer pressure in the area to keep the village
appearance unchanged would be the principal motivation to encourage conforming
Agricultural lands would benefit from water—quality improvements
regardless of treatment plant capacity. The use of water to support increased
use of the resort complex (and/or snowmaking) could require retirement of up
to 15.15 acres of water rights land. The necessary acreage is already owned
by Taos Ski Valley, Inc. and represents less than 1 percent of the irrigated
land in the valley.
6.5.5 Impacts of Other Types of Alternatives
Impacts of the remaining components for development of a complete
wastewater system would be minimal. Rehabilitation of existing collection
lines would create a short term visual impact as would sewer construction (see
Table 6—1). Sewer extensions would create greater potential for historic or
archeologic site disturbance as well; surveys will be required prior to
6.5.6 Impacts of EPA and Other Agency Alternatives
Alternatives suggesting new plant construction would require negotiation
with the Forest Service to obtain a permit for an additional acre of land.
The Forest Service would require an environmental assessment be completed
prior to construction.
No impacts are anticipated to sacred lands, potential and existing
wilderness areas or the Rio Grande Wild and Scenic River area regardless of
the alternative chosen. Development on private land may have a potentiai. but
probably minor impact on visual resources and archaeologic sites; these
ilnacts would be similar under any EPA funding decision and would likely occur
ven if a new plant is not built.

Agricultural lands would probably remain stressed due to the general
shortage of water in the basin (see 6.2.1) and many other physical, economic
and cultural factors (see 6.6.2). EPA funding (if any) of wastewater
treatment improvements woula be associated with improved water quality and a
small reduction in the stress. EPA funding (if any) of an expanded plant
would be associated with the retirement of up to 15.15 acres of’ irrigated land
in order to provide additional water rights within TWSD (see 6.6.6).
6.6.1. Existing Population, Land Use, Economy, and Infrastructure
County Population . Taos County’s population declined through 1960 when
the census reported a population of 15,934. Since then the population has
grown slowly. Over the past 10 years, the county grew from 17,516 people in
1970 to 18,862 in 1980 (an average of 0.7 percent per year). Nearly half of
the 1980 population lives in the immediate vicinity of Taos; major community
concentrations are in Taos (3,369), Taos Pueblo and environs (2,112), and
Questa (608). However, the county is still rural with most people living in
numerous small villages located in the irrigated valleys along tributaries of
the Rio Grande.
Continued slow, steady population growth is expected, to approximately
27,700 in the year 2000 (BBER, 1979). The Taos area will increase its share
of the county population and, depending on activities at the MolyCorp mine,
significant growth could also occur near Questa. Rural areas are expected to
remain stable or, near Taos, grow somewhat.
Tourism adds substantially to the effective population of the region.
While there is no actual count of tourists, annual visitation probably
approaches a million visitor days, considering known skier visitation,
estimates of summer use, and estimates based on tourism expenditures (Adams,
1981). More than 5,000 tourists per day visit the county during peak
periods; this influx is most notable during the summer, but winter tourism,
largely associated with skiing, has become significant in recent years.
Twining Population . Twining has a population structure which is typical
of a resort: permanent residents are few, and there is a great fluctuation in
the number of day vistors, overnight visitors, day employees and seasonal
resident employees. For planning purposes it is the population during peak
periods which is of greatest interest; in turn this is a function of the
capacity of the area.
At present the effective skiing capacity is 4050 per day, since, the
lift—ticket limit Is set at this level; however, ISV, Inc. plans to increase
this to 4800 once the sewage plant is capable of handling this Increase. The
number of skiers is less than the capacity of the mountain, which is estimated
to range between 5,846 and 8,122 skiers (Flance, 1980). Lodges and condos
have a ‘pillow’ capacity of 931: 796 for guests and 135 for residents and

employees. There are 295 pillows in the existing cabins (assuming 5 per
unit). Thus, the current maximum overnight capacity of the area is 1226
persons (see Table 6—7 in section 6.6.3).
Actual populations in peak periods have approached the capacities noted
above. The peak—day population to date is about 5,000, reached in the 1979—80
season. This figure includes 4,400 skiers, about 440 other visitors, and 335
employees; about 960 skiers and other visitors and 110 employees were over-
night residents (Wilson, 1981). In comparison, the winter—long average
population in 1979-80 was approximately 2,400 (or roughly 333,000 total
employee, visitor and resident days). The peak sumer population is about 330
(Wilson, 1981). Existing “baseline” population figures, presented in Table
6—7, are somewhat lower than past peaks due to the ski—ticket limit of 4,050
currently in effect.
County Land Use and Land Use Planning . Land uses in Taos County have
changed little over the centuries. Rural uses predominate and are character-
ized by non—intensive agriculture and recreation/forest. Almost all the
agricultural land is used for grazing; 40,000 acres (2.7 percent of the
County) are irrigated (primarily for animal feed crops). Nearly all of the
irrigated land (86 percent) depends on surface runoff and is located along the
tributaries of the Rio Crande with concentrations in the Taos and Cerro-Red
River areas and in the Embudo Drainage.
Twining’s influence on regional land uses is concentrated in the area
between El Prado and Amizette, where several commercial facilities (including
condominium rental units) cater to skiers. There are also seven subdivisions
on Highway 150 which owe their marketability at least somewhat to the prox-
imity of the ski valley. The 356 lots in these subdivisions represent less
than one percent of the platted lots in the county; build—out on these lots
has been slow, but could increase if winter tourism continues to expand and
overnight development does not occur in Twining. Future land use changes
could also include some new commercial facilities along Highway 150, catering
to the projected increase in skier use of the area. Refer to section 6.6 for
a discussion of potential additional development pressures which could arise
under the TWSD sewage treatment alternatives.
wo parts of the county face potential significant land use changes In the
near future. One is the area In and near Taos, where urbanization Is likely
to continue, especially in strip development to the south of town. The second
is to the north, from Questa to the state line. There, growth may occur in
response to expansion of the MolyCorp mine and/or development of a new ski
resort by the Rio Costilla Livestock Cattleman’s Association. Also, the
Public Service Company has proposed to trade the Top of the World Farms to BLM
which might then develop a recreation area on a portion of the land.
The municipalities of Taos, Questa and Red River all have Comprehensive
Land Use Plans. The county has taken preliminary steps toward development of
a county—wide land use plan and zoning ordinance, but completion of the work
appears to be some years away.

Land Use in Twining . A generalized map of land uses in TWSD is presented
in Figure 6—6. The base area of the valley contains ski facilities of Taos
Ski Valley, Inc. and several separately owned lodges and condominiums. East
of the base area is a subdivision which contains more than 150 lots being
developed mostly for cabins. Despite the area’s growth, large amounts of
vacant land occur within the base area and the subdivision; this land is owned
by many different persons, most of whom do not live in Twining. There are
also three large parcels of vacant land shown on Figure 6—6, owned by the
Pattison Trust, the Burroughs family, and the Twining Association (an
organization which includes existing Twining property owners and others).
Uses on Forest Service land outside TWSD include the parking areas, ski
trails and the sewage treatment facilities, in addition to hiking trails and
picnicking facilities unrelated to the ski basin.
The sewage treatment plant is located on a wooded, three—acre parcel for
which TWSD has a special use permit from the Forest Service (see Table A—i in
Appendix A). The site is adjacent to and slightly below the level of Highway
150, approximately 850 feet from the nearest existing development (Figure
6—6). Although largely surrounded by undeveloped Forest Service land, there
is a vacant, privately owned parcel on the opposite side of the Rio Honda,
southeast of the plant.
County Employment Patterns . Table 6—3 lists employment statistics for the
period 1960—80. Several patterns are evident in the table.
1. The unemployment rate generally has been high, around 14 percent.
2. The number of jobs available has grown steadily over time, with the
most rapid increase occurring in the 1970’s.
3. At the same time the size of’ the work force has also been growing.
4. The unemployment rate decreased throughout the 1960’s, as the number
of jobs gradually increased, and the labor force expanded more slowly.
5. The unemployment rate Increased In the 1970’s, when the large number
of new jobs was exceeded by the even larger number of people seeking
All of these conclusions reflect long—term conditions; employment and
unemployment often change substantially from year to year. Unemployment which
is higher than both national and New Mexico averages remains a critical
Although average unemployment has remained high, seasonal variations in
unemployment have been reduced (Table 6—4). During the 1960’s, summer and
early fall unemployment rates were low, averaging 4 to 8 percent while winter
unemployment rates often rose to 20 percent or more. The decreasing reliance
on agriculture coupled with increased jobs in services, trade, government,
manufacturing, and skiing have reduced this fluctuation.

F ozer
Beaver Pond
0 1000ff
—-j ____ I
Figure 6-6
Cabins /
ISV, Inc.
CorTynercial /
/acant — Non—
Designated Use
51.66 ±
( .. ,
a. All lots within the platted subdivision (subdivided by the
Pattisons) are considered to be cabin sites.
b. Additional coimnercial development occurs in association with
other land use types (lodges, condos, TSV, Inc.).
Source: Lee Wilson and ASsociates, 1980.

1960 3190 3884 17.8%
1961 3190 4089 21.8
1962 3370 4072 17.3
1963 3500 4099 14.6
1964 3915 4673 16.4
1965 4325 5078 13.6
1966 3840 4502 13.2
1967 4000 4498 10.9
1968 4190 4530 10.0
1969 4600 5003 8.0
1970 4720 5280 10.4
1971 4820 5727 14.4
1972 5165 6024 12.8
1973 5247 6022 12.9
1974 5765 6669 13.6
1975 6399 7750 17.4
1976 6876 8304 17.2
1977 7156 8666 16.4
1978 7726 8772 12.2
1979 7719 8799 12.3
1980 7640 8853 13.7
Source: New Mexico Employment Security eoartrnent data (figures based on
place of residence)
P . cnth Yr: 1964 1965 1966 1967 1968 1976* 1977 1978 1979
Jan. 24.4% 19.9% 17.2% 16.4% 14.4% 15.0% 21.2% 16.6% 13.6%
Feb. 25.4 23.0 22.4 18.6 15.7 13.7 21.2 15.4 13.7
Mar. 23.6 24.3 21.4 16.1 13.8 13.6 19.5 12.9 14.1
Apr. 14.8 18.4 17.4 13.5 12.4 13.3 20.5 11.6 13.5
May 10.2 13.1 12.7 9.5 9.9 12.5 7.8 10.8 11.9
June 9.4 12.4 11.7 9.3 10.0 12.3 16.1 10.6 11.3
July 5.2 9.8 7.7 7.3 7.3 12.3 15.2 10.3 10.4
Aug. 4.9 7.9 7.1 6.9 6.2 10.9 15.7 11.5 9.9
Sept. 4.6 5.5 6.4 6.2 6.0 11.3 14.6 11.1 10.4
Oct. 5.9 5.9 7.8 6.6 6.1 12.0 13.6 13.6 11.0
Nov. 11.2 10.1 11.3 10.8 9.0 12.6 16.1 11.5 11.6
Dec. 16.6 12.9 13.5 11.5 8.6 18.2 15.2 11.1 11.0
Average 16.4 13.6 13.2 10.9 10.0 13.1* 16.4 12.2 12.3
Source; w Mexico Department of EIr 1oyment Security,
Note: Employment Security data for 1976 are conflicting. The average annual
unemployment rates for 1976 do not agree in Tables 6—3 and 6—4.

Minority Employment . Hispanic and Indian people have had a higher than
average unemployment rate in Taos County. For example, in 1970, 17 percent
were without jobs, while the jobless rate for the remainder of the county
residents was 8.1 percent. Employment Security Department (ESO) data reveal
that in 1979 “minority” unenployment was 12.5 percent, while an 11.9 percent
rate prevailed for the remainder of the population (Wilson, 1980). Thus the
difference in joblessness between minorities and other groups has been
substantially narrowed. The improvement in Hispanic employment is also shown
by the increase in Spanish—surnamed members of the work force, from 2200 (41.6
percent of the total) in 1970 to 4400 (50.1 percent of the total) in 1978
(Wilson, 1980). However, in proportion to population, minorities are still
underrepresented in the labor force.
Income . In Taos, incomes are low, although the situation is Improving.
Median family spending income in 1970 was about $4,500; by 1978 this figure
had risen to $9,095 (SBP, 1979). Despite inflation there appears to have been
a real increase in family income as incomes rose faster than the best avail-
able indices of the cost of living (national consumer price index and index of
Albuquerque food prices). Incomes in Taos also improved relative to the state
and nation. In 1970 the median family income was only 43 percent of the na-
tional figure and 51 percent of the state’s average. By 1977 this had risen
to 53 percent and 65 percent, respectively. Still the Taoseno’s income Is low
and much improvement is needed. In 1970 (the most recent figure available),
35.8 percent of the families had incomes below poverty level ($3,745).
Agricultural Economy . Trends in Taos County’s agriculture are similar to
those of the nation. There has been a steady decline In agricultural
production over the past 25 years and only large farms are proving to be
economically viable. On the whole, agricultural pursuits In Taos County today
are marginal and most farms are subsistence operations (Mirubres, 1978). Over
the past decade the decline in the agricultural economy has slowed and it
appears that this sector will stabilize. The remaining farms and ranches
which do contribute to the county economy produced goods valued at $2,514,000
in 1979; total farm labor and proprietor’s income was $2,819,000 (BEA, 1981).
Agriculture also supplied summer employment for about 200 workers annually
throughout the seventies (ESD, 1981).
Non—Agricultural Economy . Table 6—5 indicates the number of jobs associ-
ated with different sectors of the economy. Since 1970, jobs in the county
have increased by 52 percent, faster than the state—wide increase of 42
percent. Most sectors of the non—agricultural economy have grown in propor-
tion to the countywide increase. Services and trade are a major exception;
these sectors have expanded more rapidly and now provide nearly half of the
total employment. The growth in services and trade reflects both increased
tourism and growth of the local and regional trade economy.
Similar trends are reflected in the personal income statistics by Industry
(Table 6—5). The economy is expanding; from 1970 to 1979 total non—farm
Income increased by 179 percent to $71,425,000. The decreasing reliance on
mining and increasing role of trade and services is apparent, as Is a small

of dollars)
1970 b/
1979 5/
8674 5/
Contract Construction
Transportation & Public
Wholesale & Retail Trade
Finance, Insurance &
Real Estate
1,394 “
Other Industries
a. Includes mining employment, reported to be 789 (Yguado, 1972).
b. Based on 1967 SIC.
c. Based on 1972 SIC; preliminary figures.
d. Includes “Other Industries”.
Source: Employment data from: Employment Security Department if New Mexico (figures
based on place of work. Income data from: BEA—Personal Income by Major Sources,
1970—73 and 1974—79.
shift towards diversification with growth in construction, manufacturing and
transportation, communication and utilities. Although the economic base is
expanding, the economy is still dependent on tourism.
There is some potential to attract new non—polluting industries such as
optical firms, science labs, and equipment assembly plants which specialize in
high—technology products that have a high final sales price and small unit
volume. Such industries may be willing to locate where transportation to mar-
kets is inefficient in order to have access to abundant, relatively low—cost
labor and/or a preferred living environment. Generally, Taos is less compet-
itive than other towns trying to attract these industries (Gonzales, 1981).
Taos does have an abundant labor supply and it is a lower wage area; technical
training programs could be established. However, New Mexico communities can
offer companies few economic incentives (such as deferred taxes, etc.) since
most revenues are collected by the State; community infrastructure frequently
is inadequate; and most critically, in Taos, transportation and access to
markets is poor.
Taos is an attractive area and if other problems can be overcome or are
not critical factors to a particular firm, companies could select Taos for its
attractiveness alone. If so, employment might improve without much adverse
impact; however, there would not be much improvement in the current wage scale.

The Role of Tourism . Tourism is one of few basict industries in Taos,
(so labeled because it brings new money into the County and thus supports
growth of’ the local economy). The important economic role of tourism is most
evident in the jobs and income provided in the service and trade sector.
Along with livestock and lumber products, tourism is considered to have the
greatest capacity for stimulating local economic growth (NMSU, 1972).
Several studies have quantified the direct and indirect economic impacts
of tourism. In 1979, the most direct effects in Taos County were as follows
(CID, 1981).
Total travel expenditures 1979 $40,054,000
Travel generated payroll $ 8,015,000
Travel generated employment 1,577
Local tax receipts $ 390,000
State tax receipts $ 1,859,000
These figures do not take into account sales of arts and crafts.
The major indirect effect is that, for every basic job, another 1.5 non—
basic jobs (and possibly more) are created to serve the local needs of Taos
County (Yguado, 1972). Thus, the 1577 jobs directly attributable to tourism
(restaurant personnel, motel workers, tour bus drivers, ski instructors, etc.)
probably account for another 2366 jobs (as for mechanics in local shops to
work on tour buses, clerks to sell the mechanics tools, etc.) In total,
nearly 4000 of county employment can be attributed to tourism, or about half
the basic and half the total jobs. .Jobs associated with arts and crafts are
not included in this total.
The dollars spent by tourists also have a multiplier effect which is
estimated to be about 80 cents for each initial dollar of expenditure (Adams,
1981). (This figure is lower than the job multiplier since much of the money
received by proprietors and wage earners is spent outside of the County;
Yguado, 1972). Combining this factor with the $40,054,000 spent directly by
visitors in 1979, it appears that tourism contributed a total of about $72
million in expenditures, equal to more than 50 percent of total county gross
Formerly, tourism was largely confined to the summer months, but with
growth of the ski industry, winter tourism has increased significantly and
peak winter days now approach summer peaks (Armentrout, 1980). This change
has been beneficial to tourist—oriented businesses, most of which are marginal
and heavily impacted by the seasonality of tourism. Winter tourists also tend
to be destination visitors who stay longer and spend more than summer visi-
tors, thus contributing proportionally more to the economy (Mimbres, 1978;
NMBJ, 1979). However, winter tourism is more vulnerable to the weather than
summer visitation.

The Economic Influence of Taos Ski Valley . Based upon visitation and
skier expenditure data, it is estimated that skiers at Taos Ski Valley contri-
buted to about one—third of the total tourism impact in 1979, directly
accounting for about $14,000,000 in expenditures and 335 jobs in the ski basin
as well as 150 to 200 direct jobs in the region. USFS (198la and 1981b)
contains a more detailed analysis (with similar results) for the 1979—80
season; their analysis is summarized in Appendix D.l of’ this EIS.
Twining Employment . About 335 people are employed in Twining during the
winter, although this number varies depending on snow conditions. ISV, Inc.
accounts for about two—thirds of these employees; the others are employed
primarily in the lodges and condominiums and their associated restaurants.
Jobs created within the resort complex tend to be filled by persons who are
not long—time residents of the area. This is at least partly because of the
presence of transients and newcomers who aggresively pursue the jobs, who have
skiing skills, and who are willing to work in the evening hours. The skiing
programs underway for area children will produce local residents trained in
skiing skills, which may somewhat offset this trend.
The following characteristics are associated with most of the resort jobs
held by Spanish—surnamed persons native to the area: they are service posi-
tions, with income and benefits comparable to service positions held by
others; they are seldom of a supervisory nature; and they are limited to the
winter seasons. Data on Twining employment are included in Appendix 0.2.
Special Economic Issues . Several issues have been raised concerning the
possible economic penalties associated with the income and jobs generated by
the ski industry in Twining. (This is separate from issues of’ cultural
impact, discussed in section 6.6.2). Three such issues were selected for
study In this EIS: tax subsidies; property values; and buying power.
Appendix 0.3 provides data which address the question of whether or not
federal, state and local tax dollars subsidize the private enterprise which
occurs in TWSD. The analysis suggests that skiers generate much more in tax
revenues than they require from government expenditures and that there is no
net subsidy of commercial activities in the District.
Appendix D.4 addresses the question of whether the presence of Taos Ski
Valley affects land values in the surrounding area. Based on the price of’
residential properties (without water rights) in and near Taos County, the
impact of the resort complex Is prominent in the Twining—Amizette area where
the effect on land costs is up to $45,000 per acre. A lesser impact occurs in
the Valdez-Arroyo Seco vicinity, where land prices may be up to $2,000 per
acre higher than in some other parts of the region, due at least in part to
the presence of the Ski Valley. Assuming that the entire difference was due
to the resort, the effect of Taos Ski Valley has been to increase land prices
near the mouth of the Honda canyon by about $200 per (non—Irrigated) acre per
year, which is perhaps 50 percent above the average. Further away there is no
apparent direct impact of’ the resort. It is possible that the current pattern
will change with time, particularly if pressure for development at the base of’
the mountain increases.

Appendix 0.5 provides data which address the question of whether the shift
toward a tourist economy has had an inflationary effect such that the local
cost—of—living has risen faster than income. Based on approximate data, the
analysis suggests that Taosenos have about the same comparative buying power
as in other parts of Northern New Mexico. This does not necessarily mean that
Taos natives have made real economic progress in recent decades, but rather
that inflationary factors are typical of the region and not especially high
because of local development such as ISV, Inc.
County Infrastructure . There are several types of infrastructure (ser-
vices and facilities) which can sustain impacts from county growth in general
and Twining growth in particular. These include highways, water and sewer
systems, and energy and communications facilities.
Traffic to the resort uses Highway 150 between Taos and Twining. This
road’s capacity varies from 1242 vehicles/hour in the first five miles to 1800
vehicles/hour for the remainder. The average daily traffic ranges from a
little over 2000 vehicles/day in the Arroyo Seco area to 600—700/day further
up towards Twining: while hourly use varies, it is still well below the
capacity of the road (Hayes, 1981). The road is in fair condition but is
deficient from a safety standpoint due to such problems as narrow bridges and
numerous sharp curves. In 1979, there was a total of 32 accidents on this
road; the accident rate is particularly high near the sharp turn just past
Arroyo Seco leading up to the Canyon. At this time, there are no plans for
the road other than routine maintenance. Former plans to extend the road
through to Red River have been canceled (Hayes, 1981).
The Town of Taos has community water and sewer service. The water system
is adequate and can accommodate some growth. There are plans to expand this
system to handle close to 10,000 people In Taos and its environs. The sewage
system is presently overloaded. The comunity is preparing plans to expand
this system; and facilities to serve about 8,000 people should be available in
two years (Sayre, 1981).
Unincorporated communities nearby generally have a small ‘mutual domestic’
water system which is already at or near capacity and which would require
expansion if growth occurs. For both the Town of Taos and the other comu—
nities, some water rights will probably need to be retired in order to allow
expansion of the water system; however, Taos is expected to use Its allocation
of San Juan—Chama Project water for the bulk of its needs over the next 20
years. Several communities near Taos have formed or are considering formation
of sanitation districts to develop sewage collection facilities (with inde-
pendent treatment plants or hookup to the Town of Taos facility).
There are two power lines which serve Twining, one from Red River and one
which comes up the Canyon. The Kit Carson Electric Cooperative does not anti-
cipate any problems in providing power to serve future growth in the Hondo
Canyon area. In addition to recent construction of new telephone cables, in-
stallation of a new substation is planned to solve current problems with ser-
vice. Based on statements made by appropriate officials, the resort has no

significant adverse effects (and in some cases has positive impacts) on such
community institutions as the hospital, school system, and landfill (Wilson,
Twining’s Infrastructure . As defined by the community, major infrastruc-
ture needs in Twining are for improved water and sewer systems and improvement
of parking facilities for skiers. Some expansion of TSV, Inc. base facilities
is also desired. Current problems and possible solutions for the sewer system
are presented in chapters 3 and 5 of this EIS; the water system is discussed
in section 6.2.4 and Appendix C.
A 30—year master plan has been developed for Taos Ski Valley, Inc. The
improvements are intended to relieve traffic congestion and improve the
quality of the skiing experience. They could also allow a longer ski season.
The improvements will not fully develop the potential capacity of the ski area
since the proposed skier limit is less than the capacity of the mountain. The
schedule of improvements is based partly on the lack of an adequate sewage
treatment plant. Facilities which would contribute wastewater to the plant
would not be constructed until after the sewage problems of the area are re-
solved. Table 6—6 summarizes the improvements proposed by the master plan;
the proposed actions and alternatives to it are evaluated in a separate ElS
(USFS, l98la and 1981b). The Forest Service has approved the master plan
(with modification). The Forest Service decision has been appealed by members
of the public on the basis that the Draft and Final EIS’s were deficient; the
decision has not yet been implemented. The appellants also requested a stay
on implementation of the plan. The Regional Forester granted a stay on the
up—mountain development but decided to proceed with the parking development
for safety reasons. This decision has also been appealed by the public.
6.6.2 Cultural Patterns
The quality of life in Taos is strongly interwoven with its complex cul-
tural history and traditional agrarian economy. Statistics do not adequately
express the strength of area traditions, but they do demonstrate the dominance
of a Spanish-Indian population. Table 6—3 indicates that about 66.5 percent
of the county’s population identifies itself as of Spanish heritage, and 6.6
percent are Indian.
These groups, along with a well—established artists colony (primarily
Anglos who started arriving at the end of the last century), form a tn-
cultural society in which each culture retains many of its traditions, not
only during holidays, but on a daily basis. The Spanish and Indian social
structure is based to a large degree on an economic system which derived from
irrigated agriculture. That is, the culture of the region represents an
adaptation to an agrarian environment. Despite the rapid decline of family
farms in much of the U.S., small-scale, subsistence agriculture remains an
important part of the human fabric in Taos, a fact which testifies to the
value which TaosenoS place on their rural way of life. Anglo immigration to
the area is, at least in part, based upon the attractions of this lifestyle.

tt-w’ ISV, 1r ’. master plan has been revised to reflect the modifications recultirin from the United States Ferrof rorvier 115 pI(OP . lhrjr Onilysls
addressed facilities involving rorest Service lends, i.e, up—mountain facilit foc arid cirr-ljlstjor u arid porlirn.
facility which ceuld potent tally discharge In sewage treatment plaiui
I YUF Pr I lf PflVE Mt t It
CIrLulat 11)0 nui1 Pankmna
Short- term
(1—5 yeats)
Construct 2 lifts and tialic
Schwerdl restaurant (private
land) !‘
Construct up—mountain restaurant
Construct garage
Construct ski patrol facility
Expand east permit be indary /
Re I oral campqrrni nd in corn luir.ct I on
with cirarnucs tu park jn 11 lot
Estatlish service stat ion,
info treat ion hoot I , ticket hnet he
See also, circulation anti psrkioq
rcnannl rtmit tinirnniary thy 71.9 fr )
Rrvior road netwnrl , ann onand 1 ikIo 5
lot capnicitv Irim 6011 In 1,0f5 vclnicln .
There would be emnrnnenlcy parkinu fir ano t kr
7211 vehIcles. Inrlrjdni truc/struittle loaiincj
ar ’s, ppitestrian walkways, Inasserner
drop—off area, 1 Srndscap into arid rlri I flare,
clans, and traffic control measures.
0 ’
It termed late - te tm
(5—iCu years)
Long— to flu
(i0—Yj years)
C nstIuct 2 lifts
Hemnve I lift
Construct 2 trails
Snnwmskinq expansion
Construct ii lifts /
“Relocate and expand day—skier
f ciliti s (on private ]andl
wCunstriict mall, restaurant, and
other visitor facilities (on private
•ArId it ions 1 ciunmmr .i cia 1, condinil r ilirn,
arwi seco’ id—home dr vol it rent miii
private land
a. This was constructed in late tall 1951 ).
b. To bring existinct El Funko trail into permit area.
c. Ihe e lifts were rut xp1ir1tly approved by flue ro 5; will he
reevaluated prior tin drvelnnniemmt

Agriculture is also of economic significance to some individual families who,
by growing foodstuffs, reduce the pressures on limited cash resources.
Any decline in the viability of agriculture in Taos County has profound
cultural implications and, for that reason, is almost certain to be resisted
by a substantial portion of’ the population. Thus, there is widespread
interest in the effects of wastewater management in Twining on irrigated
agriculture. Water resources is one of the primary issues, since without
water agriculture cannot survive. Another basic concern is the possible
conflict between ‘progress’ (economic growth resulting from tourism) and the
ability to sustain the traditional lifestyle.
As with any cultural phenomena, the subject is extremely complex and
difficult to analyze. It is certain that there has been some damage to
irrigated agriculture and cultural tradition in recent decades, and that some
of’ these changes have occurred over the same time period as the growth of
tourism in general and Taos Ski Valley in particular. It is equally clear
that the very continuance of rural life is now uncertain, and that the
deterioration of the water supply is a major part of the concern. What is not
clear is the extent to which there is a cause—effect relationship between
tourism, water supply and cultural change. That is, some causes and effects
do exist between tourism and cultural change; but there are many other factors
Fiich also have an important influence on water and culture in Taos County.
As one of’ the most visible factors, tourism receives much of the attention;
but, the other factors also nust be considered in determining how those who
wish to do so can best resist continued cultural change.
An analysis of the agrarian lifestyle, and the reasons for its ongoing
alteration, was published in a recent Taos County report (see Chapter VII, by
Diane Flock, in Wilson, 1980). The factors causing change can be grouped into
three major categories, as discussed in the paragraphs which follow.
Physical Limitations to the Use of Land and Water . Taos Is a marginal
area for agriculture. The growing season is short and variable and surrmier
precipitation is variable. Thus irrigation depends on naturally unpredictable
surface runoff. Moreover, as described in section 6.2.2, there has been a
countywide trend of reduced runoff, caused by tree growth in forest lands and
by drought conditions. This decrease in surface—water supply has undoubtedly
been a major factor limiting agricultural production and causing some Taosenos
to abandon their family farms. In some areas, as the Rio Hondo watershed,
water quality has also deteriorated and the stream is considered less suitable
for irrigation.
The land itself is fragile. Soils are relatively poor in comparison with
major agricultural areas. The availability of arable land is limited, most
having been in production since the 1600’s.
Increased Need for Land Resources, Decreasing Resources Available to the
Individual Operator, and Inefficient Use of •the Land . Over the centuries,
continuing increases in the population of Taos County have placed pressure on

the limited land and water resources. At the same time, factors related to
the social and cultural history of the region’s population have also
contributed to the change in the agrarian lifestyle. These factors Include
decreasing productivity of’ the land, reduction of land and resources available
to the family, and small—scale farming practices.
The decrease in land productivity reflects overuse as demand for
production steadily increased to support larger populations and to meet rising
expectations. By the early 1900’s, depletion of the resource base was severe,
especially on grazing lands.
Lana holdings originally included family owned irrigated lands (generally
a maximum of 40 acres) plus access to common lands for grazing, water, timber,
and hunting. This amount of land is probably near the minimum needed to
support a family. However, over time these holdings decreased to the point
that, by 1939 the land available to the average family was only 6 acres (of
which only about 4 acres could be cultivated due to land requirements for the
house and other non—agricultural use). There are several causes of the
Land potentially available for settlement to accommodate excess population
was lost when New Mexico became a U.S. territory. During the same period,
the use of common lands was restricted due to loss of title and/or
overuse. Also, small operators found it difficult to compete with
commercial users for access to federal grazing lands.
The average size of the family plot steadily decreased because of the
Spanish tradition of dividing the land equally among the heirs.
For most families, land represents the only asset available to meet
financial obligations and sale of the land Is the principal means of
raising needed cash. Land was sold originally to pay lawyer’s fees in
order to establish claim to the land In U.S. courts. Later it was lost
for non—payment of taxes and other assessments (particularly during the
Depression), and throughout It was sold to raise cash when other means
were unavailable.
Finally, in the urbanizing areas high land prices offer an incentive for
the sale of land to those who want it for construction of homes and
businesses. To a lesser extent, the potential income from the sale of
water rights leads to sale of farmland. Increases in valuation because of
prospective sale in itself can raise taxes on agricultural lands and speed
the conversion process.
The current resource base may not allow the average fa ily to survive solely
on subsistence agriculture.
Small—scale farming practices hamper production on the small farms which
dominate Taos County. Land inheritance patterns have resulted not only in

smaller lots but also long, narrow lots (to maintain access to both road and
stream frontage) and, for many, land is scattered throughout the area. Modern
farming methods (i.e., machinery) cannot be used efficiently on such land.
Also, almost all irrigated land is devoted to the support of cattle or sheep.
While this pattern of use was undoubtedly prompted by the loss of comon
grazing lands, it does not use resources to produce the highest yield crops.
Other factors which prevent the realization of the land’s production potential
include: the use of unlined irrigation ditches permitting seepage; little use
of fertilizer; and limited use of techniques to prevent soil erosion. Often
these conditions are in turn the result of the lack of capital to invest in
improvements and due to the subsistence nature of most operations, it is
frequently not realistic to make substantial investments.
Economic and Social Trends Affecting the Rural Way of Life . External
factors also contribute to change in the subsistence agricultural lifestyle of’
Taos; the most Important are the shift to a cash economy, involvement In the
national agricultural economy, and exposure to social change.
The shift to a cash economy began from the first arrival of entrepreneurs
from other areas, and evolved at an increasing rate through the latter half of
the 19th century. Construction of the railroads in the 1870’s permitted
economic development on a scale unknown before and introduced a new,
commercially—oriented economy with many wage jobs in commercial farming,
ranching, mining, logging, construction (at a time when farms were already
insufficient to meet the family’s needs). For most, this meant working away
from home part of the year, establishing a migratory work pattern which lasted
until the depression.
Need for money steadily Increased due to many factors:
— taxes and assessments to pay for Improvements such as domestic water
systems, range improvements, and roads;
— advancing technology, and exposure to other lifestyles created a demand
for certain goods which came to be regarded as necessities, such as health
care, electricity, refrigerators, washing machines, and automobiles;
— reduced production from the land (discussed earlier) required families
to purchase what they once provided for themselves, including food,
clothing, home building materials, and feed for animals.
These needs In combination with the others presented the family with an ever
increasing need for cash.
Economic changes were not only local, but reflected shifts in the national
agricultural economy. Specifically, modern farm markets are urban centers,
which are most efficiently supplied by large, high—yielding mechanized farms
located along major transportation corridors. Few farmers In Taos have been
able to develop commercial enterprises to supply these markets. Further,
subsistence operators lost local markets for their products when these markets

switched to regional suppliers. In essence, in terms of the national economy,
the Taosenos generally fit the category of the small operator who has been
forced out of commercial agriculture. Today most subsistence farming in Taos
provides food for the family and for some, extra income, but it is no longer
the economic base of the area. However, In Taos, unlike other regions of the
U.S., subsistence farming remains an important part of the social tradition,
and this represents an activity which is essential to cultural survival.
Social change, evolving primarily from external factors, parallels, but
lags behind, economic change. Increasing exposure to new values occurred both
as people went to other areas to work and as newcomers came to Taos. World
War II greatly increased this exposure. Many Taosenos left to serve In the
armed forces and to work in defense factories in California. They were
exposed to the nationwide development of new ideas, standards and lifestyles
which were more urban, less rural’ and based largely on Anglo rather than
traditional Spanish values.
Tourists are one of the factors contributing to increasing exposure to the
outside world. The unique cultural mix and agrarian atmosphere of Taos
(coupled with spectacular scenery) are primarily what draw tourists to the
County. But these tourists also bring new ideas and new demands for what the
area should provide and thereby themselves create pressures to change the
area’s character. It is not only the tourists who create change. Social
change results from all exposure to other areas and this comes in the form of
education (dominantly in English), travel, radio and television, and changes
in religious practices, to name only a few of the sources introducing new
alternative ideas and values, many of which are urban and threaten traditional
values based on the land. In short, with modern communications and
transportation systems, Taos is no longer isolated from national and global
While tourists are not the only cause of change, they are highly visible.
Local attitudes toward tourism vary depending on many factors. Based on
public participation testimony, many Taosenos who directly benefit from the
ski industry are supportive of tourism. This includes members of the business
community as well as individuals whose jobs in the resort complex have helped
them remain on their land. Often these individuals point out the very
substantial employment and income benefits of tourism, the importance of free
enterprise, and the ability of Taos to adapt to change.
Those who benefit less directly, or not at all, tend to be less supportive
or are opposed to expansion of this segment of the economy. Their objections
reflect numerous areas of conflict which create friction:
— tourists are personal representatives of the modern, urban values which
are encroaching upon the traditional society; natives who want to retain
the old values resent this invasion;
— tourists, skiers in particular, are generally more affluent than the
local population;

— community members who directly benefit from tourism are also often more
affluent than the local population and include a high proportion of non—
— tourists are using land for recreation that the natives want to use to
maintain their traditional livelihood;
— residents feel that the activity and development In Twining disturbs
the natural harmony of the mountains, and further that this adversely
affects the supply and quality of the water used to support downstream
— the jobs provided by tourism tend to be low—skilled and low—paying and
are often viewed as having a law ‘value’, contributing little to a
person’s self—esteem;
— the industry is seen as obtaining special benefits from government, as
for example public funding of the TWSD facilities plan and ElS; many feel
such funds should be spent on programs oriented more toward the needs of
the native population.
It is difficult to synthesize these attitudes into a single phrase, but
perhaps the notion of ‘adding insult to injury’ characterizes the position of
many persons who do not favor a tourist—oriented economy (and especially
skiing). The injury is viewed as including adverse impacts on land and water
resources and traditional values; the Insult includes the use of’ public funds
to further this development and the concept that the wealth so produced, which
natives are told Is the reason for such support, comes to them visibly through
service jobs waiting on tourists. The preference Is for alternative types of’
growth and development which are compatible with the established culture and
which do not require such an adaptation to a new way of life where the
traditional lifestyle Is lost.
Thus, resistance to resort expansion represents, at least In part, the
perception that tourists are a threat to the continued existence of the
traditional lifestyle and that the newly evolving economic and social system
offers the native no advantage, nor even an equal share. However, as noted
earlier in this section the cause—effect relationships influencing the local
culture are complex. It is not clear If all those who oppose increased
tourism understand that this position attacks only a part of the problem.
Taos, like countless rural areas elsewhere, is changing for many reasons; it
is doubtful that the established culture can be sustained unchanged even if
everyone so desired. Indeed, much of rural northern New Mexico does not have
the tourist invasion experienced by Taos, yet experiences many of the same
problems in maintaining an agricultural tradition.
The complexity of cultural phenomena, and the inevitablity of change, are
not reasons to Ignore impacts which may result from such actions as a new
treatment plant in Twining. Rather, effective, long—term solutions to social
and economic problems require effective, long—term management of as many of

the controlling factors as practical. While social and economic considera-
tions must play an important role in TWSD’s facilities planning and EPA ’s
decisions about facility funding, these cannot substitute for comprehensive
planning and locally based decision-making about such factors as the role
tourism should play in the economy and the means by which agricultural land
and water may best be protected.
Summary . Changes in the traditional agrarian lifestyle in Taos County
have been ongoing for many decades and are caused by many factors, including
(in order of’ presentation here, and not necessarily in order of importance):
natural limitations of soil and water supply; changes in water quality; a
recent trend toward reduced runoff; past overgrazing; the loss of’ land grants;
the high cost of using federal lands; decreases in the size of irrigated
parcels; the fact that land is among the few assets which can be sold to raise
cash; loss of land for non—payment of taxes and other assessments; the high
value of land in urbanizing areas; the value of watdr rights; small—scale
farming practices; the lack of capital to Invest in farm Improvements; the
development of a commercially oriented economy (especially since construction
of the railroads); the rising importance of cash, wages and emigration in
response to this economic change; the increased need for money to pay for
community improvements and newly defined necessities of life (e.g. health
care, electricity, appliances, automobiles); the need to purchase food,
clothing and other products formerly produced on the farm; the national trend
toward food markets which are supplied by large, mechanized farms; and
increasing exposure to outside values (especially since the beginning of World
War II).
It seems evident that these factors, which have arisen from many causes,
have substantially reduced the ability of Taosenos to derive a livelihood from
the land and therefore have had a significant, adverse Impact on the agrarian
lifestyle and cultural tradition of Taos. The surprise is that subsistence
agriculture continues to play such an important role in the community.
Although Taosenos derive some economic benefit from farming, the economic
importance of irrigation appears to be secondary to its role as the cultural
foundation of the community.
Because there are so many factors which have influenced cultural change in
Taos County over a very long period, because there are few data describing
soclo—economic trends over the past centuries, and because of limitations In
study methods, the state—of—the—art in socio—economic analysis does not permit
quantification of the magnitude of change associated with the development of
Taos Ski Valley.
For example, to truly assess the effects of Twining on farming one would
have to resolve long—standing debates about the irrportance of land grant
losses (and lot splits, etc.), then separate out the water—resource effects of
retiring 10 acres of land versus climate and watershed changes which have
reduced runoff by several thousand acre—feet, then try to determine whether
people who emigrated before the ski valley did so for reasons different from
those who emigrated in the 60’s or 70’s (assuming these people could be

found), and so on. The analysis would have to derive sufficiently precise
correlations to enable firm predictions about future change should the resort
develop further; and to be of value to EPA, the predictions would have to be
sufficiently sensitive to distinguish between the effects of capacity
alternatives which, in reality, do not lead to markedly different future
conditions. A comprehensive study of these issues is beyond the scope of a
facilities plan and EIS; even for a countywide plan, only a few of these
factors could be assessed adequately.
Based on a more generalized analysis, and considerable public input during
the planning process, it is very likely that tourism is responsible for at
least a portion of the following factors: changes in water resources, high
values on (and incentives to sell) agricultural land in prime growth areas and
land with water rights, the value of water rights, the development of a
commercially oriented economy, non—agricultural use of’ public lands, and
increasing exposure to outside values. The economic benefits of tourism are
very substantial but not equally shared nor always desired. Wastewater
management decisions must reflect these factors, but a comprehensive
resolution of the cultural issues which face the community is not possible
within this EIS and can be accomplished only by the people of Taos through the
political process, for example, through preparation and adoption of a
comprehensive plan.
6.6.3 Development Potential and Population Projections for Twining
The development potential and projected population in Twining will
determine the future sewage flows which must be managed and will identify the
magnitude of potential growth impacts. Normally population projections for
sewage—treatment plants are established by the state as part of their
statewide planning process. Such projections are intended to reflect
established trends in development, and often show a 50—100 percent increase in
growth over a 20—year period. However, for Twining the state projection was
that the peak—day population in the year 2000 would be 4000 persons, a number
which has already been exceeded. Therefore, a more accurate population
projection was developed for use in evaluating alternatives (Wilson, 1981).
Forecasts of the growth in resort areas is always difficult because such
areas are very sensitive to external economic factors. Twining poses a
special problem because there is no formal master plan for development in
TWSD, nor are there zoning regulations or other laws to control land use
(except within the Pattison subdivision). The only basis for projections is
to consider what has happened in the past, and what people say or believe may
happen in the future. Thus, the approach used In this report involved the
assessment of many factors which could influence the growth potential of the
area, such as past trends, existing conditions, and known development plans.
The implications of these factors were discussed with persons familiar with
TWSD (including District members and realtors), and a range of projections was
established reflecting alternative development scenarios. This section
reviews the development potential of’ Twining and presents the resulting
population projections.

Past Rate of Growth . Development of the ski area began in the mid—
fifties. Most existing facilities were built during the sixties, but growth
continued through the early seventies. Although only one new lodge was built
in the early seventies, this coupled with expansion of’ other facilities,
increased overnight capacity of lodges and condominiums from 411 in 1970 to
931 in 1979, a 127 percent increase. (The figure of 931 includes both live-in
residents and overnight guests.) While cabin growth has occurred more slowly,
a total of 59 cabins have been built over the last 15 years or so; this is a
rate of four per year. During the past few years cabin development has been
somewhat erratic but it does not appear that current economic conditions have
slowed the rate of cabin construction (Bryan, 1980).
High—density development, however, has been restricted in recent years by
the lack of sewage treatment capacity at the TWSD plant and the moratorium on
sewer hookups which has resulted. A few exceptions to the moratorium have
been approved (for example, to permit a new bathroom during remodeling).
Also, some expansion has occurred by adding rooms without increasing the
number of sewage connections. Despite this activity, the moratorium has
definitely limited high—density development, as well as expansion of TSV, Inc.
base facilities.
Expansion Potential . A map and description of’ current land use in the
District is presented in section 6.6.1. Lots within the Pattison subdivision
have specific land—use restrictions (e.g. commercial, residential) but
otherwise there are no legal controls on land use in TWSD. Consequently,
there are no effective development or density restrictions other than those
imposed by the terrain or by wastewater treatment capacity. These
restrictions are discussed below.
Within TWSD there are three large undeveloped properties, totaling over
100 acres, which could accommodate a significant amount of growth (Figure
6—6). One of these large holdings is tract H owned by the Pattisons. The
southern portion of’ the tract is the land for which the Kachina Village plan
was proposed, which would have housed more than 2,500 people. This land is
available for development. However, the fact that the entire wasteload
allocation is held by Twining, and that it does not allow for substantial
growth in the short-term, indicates that a project the magnitude of Kachina
Village would not be built in the near future (unless an Independent, total
recycling treatement plant were used). However, this type of development, or
at least some use of the Pattison tract, remains a realistic potential In
perhaps 15 or 20 years.
The other two large holdings, 33 acres owned by the Burroughs and 18 acres
owned by the Twining Association, have potential for development of overnight
accommodations and/or commercial ski—related facilities. At this time, the
Burroughs have indicated an Interest in retaining their land In its present
state. The Twining Association land, however, has been discussed as the
potential site of a condominium development or, possibly, additional skiing

In addition to these three large vacant tracts there are also 94 cabin
sites which are as yet undeveloped. All but 15 of these have been purchased
and, so far at least, people have bought with the intention of eventually
building rather than for speculation so it is likely that they will be
developed during the planning period (Bryan, 1980; Kleiner, 1980). Further,
most existing developments could be expanded to accommodate growth.
Capacity for Development . From an engineering viewpoint, virtually all
land within TWSD is potentially developable. Rocky and marshy soils place
some constraints on construction, particularly for septic tank systems, but do
not prohibit development if specialized wastewater systems are used. The most
severe constraint on construction is steep slopes. Still most of TWSD has
slopes of less than 40 percent. Such areas are considered buildable, if
access is feasible. There is some developable land outside TWSD. This land
includes parts of the National Forest and parts of the remaining holdings of
the Pattison Trust. Except along the river valley extending to Bull—of-the--
Woods Pasture, access to this land would be a major obstacle to development.
While estimates vary, previous studies indicate that the 267 acres within
TWSD could accommodate between 4,000 and 4,500 overnight residents if fully
developed (Taos Architects, 1970; Beardsley—Davis, 1973). If such development
were at current high densities (10 units/acre +), not all of the buildable,
accessible land in the area would be utilized. Therefore, at least
theoretically, an even greater number of persons could locate in the area. In
summary, the availability of buildable land is not a severe limitation to
development of additional resort facilities in the Twining area. However,
access may affect the economics of development, such that not all the land
would be put into a high—density use.
The effect of restricting sewage treatment capacity on development is
uncertain. As noted previously, it is physically possible to construct some
type of on—site wastewater system on most (if not all) land in TWSD. Although
this poses an economic barrier to development, it is one which may be overcome
considering the commercial nature of the area and the high value of land.
TWSD would have authority over on—site systems. As long as there is
insufficent plant capacity to accommodate new growth, TWSD would not prohibit
on—site systems in the District. However, regulations could limit the types
of on—site systems used, with preference given to alternatives which do not
involve conventional septic tank drainfields. Theoretically, the limit on
total pollutants which may be discharged from area sewage systems would
ultimately prohibit any future development, except for construction
incorporating total recycling systems.
Plans for Development . •TSV, Incorporated. The ski corporation has the
announced intention of limiting lift—ticket sales to 4800 per day. In all the
discussions presented in this report, it is assumed that the Ski Valley will
be successful in accomplishing its stated objective. It is by no means
assured that this limitation can be imposed due to legal, management or other
constraints. If the limitation is not successful then day populations would
be much higher than indicated in this report. Since the ski limit is only 10

percent greater than the peak day in 1979—80, It could probably be reached in
the next good ski season. However, until sewage treatment problems are
resolved, there is an interim limit of’ 4,050 skiers per day. TSV, Inc. has
also indicated interest in expanding base facilities, including some
restaurants (section 6.6.1).
Lodges and Condominiums. Current development proposals by TWSD landowners
include the expansion of existing facilities, as well as the construction of
new condominiums and lodges. In general, these proposals represent
openly—discussed intentions, rather than formal plans and specifications.
Interviews with TWSD residents indicate that if a resolution of the sewage
problem so permitted, much of the proposed development would occur within 1—5
years. At a minimum, by 1985 new construction could include the expansion of
existing facilities and two condominiums which are currently in the planning
stage. This would add 1,169 pillows to overnight capacity, a 125 percent
Beyond the development discussed above, there Is talk concerning four
sites on which additional condominiums/lodges might be built. Also, some
lodges have indicated an interest in long—term expansion. In both cases,
there are few specifics in the discussions. Based on interviews with local
residents, such development would probably occur in the period 1985—1990, if
not by 1985, and could involve more than 680 new pillows. Coupled with the
development discussed previously, the total increase in overnight capacity
would be more than 1,849 pillows, which would represent a growth of at least
200 percent over current conditions.
Cabins. Interviews with TWSD residents indicate that there are no factors
which would markedly change the historic pattern of slow, steady cabin
development. There are 94 lots in the cabin subdivision which remain vacant;
79 of these have been sold. At historic rates, four cabins would be built per
year, so that all the sold lots would be occupied by the year 2000.
Development Beyond Announced Plans . It is not certain that all of the
proposed development would occur even if there were no water—quality problems
in the area. For example, setting a limit of 4800 skiers might reduce
interest in the development of overnight accommodations. (Or, it could slow
condo growth unless and until the area were to become a summer as well as a
winter resort.) Still more uncertain is whether or not development could go
beyond announced plans. Some large ski resorts have more overnight capacity
than lift tickets; for Twining, it is at least theoretically possible to
foresee an overnight capacity equal to daytime capacity. This equates to a
demand for perhaps 5,000 pillows, a level which is within the physical
capacity of the land, and a level which could result from a project the
magnitude of Kachina village. The purpose of this observation is simply to
point out that even the high projection given in this report does not reach
the level of growth which is possible in the area.

Projected Growth in Twining . The review of past development and future
plans in the Twining Water and Sanitation District (TWSD) provides a range of
predictions about the number of residents and visitors who could contribute to
wastewater flows in the year 2000; see Table 6-7. The actual numbers will
depend on the development policies adopted by the community or, if no policies
are adopted, on economic conditions. The projections concentrate on peak
winter conditions which represent the maximum flows which must be handled over
a prolonged period.
Five growth scenarios are presented. Based on alternative growth
policies, four predictions were developed: the lowest estimate, representing
no increase in the current skier limit and no high—density growth; a low
estimate, representing an increase in the skier limit but no high—density
growth; a high estimate, representing TWSD’s desired level of growth; and the
highest estimate, representing the magnitude of growth which could occur from
construction of all proposed new lodges and condos (excluding Kachina
village). In addition, populations associated with a 95,000 gpd plant have
been developed and included in the analysis, since this size plant has been
identified as the maximum which can be built and still protect stream
standards. This projection allows a moderate amount of growth, representing
an increase in the skier limit and some high density growth. Table 6—7
includes the assumptions used to develop the projections and presents the
actual numbers for each component of the population (i.e., employees, skiers,
and guests). Although the high projection is the maximum contained in this
report, higher populations (particularly at night) would occur if every acre
of developable land in TWSD were fully utilized for overnight facilities.
with full development, overnight populations could exceed 5,000 people.
Projected Sewage Flow . Design flows for the sewage treatment plant have
been developed for each population projection and for existing conditions.
These figures and their derivation are presented in detail in Table 6—7. A
major difference in the projections relates to assurr tions as to which
portions of the population would be served by the central wastewater system
versus those that would be served by on—site systems. The existing central
system serves five (of 59) cabins, and all base facilities except for one
condominium. Five additional cabins have temporary on—site facilities and
desire hookups. For the low population projection it is assumed that the
condominium and these five additional cabins would be hooked up to the central
sewer system. The remaining 44 existing cabins, and all of the projected 94
new cabins are assumed to use on—site systems. For the Intermediate and high
projections, all high—density development (lodges, condos) are assumed to be
served by the treatment system. The Intermediate projection also assumes that
ten cabins (5 now on the system and the 5 additional units discussed above)
would be hooked up, while all other cabins are assumed to use on-site
systems. The high projection assumes all cabins (and therefore all develop-
ment) would be served by the central system. This projection Illustrates the
capacity required to serve all growth discussed in this EIS (except Kachlna

Lodges !
Existing Pillows
New Lodge
Coodcxnjnjtjns “
Existing Pillows
New Lodge
Cabins /
Existing Pillows
Employees /
Dvernig it
Day Dely
Qvern1 - ,t
Day DAly
Overni 1t
Day DAly
3 0 19
See note C
4, 803
Hi —density orowth of’
489 pIllows as permitted
by plant capacity; skier
limit = 4800/day
Desired growth: double
existing lodge and condo
capscity; continued cabin
develooment; Skier limit
= 4800/day
1 ,226
plus see note c
Total Pillows
Existing Pillows
o ’
4 Timing of Development 1
1, 226
See note c
1980—8 5;
1961 conditions No high—density growth No high—density growth;
continued cabin develop- continued cabin develop-
ment; skier limit = nmnt; skier limit =
4050/day 4800/day
Ne additional
plus see note c 1980-85;
011 proposed lodge and condo
development; continued cabin
development; skier limit =
1980—1990; plus see note c
Peak Day Population

TABLE 6—7. (continued).
Hookups ’
Overn1 t Population
on System x 50 gpcd /
Day Population on
System x 10 gpcd i/
Peak_Day Flow froe
HOOkt. s
Average Daily Flow
Peak Week I’
C’ Infiltration J/
Design Flow Y
Sewage Discharged to
On—site Systems 1’
Desitji Flow with Water
Conservation (
Sewage Discharged
to On—site Systems
with Water Conserva-
tion W
1981 conditions
No high—density growth
continued cabin develop—
ment; skier limit =
No high—density growth;
continued cabin develop—
n nt; skier limit =
High_density arowth of
49 pillows as peiv-itted
by plant capacity; vkiej
lull a8 l J/day
tesired growth: double
existicil lodge and condc
capacity; contirijed cabin
Jeveloocenit; Skier limit
vtU0/ Jay
All pI000seci ludqe nd condo
Jeveicliet; C tjuec caL n
Jevelopoent; ‘let lint
Existing; only 5
cabins; Kanidahar
ont on system
All high_density develop_
sent; 10 cabins
All high—density develop—
sent; 10 cabins
All high—density develop—
ment; 10 cabins
All high—density develop—
sent; 10 cabins
All development mci. all
788 pillows
39,400 gpd
981 pillows
49,050 god
981 pillows
49,050 gpd
1470 pillows =
73,500 god
1912 pillows
95,600 gpd
3545 pIllows =
177,250 gpd /
39,130 gpd
36,860 gpd
47,320 gpd
40,735 god
36,610 gpd
21,160 gpd
78,530 gpd
85,910 gpd
96,370 opd
114,235 gpd
132,210 gpd
198,410 god
69,892 gpd
76,460 god
85,769 god
101,665 gpd
117,667 god
176,585 gpd
1,600 gpd
1,600 rod
1,600 gpd
1,600 gpd
1,600 gpd
1,600 gpd
71,492 d
78,060 d
87,369 god
103,265 gpd
119,267 gpd
178,185 gpd
15,806 gpd
25,775 god
25,775 gpd
25,775 god
25,775 god
0 gpd
71,492 gpd
78,060 gpd
84,630 god
95,125 ged
105,690 god
147,830 gpd
15,810 god
20,175 gpd

L LE 6—7. (continued).
a. Existing lodge capacity based on survey described in report on Twining
Water System; expansion estimates based on interviews with lodge owners,
described in sane report; estimate of new pillows made by Chris Stagg
assuming construction of TSV, Inc., Hotel.
b. Condos include apartments. Existing condo capacity based on survey
described in report on Twining Water System; expansion estimates based on
interviews with condo owners, described in same report; estimate of new
pillows made by Chris Stagg assisning caipletion of known development plans
and a maxinun capacity of 3—4 people/romm. Intermediate projection simply
reflects construction consistent with a doubling of overall lodge and
condo capacity. High projection based on: 800 pillows in condo near
Sierra Del Sol (request for 200 hookups already on file); 126 pillows in
condo near Thunderbird; 120 pillows in condo near Ede lweiss; 160 pillows
in TSV, Inc. condo near garage; 200 pillows in condo near Ric Hondo.
c. Cabin capacity assumed to be 5 pillows. Existing based on actual cabins
now built (59 cabins); projection assumes development of all vacant lots
at build—out rate of 4.7 cabins/year (total 94 cabins).
d. Based on discussions with TWSD residents, TSV, Inc. officials, etc.
e. Existing situation based on existing employee count as reported in study
of Twining Water System. For other projections the number of employees is
calculated to increase in proportion - to the increase in skiers and
overnight guests. Of these employees, 30% are assuneo to stay overnight;
the rest are oay employees.
f. Calculations related to skiers arc non—skiers are interdependent. First
5% of total condo and cabin capacity (not lodges) were assumed to be
overnight non—skiers; this is based on discussions with TWS& residents.
Those pillows not allocated to mn—skiers and employees are assumed to be
used by skiers. Skiers not staying overni t are assumed to be day
skiers. Pbn—skiing day visitors are assumed to be 10% of day skiers based
on traffic surveys at the ski valley.
g. Existing hookups include 5 cabins and all hi i—density development, except
the kandahar; low projection hookups assume Kandahar is added to system,
plus 5 existing cabins now using holding tanks. Remaining cabins assumed
not hooked up. Similar assu i ptions apply to intermediate projection;
however in tie high projection aU cabins are assumed connected to
system. Flows (gallons per capita per day, gpcd) based on earlier study
of Twining Water System.
h. Day population on system is the difference between total day population
and overnight population on the system, except that non—skiers who occupy
cabins/rooms not hooked up to the system are assumed not to contribute to
system flows, The existing flows also exclude 8 day employees at the
i. Assumes week—long flows average 89% of weekend peak.
j. Existing assumes current infiltrstion of 25,000 gpd is reduced.
Infiltration figure baseo on standard EPA factor.
k. Average daily flow in peak week, plus infiltration.
1. Flow from rooms/cabins not hooked up to system; excludes day contribution
of skiers who occupy rooms/cabins; assumes week—long flows average 89
percent of peak day.
m. Assumes use of dry (eq. composling) rather than conventional toilets in
new construction; this will reduce flows from new units Dy one—third.

Another variable assumption relates to the effect of adopting additional
water conservation measures. Table 6—7 includes calculations without such
conservation, as well as flows which would result from a requirement to use
dry or extremely low—flush toilets in all new construction.
A final major assumption involves the relationship of peak—week popula-
tions (the basis for treatment plant design) to peak—day populations (the
numbers just calculated). This relationship is known as the loading factor;
presently it is about 70 percent for the ski season as a whole. Past trends
are toward an increase in the loading factor, especially in peak periods. The
limit on lift—ticket sales will reinforce this trend. Based on discussions
with TWSD residents and others, a loading factor of 89 percent has been used
in Table 6—7. This means that for the entire peak week, populations would
average 89 percent of the weekend maximum.
The estimates of sewage flows are intended to indicate the amount of
wastewater which could be generated in Twining during prolonged peak periods.
They do not imply that a single, central plant must be built to accommodate a
particular peak flow. Rather, the adopted alternatives must account for
management of the flows which are associated with the adopted development
6.6.4 Impacts of the No Action Alternative
The no—action alternative would avoid any socio—economic and land use
change resulting directly from treatment plant actions, but not necessarily
avoid considerable change resulting from development in TWSD. Such develop-
ment would reflect increased use of the area in non-peak periods (early and
late in ski season, summer) plus cabin development and other relatively
small-scale growth using independent on—site wastewater systems. The nature
of this development is discussed in section 6.6.6 in the context of the
‘existing flow’ alternative of an 80,000 gpd treatment facility. Also,
continued pollution of the Rio Hondo would interfere with the water resource
needed by summer residents.
6.6.5 Impacts of Treatment Alternatives
The major economic, cultural and land—use impacts of treatment alterna-
tives were discussed in section 5.2. By way of summary, these effects include
the following.
— Direct economic costs to TWSD (and funding agencies) vary according to
the alternative being considered. None of the most expensive options are
likely to be the most cost—effective and there are still substantial cost
differences between the remaining alternatives. The most expensive of the
conventional alternatives is also considered the most reliable, flexible
and capable of expansion; it could produce the best quality effluent on a
day—in, day—out basis. Aquaculture (alternative 2) is potentially one of

the least expensive options, but its reliability has not been proven and
could increase the risk of failure. The final decision must reflect
whether the additional reliability (which cannot easily be quantified) and
effluent quality are worth the additional expense ($35,000 to $40,000 per
year more if alternative 1 is selected over alternative 12).
— Many of the alternatives were found to have major water—supply impacts
(for example, regional options generally increase water—rights require-
ments for TWSD) and/or water—quality impacts (on—site systems and snow-
making probably would violate the stream standards). In turn, these
impacts would have an adverse effect on downstream residents and their
agrarian lifestyle. The alternatives with the greatest adverse impacts
would not be considered most cost—effective.
— Some of the regional alternatives would provide potential benefits to
the regional community, but also have the potential for creating or
increasing community conflicts. Severe land use problems could also
result from the two options which would create a regional sewer system
(alternatives 10 and 11; see section 5.2). These impacts are a major
reason for concluding that the regional choices are not acceptable.
Regarding the ype of treatment process (as opposed to the size of a
plant), the major issii which has not been resolved in the planning process is
whether or not the costs of alternative 1 (in relation to the other two
alternatives) are justified by its additional reliability and flexibility.
6.6.6 Impacts of Capacity Alternatives
The relationship between treatment plant capacity in Twining and the
economy and social structure of the Taos region are quite complex, often
subtle, and difficult to analyze (see discussions in sections 6.6.1 and
6.6.2). In this EIS the emphasis has been on identifying the major changes
which definitely relate to expansion of the resort complex — that is, those
Impacts where a cause—effect relationship can be readily assessed. With these
impacts in mind, it is possible to discuss In a general way those changes
which are more speculative, such. as cultural changes which have multiple
causes and which may depend somewhat on the differing perceptions of different
members of the community.
There are five primary categories of’ change which can be projected to
occur in Twining and which will be discussed in the pages which follow.
1. Economic benefits are, likely to expand simply due to increased use of
the area in off—peak periods during the ski season. This expansion can occur
with or without an enlarged sewage treatment plant and relates to a more
continuous, Intensive use of the area, rather than an Increase in peak use.
2. Increased summer use of the resort complex would have the same effect
as increased skier use in off—peak periods and also would result In more

continuous, intensive use of’ the area. At present there is no indication that
surriner use will increase dramatically, but it could do so with or without an
enlarged sewage treatment plant.
3. There is certain to be some physical expansion of’ the resort due to
developments which use on—site systems (OSS) and which are therefore
independent of the capacity of a central treatment plant. This expansion
could include cabin construction on most and probably all of the 94 vacant
lots in the Pattison subdivision; also, at least some lodge and condo
development could occur in the base area and TSV, Inc. could probably use OSS
to service an increase in the skier limit.
4. If permitted by expansion of’ the TWSD treatment plant, there would be
an increase in skier capacity from 4050 to 4800 per day. This would represent
real growth of the area which would be supported by selection of a capacity
5. The size of’ the sewage treatment plant can influence the location of
new overnight facilities. If an intermediate capacity is chosen (such as
alternative C), which services new skiers but supports no lodge expansion in
TWSD, then there could be an increase in demand for overnight capacity which
must be met somewhere else In the Taos region (or in Twining using on—site
systems). The effect of expanding the TWSD plant to 95,000 gpd, rather than
an intermediate limit of 85,000 gpd, is to facilitate the development of
overnight capacity in Twining. In the discussions which follow, ‘elsewhere’
is referred to as the Taos Region (or simply the region); it includes areas
such as Amizette, Valdez, and Arroyo Seco as well as Taos and, for some
impacts, may extend to Red River, Angel Fire, and Santa Fe.
To help highlight these five types of change it is useful to first consid-
er the impacts associated with items 1 and 4 — changes which relate directly
to the size of the ski Industry. Then it is appropriate to discuss the
impacts of items 3 and 5 — which deal more with the character and location of
resort development rather than the total size of the ski industry. There is
little basis on which to assess possible impacts from summer tourism (item
2). The assumption Is that Twining will not become a major yearround resort;
calculations of impacts (adverse effects only) assume that summer visits
average 10 percent of winter visits. Finally, it is possible to discuss some
of the secondary or indirect effects of all five types of change. As
appropriate, other sections of this EIS deal with the physical consequences of
growth, such as changes in stream flow, water quality, air quality, etc.
Direct Impacts of’ Ski Industry Growth . Table 6—8 sumarIzes the major,
direct effects on population, the economy and land use which would result from
an increase of the skier limit from 4050 to 4800 per day. Many assumptions
were made to develop these estimates, as indicated in footnotes; variations in
the assumptions could change any of the numbers, but for the most part the
table should provide a reasonable indication of the magnitude of’ readily
quantifiable impacts associated with skiing. As a general concept, the table
is based on the following logic: increases in tourism produce a development

This table presents future conditions in the region due to tourism at Taos Ski Valley. Column 2 presents
future conditions which would result even if there is no increase In the skier limit nor construction of
new high-density development. Column 3 shows the effects duo strictly to increasing the skier limit.
Column 4 combines the effects of Columns 2 and 3, showIng the total future effect of ski valley visitors
in the region If the skier limit is Increased but no new high—density developsent occurs. “Skier limit
Increases” assumes limit on lift ticket sales Is raised from 4050 to 4800 per day; reflects a year of good
ski conditions (maximum Impact). Impacts are the total change for the region as a whole and need not
occur only in Twining or t-londo Valley; rushers are rounded off. The changes listed in the table
constitute the major impact of expansion of the winter resort complex which could be associated with any
of the capacity alternatives providing 85,000 gpd or more and with alternative C. Benefits do not include
those from sumner use; adverse effects (land, sewage flow) assume sunm’er use is 10 percent of winter use.
Table 6—9 considers effects related to the location of any growth which occurs.
Peak Day Visitation a!
(No. of people)
Skiers = 4050
Visitors = 320
Skiers + 750
Visitors = + 50
Skiers 4800
Visitors = 370
Annual Winter Visitation /
(person days)
10—20 yrs = 520,000
(Now 275,000)
+ 95,000
Development Pressure /
3850 pillowS
+ 285 pillows
4135 pillows
Winter Revenues “
10—20 yrs = $52,000,000
(Now = $27,500,000)
+ $9,500,000
Jobs !‘
+ 190
New Residents ii
+ 40
Land For Water Rights /
for Non—Residents
10—20 yrs = 22.5 acres
(Now = 12.5 acres)
+ 4 acres
27 acres
Peak Sewage Flow fl/
from Non—Residents
165,000 gpd
+ 20,000 gpd
185,000 gpd
Peak Traffic (parking) /
in Twining
1650 cars
+ 310 cars
1960 cars
Annual Traffic J/
10—20 yrs = 210,000 trips
(Now = 115,000 trips)
+ 35,000 trips
245,000 trips
Piitpuse of taDle is to establish approximate dimensions of change based on a worst case analysis; many
assm ’fttlons have been used to develop a st raight fnrward analysis; inpactS may vary somewhat from tho p
given here if assumptions are cht nged.
a. Skiers and visitors in TW D on busiest day of year; pxc1ud s rmp1oy es. ror subsequent calculations,
80% of skiers and visitors are assumed to require overnight accommodations somewhere in laos area (this is
same as present estimated percentage).
b. Average day population is assumed to increase to 85 percent of peak day with or without increase in
lift—ticket limit (compared to present ratio of 45 percent). Season Is assti d to be 140 days. The
pro ected change due to increase In skier limit (middle column) Is that Increase over and above what will
occur from the incieased use of the ski area in off-peak periods (see text).
c. Lxisting pillows required by historic peak-day use (‘4/400 skIers and a snciated vIsitors; it j
sstjned this demand was net). Increase (middle column) is difference iii piliows associated with 48110
ckiexs vs 4400 skiers.
d. 1980 dollars, includes direct and indirect revenues; roughly equal to $100/visitor_day. cc c Toble 6-9
mr discussion of where those dollars are spent.
e. Direct jobs pius estimated 1.5 indirect johc per dilect lob; see note i.
i. Equal to 50 percent of new ençlloyees In Twining, based on existing conditions.
g. Involves water fnr tourists and new residents only; values for winter season are Increased by 10
percent to reflect Sunxser use. Existing county residents w io ski or work in Twining are not included as
they olace a demand for water whether or not Involved at TWSD. Consumption for snowmaking not included
(see section 6.2.6). Consumptive use Is assuned to he 21 gallons per day for don ct1r use an To require
0.8 acres of land for each acre-foot of consumptive use water right; new use decreased by 33% to reflect
benefits of water conservation.
Ii. total sewage flow generated by tourists and new residents only. (Issumes 10 cipd for visitors; 40
additional qpd for overnight residents; project inns decreased by 33% to reflect benefits of water
etinseivatino; peak day flows factored by 89% to reflect daily uce peak week. Existing enurity rocidents
whe ski or work In Twining arc not Included. (Non—point source pollution a sumrd to Increase in
proportion to annual vi itatjon).
I. Assumes every person who visits EWSD makes one rourwt-tiip to or from the area daily. For prolertlon
of existing ituat.ion, 333 of the 625 direct employees work in Twining; for future assorts’s 76 now
employees work in Twining. Assimnes 3 totjrists/vjsltors per vehicle and 1. / 5 employees per vehicle (based
no current conditions); rio allowance forhenpfjts uf shuttle system.
j. Crxntiinos ass1inptinnc given in iintcs h arid I; simmer use estimated at 114% nf winter tine.

pressure on the community which Is reflected in construction of’ overnight
facilities, increased revenues, and some new jobs which are taken by both
local residents and newcomers. Collectively the influx of tourists and
non—resident employees increases the demand for resources; the table provides
information on two of the most quantifiable resource impacts — land required
for water rights, and sewage capacity (demand for wasteload assimilation
capacity in rivers). Finally, increases in traffic levels are estimated as a
function of the increase in tourism and jobs.
Three important conclusions can be drawn from Table 6—8: many impacts
associated with Taos Ski Valley may double in the next 10 years or so, even if
treatment plant capacity is not increased; raising the limit on ticket sales,
facilitated by increasing treatment capacity, would further increase most
impacts (beneficial and adverse effects) by 10 to 20 percent; the impacts are
regional in character, often occurring outside the Hondo Valley and, in some
cases, even beyond Taos County. Each of these points is expanded upon below.
The second column of Table 6—8, ‘no change in skier limit,’ presents
future conditions assuming there is no increase in the skier limit and no high
density development within the resort. It is the baseline situation,
comparable to the “Lowest Projection” in Table 6—7. The projection includes
the effect of growth in off—peak skiing. Annual visitation has been
increasing at the rate of 15 percent per year and this trend in demand is
expected to continue. Average daily use has been 45 percent of the peak day
use. Any type of skier limit, whether 4050 or 4800 per day, will tend to
increase the average use in comparison to peak use since peak day use is set.
Thus, the forecast is that average use will approach 80—90 percent of the peak
within 10—20 years, and skier visitation will double simply due to this
increased demand. Obviously, there will be years of poor snow conditions when
the off—peak use is low. However, for purposes of a worst—case analysis it is
the years of maximum impact which are of’ most Interest.
The doubling of skier activity would effectively double some of the
impacts associated with the resort complex. For example, the economic
benefits (revenues) from skiing would nearly double and so too would the need
for water rights. Other impacts — those related more to peak—day populations
— would not change. Thus, the table shows no new jobs being created by this
expansion. (Like everything in the table, this may simplify matters; a few
jobs could result simply from the change in business conditions.) Traffic
impacts also illustrate the difference between annual and peak—day effects.
Peak traffic (which influences road safety) will not increase because of
off—peak visits; but total traffic (which influences energy use, air quality,
etc.) will increase.
The third column of the table shows changes which would occur if the skier
limit is increased to 4800 per day. In contrast to the second column, these
changes would be facilitated by expansion of treatment plant capacity (unless
alternative C is adopted; see Table 5—5). The effect of a nearly 20 percent
increase in the skier limit is an approximately 20 percent increase in most
Impacts — from economic benefits to water rights. The increase in jobs is

actually less than 20 percent, because ISV, Inc. employees can now serve 4400
skiers and require only a 10 percent increase to serve 4800.
The impacts defined in Table 6-8 are regional in extent. For example, the
total non—resident sewage treatment capacity required to support 4800 skiers a
day is about 185,000 gallons per day somewhere in the region. If 80,000 gpd
is provided in Twining, then 105,000 gpd must be provided elsewhere (such as
septic tanks along the Rio Hondo and Highway 150 and/or treatment in Taos
itself). Even if the TWSD capacity is raised to 95,000 gpd, this is just
slightly more than half’ the total treatment which will be required.
Impacts of Expanding OverniQht Capacity and Use in Twining . The
development of new overnight facilities does not increase the overall impact
of skiers but does determine where the impacts would occur. Table 6-9
summarizes how these impacts on population, the economy and land use described
in Table 6—8 would be distributed if a 95,000 gpd plant is built. Many
assumptions were made to develop these estimates, as indicated in the
footnotes; variations in the assumptions could change any of the numbers, but
for the most part the table should provide a good indication of’ the magnitude
of where the impacts defined in Table 6—8 are likely to occur. Other capacity
alternatives would contribute to a somewhat different distribution of impacts
as noted in the table and in the following comments. Large capacity
alternatives could also contribute to additional impacts on the regional
lodging industry as discussed in the text.
Several interesting conclusions can be drawn from Table 6—9: an increase
in the skier limit would create a demand for additional overnight capacity at
motels, lodges and condominiums (Table 6—8); this capacity Is small enough
that it might be provided In TWSD with or without an expanded central
treatment plant; it is difficult to predict the impact of providing these
pillows in Twining on the lodging industry in Taos; the benefits (revenues and
jobs) from ski resort growth are regional In nature; the adverse impacts are
concentrated In the Rio Hondo basin and/or along Highway 150 although some
also occur elswhere in the region. Each of these points is expanded below.
The increase in off-peak skiing can be absorbed with little need for
increased overnight accommodations In the region; existing facilities simply
experience a higher occupancy rate. (For simplicity, Table 6—9 assumes no new
facilities). However, If the skier limit is raised then there would be a net
increase in the need for pillows; Table 6—8 shows the increase to be 285
pillows. This Is about a 10 percent expansion of the Taos—area lodging
Industry. If a 95,000 gpd treatment plant is built in TWSD, then all of this
pillow Increase can (and quite possibly will) occur within the District.
Indeed, the projection In Table 6—9 is that there would be 489 new pillows in
lodges and condos and, eventually, another 470 pillows In cabins. Thus, the
increase in overnight capacity in Twining would not only absorb the demand
created by the higher skier limit, it would provide alternative lodging for
visitors who might otherwise stay elsewhere In the region.

Effects of expanding TWSO treatment plant to 95,000 gpd capacity. First column lists categories of chancies. Second column olves effects which
appear to be independent of plant capacity: 0 — increased off—peak skiing; S - sumner growth (estimated at 10 percent of’ winter use); and C -
build—out of cabins on existing platted lots of’ Pattison subdivision. Third col*.snn presents impacts of’ increased lift—ticket sales (from 4050to
4800 per day) and increased overni at capacity in TWSD (490 pillows) both of which could occur using on—site systems, but which would certainly
benefit if there is increased treatment plant capacity: LT = lift—ticket increase; ON = increase in pillows. Fourth column is sraa of effects in
second and third columns. Fifth column identifies impacts outside of TWSD. For purposes of comparison, the effects of overnight facilities in
Twining (marked by asterisk) would shift to the regional column If there were no treatment capacity available in the District, and if TWSD banned
independent treatment facilities for large-scale developments- All numbers are rounded of f. —
Oft—peak • cabins Skier L halt veinight [ timulat 1VC 1 I5 .2c 5 Oteid( of 1 winion
- + iaina r Increase Impacts

Peak [ Siy Population ‘ on effect LI + 000 visitors • 015; now all vIsitors (5170) would pass threunh
(No. of people) LI 4 20 cn loyeeS total 5 h0 region to reach TN -P; half nf new Ca--
110 = + 5Sen lOVeeC py ’s in iwinino o 45 ’IySPd to
C’ new_residents
Winter Visitation ti! 0 - + 745,0(1); LI - + 5 ,fl1)O 3A0,000; nuw
(person days) new total 520,00) notsl s1S,flnI
Overnight Capacity C C + 470; IN • 1,91) (205 ’) ‘50; new ra,f t
(plilows) new total 755 mIni .‘‘IlO
Winter todgir Use C 56,000 IN — ( O ,iI(1O , 1Il, h ; new • 127,01 )0; new totol 2 2
(person niqhts) 0 + 33,11)0 t’tal ;1 ),OtiCI
flew total 701,00(1
Winter ReverueS
Skiing 0 + $4,430,000 LT = + $1,710,000 + $6,140,000
ON C+0 = + $4,220,000 ON = + $2,770,000 + $6,990,000 + $ 5,960,000
Indirect None None None + $15,000,000
Total + $8,650,000; new + $4,480,003 + $13,130,000; new + $20,960,000; new total
total $18,950,000 total $23,430,000 total $38,100,000
Jobs 11 no effect LT = + 20 for 250 + 75 for 410 direct + 0 = 295 direct jobs
direct jobs jobs
ON + 55 for 169 direct + 115 = 1055 indirect jobs
jobs (32k) new total 1350 jobs
Land For Water 0 = + 5.6 ac LI + 0.6 ac + 10.6 ac; new visitors cause increase of’ 5 acres
Rights / C = -F 1.5 ac ON = + 1.7 ac* total 18 ac for total of 9.5 acres
S = + 1.2 ac new residents require 0.25 acres
new total 15.8 ac
(Total regional demand, all valleys
increased by 16 acres to 28 acres)

TABLE 6—9. (continued).
Off—peak • Cabins
+ SL Tm r
Skier Limit + Overnight Cuiulative
Increase Impacts
lrrçacts Outside
of Twining
Sewage Flow !!
C = + 11,000 gpd;
r w total 20,000 gpd
using on—site system
LI + 4,800 gpd
IJ II = • 11,810 gpd*
+ 16,600 gpd; new
total 95,000 d
using plant
+ 11,000 gpd; new
total 20,000 using
+ 1520 gpd (for new
Peak Day Traffic
and Parking /
no effect
LI = + 280 vehicles
[ N = + 30 vehicles
+ 310 vehicles; new
totsi 1960 vehicles
all vehicles (1960)
region to reach TWSD
pass through
Annual Traffic , /
+ 115,000 trios; new
total, 210,000
LI + 32,000 trips
ON = 3,000 trips*
+ 150 000 new
total 245,000 trips
all vehicles pass th
to reach TWSD
rough region
a. Fitiwn table ( —1; 8(1(1 inctririn ckipn’ /nttipr vlsitrris
b. iroiti Table 6-8.
c. Capacity increases bas d 1111 Table c— i. No new emp yer y assumed to reside in lWflfl. 01 tl 1I1 pillows, I I oro (Oral w’rr]l coot litre (p e l
occiipi l by flployees. 011 xict II cti lu iyei not Hvir ill tWoT) rs c000i ( ’rrrcj (Ii ti ’ Ii of tlo area rrd (IT O st L,urdoii ‘a r:onfu ilitil (rO
to the demand ( c li overnight cri acity.
d. As i ies 1(10—day ski season; OVPnni 0 ht Stays RIO ii i whet or vi itatjnrn (Cool III i ’JT I cr t roust! loris). rorrv i i t: rr p fr’r o pr
p1 lot: detsarti not met in T wi iuirn al lOcated to rrsprin.
c. 1 hU dollars; irCroasor ji ’ludp direct and irwlj rent revoiinroc (rut unhI y i ” nl to lIen/v k i r’r,oy ; a I I ( cd i r=, I r050rIo= S 5 rod to noun
dilect revenues apportjoncrj; skj-r l t ed Ospentlitutec to tw inirvi, other di t if es (irruIlji t :IPs to tt It tn of uiverojinlul s( ay, fbi’ nor’ at =s
exp000itiJles in twirling since ratio iepjdn ’nts arid nittects will p’Jrrlose many it 0 5 5 iii IPOS .
f. fixed jobs plus 1.5 indirprt (rt s per direct job; lI indirect jobs Ossi’in”rI to roqion.
g. Coristiapt ion (Or sno nakinq ont included (see sect ion 6.2.r). Consn,rpt lye ‘“ asrrrriod to he /1 aat torus per day icr drsr ’=t i: use ‘rat
require 0.8 acres of land tni acre—font nf consumptive use water riitht; at] POW Iif ’VFlO [ rur (eot Iierriasr ’d by 3 ’v to reilt ’rt ben flt of wator
conservation. See section 6.2.1 , for discussion of how these aereape requt rcmoot a cor.upare to clot iii wet’ r rj 1 h( ii (reid by Twyp; 1OV, irs; nd
Pattjson Trust.
Ii. Assttnes 10 gpo for skiers, ( n addition i ctpd for overnight residents; all new develepinrent rtorea=et by to reflrcf i’ efj( 5 of
conservat ion; peak day flows factored by 89 to reflect average daily use pca work. ioc (jnhral flows ale for rvern(qtrt port inn only (r:ul ira doy
these people would be in Twining). Rdclit!n in of infiltration (16t1u qpd) to total lnifltr_tlc ’nsjty flow Ccccr’urrts for tie a5, )rl capacity of a new
i. See note i, Tattle 6-ft. Increase in nvernight caper i i v in (Won ru it d ‘let rco .r ’ truffle heron’’ nit’ pu n sours would ci irs in urea art sf omyj
to/true lorry; however, fbi, cnni]d ho off pt by evening travel to i r y (to p u t to rp ’tarjrapts sinpy dcl No at low irco for ‘onrfits of s Ir 1 1 I I ’
sy c trait.
be’ raite j, Table (-H.

Building a smaller plant would not necessarily prevent growth of overnight
accommodations in TWSD. If the treatment plant is expanded only enough to
support the increased skier limit, then any new pillows in Twining would
require on—site systems for sewage disposal. This may change the character of
development (for example, there might be many three and four—unit condos
instead of two or three large ones), but it would not cause a violation of the
stream standards (see wasteload allocations, Appendix B.4) and it would be
consistent with TWSD policies (see section 5.3.2).
If new pillows are not provided in Twining, any Increase in the skier
limit will create development pressures in other parts of the region. The
demand for 285 new pillows (see Table 6—8) would most likely be reflected in
new lodges and condos in areas such as Amizette, Valdez, Arroyo Seco and Taos;
it is not possible to predict exactly where and how. Should the development
be concentrated in the Hondo Valley or along Highway 150, it would tend to
increase area land prices, result in conversion of rural land to traveler
services and increase the visible presence of tourists.
If’ the pillow demand is met in Twining, the effects on existing overnight
accommodations elsewhere would be mixed. In good snow years there would be no
adverse effect (see Table 6—9), but in a poor snow year rooms in Twining could
capture some of the market which otherwise would be directed toward Taos and
the larger region. Due to the overall projected increase in winter ski
visits, the net effect should still be an increase in local business.
Alternatives such as C, which would facilitate very large growth in
overnight accommodations in Twining, could adversely affect the regional
lodging business by drawing away lodgers from established facilities. The
area most likely to be affected would be Taos County. There are an estimated
2000 pillows in the county excluding Twining. Under the maximum capacity
alternative, 3,500 people could be housed In the ski valley, nearly 2800 in
lodges and condominiums. This degree of growth could draw over 50 percent of
the business away from regional facilities even on a peak day in a good snow
year. (This ignores other factors, such as possible increased winter tourism
not related to Taos Ski Valley.) Should such development occur in Twining, it
could restore the historic summer/winter differential in local business and
tourism jobs in Taos. The effects would be particularly hard on small or
marginal businesses. In a good year, these effects would largely be offset by
the projected doubling of skier visits throughout the winter; in a poor snow
year, however, these iripacts would be very evident.
The revenues generated by skiing are both direct and indirect (see section
6.6.1). While most of the direct spending would be iii Twining (for recrea-
tion, food and lodging), much would be elsewhere In the region (especially in
motels, restaurants and shops). Table 6—9 identifies the direct revenues from
overnight guests staying in the region. These figures may overestimate
regionwide revenues from the ski area, since they reflect good ski years, and
not average conditions. On the other hand, the numbers underestimate direct
regional expenditures because the table assumes that persons lodging in
Twining make no purchases elsewhere in the region.

Twining receives essentially none of the indirect revenues from skiing;
these economic benefits accrue to the Taos region. Table 6—9 indicates that
these revenues are substantial; however, in the community the income may not
be recognized as coming from skiing. These funds are generated by the
purchase of goods and services to supply tourist oriented facilities and their
suppliers. Therefore, as an example, the money payed to a local bakery for
bread served to tourists, and in turn part of the salary of the baker,
expenditures for flour, etc. are indirectly generated by the tourists. In
this way a large portion of the economy actually shares in the benefits of the
tourist dollar.
The available data indicate that over half of the economic benefits from
the resort complex accrue in the region rather than in Twining; the percentage
of regional benefits is greatest if there is minimal overnight capacity in
Twining. 01’ course, in Twining itself, every member of the community depends
on and can clearly see income from skiing; as individuals, these people
benefit substantially from the resort. To a lesser extent, this is true for
tourist-oriented businesses and employees in the region including construction
workers building new facilities. In contrast, residents who do not own or
work in a tourist business often receive a lesser share of the benefits (on an
individual basis). However, it is still true that the funds generated by the
resort are widely distributed and contribute, at least partially, to the
incomes of a substantial share of the county population.
Based on existing patterns, the majority of new jobs would be filled by
residents of the area (both natives and persons who have relocated for reasons
other than the prospect of a resort job). However, following current trends,
it is likely that about half the new employment in the ski valley would go to
persons who move to the county as a result of the job opportunity. All
indirect jobs would be expected to go to local residents who would be employed
by regional businesses.
One impact of major concern to residents of the Hondo Valley is the pros-
pect that growth in Twining would force TWSD to purchase water rights from
area farmers, thus drying up agricultural land. Prospective impacts on water
rights are discussed In section 6.2.7; It appears that no new water rights
would be needed by the District if growth is no greater than associated with a
95,000 gpd plant. However, up to 15.15 acres of land already owned by Taos
Ski Valley, Inc., would be retired from production to meet winter domestic
needs. This Is a worst—case estimate (unless TWSD should no longer have
access to the Pattison water right).
If the District can utilize Its San Juan—Chama Project water, the
retirement would be only about 4 or 5 acres to offset snowmaking and summer
uses (with the actual amount depending on the outcome of water rights
hearings). In either case, the retired land would be less than one percent of
the 2735.7 acres of water—rights land in the valley. Thus, while the
retirement of farmland does go against the principle of maintenance of an
agrarian society, the actual magnitude of the impact Is small. (The same
conclusion applies to the highest growth projection, alternative C, for which
up to 22 acres of agricultural land would be needed.)

The loss of this ISV, Inc. acreage from production is likely to be very
visible (especially through publicity over the hearings), and there may be
controversy over the priority of the transferred rights (among other issues).
However, the size of the change suggests that if development in Twining is as
described in Table 6—9, it would not have the kinds of significant cultural
impacts which have occurred elsewhere in New Mexico where there has been
wholesale transfer of irrigation rights. Most of’ the impact relates to the
expansion of off—peak skier use and snowmaking; as shown in Table 6—9, a small
amount relates to the expansion of overnight capacity and only 1 acre is
related to the increased skier limit.
Another impact of concern to area residents is increased traffic. The
calculations given in Table 6-9 reflect a worst—case scenario, in which
proposed shuttle services do not flourish. The impacts could be less in that
with more overnight capacity in Twining, there could be less commuting along
the road (especially during rush hours). On the other hand, there might be
more traffic in night time periods as persons lodging in Twining travel to and
from Taos for dining and entertainment. The traffic counts shown in the table
are much below the capacity of the highway. Still, a proportional increase in
congestion, disruption of local traffic, and accidents can be expected. Also,
noise and air quality impacts would increase (see 6.3.4) as would energy use
water—quality impacts associated with TWSD growth are discussed in section
6.2.7. While the potential for increased irrpacts is evident, successful
operation of new treatment facilities and non—point source control could
result in a significant net improvement in water quality. In addition, Tables
6—8 and 6—9 illustrate a major point, which is that even with an 80,000 gpd
plant, the increase in off—peak skiing will also increase wastewater
discharges outside TWSD, thus potentially producing impacts on water quality
(unless proper treatment is provided).
Cultural Impacts . As discussed in sections 5.3.3 and 5.3.4, the impacts
of TWSD growth on the culture and lifestyle of the area are a major concern to
virtually every citizen; however, perspectives on what constitutes ‘signif i—
cant change’ also vary among individuals. The economic benefits shown in
Tables 6—8 and 6-9 are large and. a major reason why many citizens of’ Taos
support development of the ski resort complex. Some citizens support even
more growth than projected and do not want to see a limit set on lift—ticket
sales. Given the benefits, it is important to understand why many other
citizens oppose development. This subsection discusses potential cultural
changes associated with growth in Twining, in order to help explain why the
debate over such growth is so intense.
Within TWSD, many existing residents are concerned about growth of what is
now a relatively small mountain community. During the winter, only about 150
people actually live In Twining and even on peak nights guest populations are
less than 1100. The potential that evening use of the area may nearly double,
canblned with increased duration of use, could so Intensify activity in the
resort that the Intimate nature of the existing community would be altered.

Much more debate has focused on changes outside TWSD — and specifically on
the lower Hondo Valley and the Taos region in general. Section 6.6.2 dis-
cusses the many complex factors which have influenced cultural change and the
decline of agriculture in the area. Based on that section and on the
magnitude of change indicated in Tables 6—8 and 6—9, the following statements
provide a perspective on the cultural shifts brought about by growth of the
ski resort.
1. The most substantial factors causing the decline of agriculture are
not related to increased tourism, but to factors such as: natural
limitations of soil and water supply; the recent trend toward reduced
runoff; the loss of land grants; decreases in the size of irrigated
parcels; and the national trend toward food markets which are supplied by
large, mechanized farms. It is difficult to envision any scenario under
which agriculture could again become the economic mainstay in Taos.
2. Despite these factors, the agrarian lifestyle remains an essential
part of the Taos culture. Most Taosenos in rural areas will go to great
lengths to retain their traditional way of’ life, even if farming is a
part—time, subsistence occupation. Thus, changes which adversely affect
farming are important not so much because of their direct economic effect,
but because they make it more difficult to sustain the traditional
3. The economic growth of the community (some of which is related to
winter tourism) has a mixed effect on the rural lifestyle. On one hand it
provides wage jobs which enable many people to stay on the land, but it
has also increased the need for cash to pay for the necessities of life.
Subsistence agriculture generates little cash; often the most valuable
asset the farmer has Is his land which growth has made Increasingly
valuable. Thus, it is harder to stay on the land and increasingly
attractive to sell.
4. Specifically, growth of the ski Industry has significantly contributed
to the supply of local jobs, Including many jobs which are not in
Twining. On the other hand, while the IndIrect jobs do provide for
professional, skilled employment (e.g. bankers, accountants, and
craftsmen) most are In the service sector, low—paying, and low—skilled;
many job seekers consider this unsatisfactory employment.
5. Tourism also encdurages somewhat higher prices. The effects of TWSD
appear to be small with the possible exception of land prices in the
Valdez — Arroyo Seco area (see Appendices 0.4 and 0.5). The projected
growth in skier use of Twining could further increase land prices, regard-
less of the plant capacity alternative chosen. For example, some
additional commercial development (restaurants, gas stations, etc.) would
likely result from the approximate doubling In the winter—long number of
skiers. Based on the historic trend, In 2000 land prices In Va].dez and
Arroyo Honda would be several thousand dollars higher than In comparable
communities farther from the ski resort. This Is a worst—case analysis;

given the small acreage involved, the changes could be much more modest.
Agricultural/rural uses still would be by far the principle land use in
the area. However, to the extent that the highway becomes a corridor of
strip commercial development, there would be a significant change in the
aesthetic character of the area between Taos and Twining.
6. Motel and lodge development outside Twining may also occur for the
same reasons described in item 5. In this respect, a larger treatment
plant facility in TWSD, and the associated expansion of overnight
accommodations within the District, could reduce development pressures
elsewhere. (Even without a larger plant, the same effect is likely
because of development in Twining serviced by on—site systems.)
7. A major fear of downstream residents is that the water supply will be
affected by development in Twining. Further reduction in the supply of
irrigation water, which is already critically short, could lead to
abandonment of farming and loss of the land and lifestyle. Data show
clearly that the reduction of irrigation flows is not due to growth in
Twining nor would limited growth have a significant effect. However,
existing conflicts regarding the priority of water rights might be
8. Beyond economic change, the influx of outside values into the com-
munity would be a major factor responsible for alterations of the area
lifestyle. Tourism is one of several influences — among them radio,
television, schooling, travel, etc. — contributing to this influx (see
6.6.2). The daily flow of skiers and other visitors to the ski valley
increases residents’ exposure to different attitudes, lifestyles and
affluence. To the extent that tourists stay in Twining, this presence
would be reduced, although an air of exclusiveness would also be
fostered. To the extent that increasing numbers stay elsewhere in the
region, there would be greater exposure to a different lifestyle. For
county residents who resent the presence of tourists, either situation
will increase their concern and the friction between the two groups.
9. The present patterns of impact distribution would continue, and
perceptions of’ these impacts would be unchanged. These patterns clearly
show a positive ratio of’ benefits to adverse effects within TWSD.
Elsewhere the pattern is less clear and may vary depending on the
individuals involved. While many citizens may enjoy a net benefit from
the direct and indirect revenues generated by winter tourism, others may
not. For at least some persons in the lower valley, the adverse effects
(traffic, some loss in water quality compared to pre—development
conditions) would not be offset by benefits.
It is difficult to combine all these factors and say that there would be
‘so much’ cultural change resulting from development in Twining. Part of the
difficulty Is that so many other factors influence the nature of the area (see
6.6.2); the actual locations of new restaurants, motels, etc. cannot be known
In advance; and the significance of’ the changes are perceived differently by

different members of’ the community. In many respects the impacts are
symptomatic of what is often termed ‘progress’. Thus, analysis of the impact
becomes an attempt to determine if such progress is truly beneficial or
instead destructive of the traditional way of life, and further, if these
kinds of’ changes are inevitable.
While the subject of ‘progress’ is too broad to be addressed fully in this
document, a few generalizations are possible. First, rural societies
throughout the world have been evolving in the face of modern economic and
cultural pressures, with the consequent loss of traditional values. Most
often, tourism is one such pressure and it no doubt has contributed to
cultural change in Taos as well. Thus, it may be speculated that the
projected development of Twining could play a role in the continuing shift
away from a traditional, agrarian, Hispanic—Indian society. Perhaps
comprehensive, countywide land use planning — or some other type of locally
derived political action — could slow such change, or even redirect it.
Anything short of such planning would be unlikely to have an effect.
Second, the development of Twining is a highly visible symbol of a type of
progress which some people embrace and others reject. For example, to many of
those interested in economic growth the large revenues generated by skiing are
very welcome. To those who want to maintain the agrarian tradition, the
revenues simply represent the acquisition of wealth by a few through the use
of resources which once belonged to many. The ‘high—profile’ nature of the
resort in itself is often cited as a cause of cultural stress, since skiers
are usually visibly affluent and engaged in recreation (‘play’) using public
resources (and perhaps a federally funded treatment plant); some Taosenos are
much less affluent and many consider themselves as needing these same re-
sources for survival.
The debate about development In Twining is certainly important in its own
right. For example, historic pollution problems must be solved and downstream
communities must be protected against any violation of the stream standards
which could result from growth of the resort. However, In many respects the
debate Is a symbol of community interest in the whole question of ‘progress’
and cultural change. The decision about the best size for a TWSD treatment
plant thus becomes a decision in principle about the future of the region.
Those who are especially concerned about survival of the existing culture (and
who certainly don’t want to speed up the change) strongly advocate a smaller
facility that won’t encourage new development in Twining (and which might even
play a role in slowing development). Those who encourage (or at least accept)
tourist—based economic development and who consider tourism a basically clean
industry which benefits rather than conflicts with the natural culture are
supportive of’ a larger capacity wastewater treatment plant for Twining.
Infrastructure Impacts . Twining’s Infrastructure should be sufficient to
accommodate the growth associated with the 95,000 gpd plant, with two
exceptions. Recently proposed Improvements to the water system are designed
to meet current needs, for details refer to Appendix C (BLL, 1980). Projected
growth would require some expansion of’ the system, particularly the transfer

and development of additional water supplies (see section 6.2.7). The other
area of potential Impact is on parking facilities which are to be expanded to
hold 1300 vehicles (USFS, l981b). Projections in Table 6—9 indicate that
there might be over 1900 vehicles in Twining in the future. Perhaps a hundred
or so may be located In private parking lots, leaving up to 500 cars without a
parking space. This impact would be offset by use of the shuttle and
Increased private parking but it Is possible that facilities will have to be
expanded further in the future increasing surface runoff and visual impacts.
In the region, the most likely effects on infrastructure are related to
increased highway use and possible development in smaller communities.
Highway 150’s capacity is adequate to handle future use; however, the road is
deficient from a safety standpoint (sharp curves, etc.) and increased use
could increase the accident rate and require improvements to the highway.
Some increased traffic congestion in Taos is also possible during skiing
“rush” hours.
The water and sewer systems in most small communities have very little
excess capacity. New development in these areas would probably require system
expansion. Some local traffic circulation problems could also occur.
6.6.7 Impacts of Other Types of Alternatives
The various alternatives described in sectIon 5.4 could have four types of
impacts on the socio—economic environment: rate increases, adjustment to
water—saving practices, revised development patterns, and expectation of
successful pollution control. In addition, the extension of sewers to
existing base area development (Kandahar) and five cabins now having holding
tanks would relieve these facilities of their present wastewater disposal
Rate Increases . In addition to plant construction and operation, the
collection system, on—site system management, and rate design alternatives
would all affect the rates of District residents. To meet the costs
associated with the construction and management alternatives (see section 5.4
and Appendix B), water/sewer rates paid within the District would have to
increase substantially, perhaps by a factor of two considering both the sewer
system rehabilitation and the water system improvements. Assuming that the
rate design described in 5.4.8 is adopted, most of these Increases would be
passed through to skiers and visitors who use the area (and who are the main
reason the facilities are needed).
Still, the proposed rate design would affect existing residents and
property owners, through payment of three major fees. The first would be an
annual assessment for system users, based on usage. This fee Is unspecified
but is expected to be at most $50 per pillow per year. It would be used to
develop an operating/reserve fund and would be assessed only as needed to
maintain an adequate fund. The second would be a hookup fee, charged to those
who develop new or expanded commercial facilities in the base area. If this

fee is set by market forces, and the demand for hookups continues to outpace
supply, the charge could be large, perhaps several thousand dollars per unit
(as a one—time cost). The third would be an assessment for owners of on—site
systems to pay for the on—site management service. During the initial years
this could amount to $150 per owner each year (which, Proportionally, would be
a greater impact than the increases faced by those who are hooked up). As the
number of on—site systems increases this fee would be reduced (disregarding
the effects of inflation).
Water Conservation . The use of water conservation measures as described
in section 5.4.6 would require residents to adjust to the use of dry or
extremely low flush toilets in order to significantly reduce sewage flows and
conserve area water supplies. The benefits of this alternative would include
reduced water and sewer fees (because smaller water and sewer systems would be
needed and because rates are based on use); also, this step would represent to
downstream residents a positive effort on behalf of TWSD to reduce its impact
on area resources.
However, operation of dry toilets has met with varying success even though
the systems have proved reliable in some installations. They do need to be
installed properly and consistently maintained. Basically this would re-
quire: care in selecting persons to do the installation; in some cases,
special consideration in house design to accommodate the system; and periodic
removal of waste (generally once a year or so depending on use and system
Even with these precautions, problems can occur for reasons which may
include (EC, 1980):
— disturbance of the system through changes in the moisture balance or
overloading (resulting from long periods of non—use or heavy peak use);
— corrosion of electrical units (from excess humidity), causing failure of
fans or heating units, and Stopping the bacterial action;
— possible need for special precautions in the disposal or use of the
compost which is produced by the toilet.
With system failure, the potential for offensive odors is significant.
These problems can be minimized through a regular maintenance schedule, as
could be undertaken should TWSD adopt an OSS management program (Section
5.4.2), intended in part to ensure that the balance of each system is
maintained. Another consideration facing infrequent cabin residents is that
the system must be kept in a heated space. This would require that the
electricity be kept on while the residents are gone, an extra cost and
inefficient use of energy.
Extremely low—flush toilets, (one litre versus 18—20 litres) also offer
significant savings on water use. Their operation and installation

requirements are similar to standard fixtures, and require little or no
adjustment on the part of the users.
There is likely to be at least some public resistence to requiring dry
toilets in all new construction, because of concerns over system failure,
odors and even health hazards. Lodges and condominiums, particularly, may be
concerned that the potential for failures could hurt their business.
Extremely low—flush toilets are likely to be more readily accepted by the
public, and they still offer the potential for significant water savings.
Should TWSD adopt a phased hookup policy (see below; and section 5.4.9), there
would be time to demonstrate the various available systems in Twining and to
determine construction and operation standards. This would also provide an
educational benefit in the water conservation program.
Hookup Policy . As described in section 5.4.9, TWSD is considering hookup
alternatives which involve phasing in of new hookups, the timing depending on
performance of District facilities and compliance with appropriate regula-
tions. The hookup policy would have several major impacts over and beyond
contributing to the objectives of quality assurance.
1) Intially, it would delay construction of new facilities desiring
hookups until the plant is completed and operating performance tested,
except for development using on—site systems.
2) Once the moratorium is lifted, delays would continue, on a priority
basis, for those not receiving a new hookup.
3) Eventually, all growth associated with the 95,000 gpd projection (and
perhaps some additional growth) could be serviced. However, at least
theoretically, TWSD could ultimately stop all development using on—site
systems (except for total recycling systems) due to limits on total
pollutants which may be discharged from both the plant and on-site
4) Delays in development would have an adverse financial impact on
property owners who seek to put their land to a more intensive use.
5) For those who turn to on—site systems, the costs of development are
likely to be greater than for those who acquire hookups. Based on state
regulations (Appendix A.l) the only systems which would receive approval
are those which discharge to ground water and which have a capacity of
2,000 gpd or less (or involve total recycling, see below). The use or
such systems would change the pattern of’ development because only small
condos and lodges (perhaps 2-4 units each) could be serviced.
6) Those who want to develop at a large scale, and for whom hookups are
not available in a timely fashion, may turn to extremely expensive
alternatives such as total recycling (alternative 13, chapter 5).

Expectations . The quality assurance program, if adopted, would raise
expectations on the part of all area residents that the long—standing
pollution problems in the Rio Hondo could and would be solved. If the program
works as described in section 5.4.9, these expectations would be realized.
Relationships between TWSD and those downstream would improve, both because of
TWSD’s visible progress toward protection of the river and because of the
improved water quality itself. However, should there again be significant
violations of effluent limiations by TWSD, conflicts among area residents
would recur and quite probably be heightened.
6.6.8 Impacts of EPA and Other Agency Alternatives
Virtually all of the potential impacts described in Tables 6—8 and 6—9
would occur irrespective of EPA decisions regarding project funding. This is
because essentially all growth impacts can occur independently of any decision
made regarding plant size. The impacts of alternative B are inevitable so
long as the resort complex remains viable and TWSD meets its obligations to
eliminate point source pollution. A larger plant would facilitate more growth
in Twining but a smaller plant would not prohibit or even effectively dis-
courage growth. Provided only that there is sufficient economic incentive,
development to or above 95,000 gpd can be accommodated through on—site systems
or independent treatment plants, both of which can be designed to meet appli-
cable regulations. To effectively control growth and its impacts would
require public action such as zoning or some other form of comprehensive land
use planning.
Still, EPA’s funding decision does have a practical significance If the
agency provides a source of money to TWSD which otherwise would have to be
raised from the property owners and from recreationists; the greater the
funding, the greater this benefit. Should EPA fund improvements In Twining
the impacts discussed above may occur more quickly. Absence of EPA funding
would place the costs of environmental protection and growth solely on those
who benefit most directly from the presence of the resort; based on historic
trend and local economics It appears that development to at least the
equivalent of 95,000 gpd would occur. EPA’s decision may be taken by many
area residents as at least an Indication as to the merits of the various
arguments over area growth. However, in actual fact, EPA’s decision will
relate to a number of issues; resolution of the complex questions about
economic development and. cultural stability will be left to the citizens of
Taos County.
In many respects, one of the most significant decisions has already been
made (by TSV, Inc.) and accepted by the U.S. Forest Service. This choice, to
limit skiers to a maximum of 4800 per day, will place a definite upper limit
on many of the impacts (both beneficial and adverse) associated with the
resort complex (see USS, 198la and 198lb).

The major resources associated with all the alternatives are energy and
materials for construction and operation of a treatment system, as well as the
energy associated with traffic which would accompany development. Analysis of
these resources indicates the general magnitude of effects of the alterna-
tives; it does not provide an exhaustive inventory of resource use.
6.7.1 Existing Conditions
Treatment Plant . The TWSD wastewater facilities currently use about
120,000 kilowatt—hours (kwh) of electricity per year. Chlorine, used for
disinfection, is added at the rate of 8 mg/i; or 1190 pounds total for 1980.
This amount of chlorine requires approximately 1550 kwh of energy for its
production off—site.
Vehicles . As indicated in Table 6—8, about 104,000 vehicle trips are made
to Twining during a good ski season. Assuming all these are round trips from
Taos (38 miles), and using the New Mexico average mileage figure (12.2
miles/gallon) this represents consumption of 324,000 gallons of gasoline.
6.7.2 Impacts of the No—Action Alternative
Under the no—action alternative, there would be no change in resource use
for wastewater treatment. Traffic would increase to 196,000 vehicle trips per
ski season, which would add the consumption of 286,000 gallons of gasoline to
current levels. If a shuttle bus system is used (see USFS, l98la),
considerable reduction in petroleum use (even compared to current levels)
could be realized. Use of a shuttle system would also have positive impacts
on air quality, safety, noise, sediment loss (due to parking lots), and
general aesthetics in the area.
6.7.3 Impacts of Treatment Alternatives
The primary purpose of improving the treatment of Twining’s sewage is the
preservation of’ a valuable resource — the Rio Hondo. However, treatment of
wastewater also requires expenditure of resources — energy, material, labor,
and money. The relative consumption of resources among the various treatment
alternatives can be approximated from their relative costs (Table B-i), since
cost represents the value of a material and the energy used to produce it.
The nature of these costs can be illustrated for TWSD’s preferred
alternative (alternative 1; conventional, 95,000 gpd). Construction of a new
conventional treatment plant would involve the consumption of’ various
materials for equipment and structures, including 208 cubic yards of concrete,
853 cubic yards of sand, 840 square yards of asphalt, and 1000 feet of PVC
pipe (BLL, 1981, App. E). Operation of’ the plant would consume 242,910 kwh of

electricity per year, an increase on the order of 100,000 kwh over current
requirements. Yearly use of’ lime and carbon dioxide is projected to be 2,700
pounds and 5,760 pounds, respectively.
Renovation of the existing plant (alternative 12) would require less
consumption of building materials, but would use approximately the same
amounts of’ electricity and chemicals. Aquaculture is reported to use less
energy, or rather It uses “free” solar energy via algae; this has yet to be
confirmed. Lime, carbon dioxide, and a disinf’ecting chemical would still be
used in this alternative. Composting toilets actually provide a resource in
that the compost can be used for fertilization. However, this alternative
would require a large amount of electricity — on the order of 500,000 kwh per
year — for heating toilets to ensure proper bacterial action.
6.7.4 Impacts of Capacity Alternatives
Growth at the ski resort would increase resource use in the watershed,
Including energy and materials used for new construction and energy associated
with operation of the entire complex. Some members of the public have com-
mented that the recreation industry is Inefficient in its use of resources.
From the perspective of Taos County, it is not clear that this Is true since
the economic production from the industry is large and the local resource
consumption does not appear to cross any environmental threshold — i.e., a
resource near exhaustion or unable to absorb expected impacts. The most
critical natural resource Is water, which is in short supply (for reasons not
related to the resort); stresses on the quality of this resource should be
controlled within limits established by state and federal regulations.
If a larger capacity alternative is chosen (95,000 gpd), traffic is
projected to increase to 231,000 vehicle trips during the ski season. This
would result in consumption of 396,000 gallons of gasoline over present
levels, compared to 286,000 gallons if the no—action or a lower capacity
alternative is selected. However, limiting skiers at Taos Ski Valley would
probably not mean that the petroleum would not be used; rather, It most likely
would be used for travel to other ski areas in New Mexico or Colorado.
6.7.5 Impacts of Other Types of Alternatives
Ozone requires more energy for its production than does chlorine. Ozone
production for alternative 1 would use 6,570 kwh of electricity per year. If
chlorination were used, 2,250 kwh would be consumed to produce the chlorine
off-site; some energy would also be required to transport the chlorine to the
treatment facility. The greater energy cost of ozone Is being considered In
order to avoid the toxic effect of chlorine residuals in the Rio Honda. If
chlorination, dechlorination and reaeratlon were used to gain the same
benefits, ozone would prove to be less energy Intensive.

Money, used to fund the treatment facilities, is another resource which
would be used. Various rate structures were discussed in section 5.4. The
impact of increased sewer rates on affected residents is discussed in section
Use of the treatment plant effluent for snowmaking would represent a
considerable expenditure of energy in order to pump the water from the
treatment plant to the snow machines. The two snow machines presently used by
ISV, Inc. consume approximately 10,000 KWH of electricity per year. A much
greater amount than this (by an order of magnitude or more) would be required
to pump the effluent up the mountain.
Use of sludge for fertilization would provide a valuable resource;
however, runoff from the sludge might add excessive nutrients to the Rio
Hondo. The energy value of the sludge could also be a benefit; however, for
cost reasons the facilities plan proposes no energy renewing processes.
6.7.6 Impacts of EPA and Other Agency Alternatives
EPA’S funding options would not have a significant impact on resources
unless the agency determines that one of the higher cost (resource intensive)
options is cost—effective. A policy by some agency to require use of a
shuttle system for transport ion to the ski area would reduce the magnitude of
nearly all impacts, even below current levels.
6.8.1 Adverse Impacts Which Cannot be Avoided
With minor exceptions, all of the adverse Impacts described In this chap-
ter would occur as the result of: a) expanded use of the resort complex; and
b) the investment of’ resources to control pollution from the area. Table 5—6
quantifies many of the unavoidable adverse impacts.
The impacts of resort expansion would be similar and perhaps identical
regardless of the capacity alternative finally Implemented; this is because
(as discussed in section 5.3) most of the Impacts relate to growth in off—peak
use, and the remainder can occur from independent treatment plants as well as
from an enlarged TWSD plant. For the same reason, the adverse impacts are
likely to occur with or without EPA funding except that it is possible that
EPA funding might facilitate the growth to some degree and hence contribute to
the likelihood that the impacts will In fact occur. Any Impacts associated
with growth that might be a result of’ EPA’S funding choice will have an impact
on downstream users of the river, especially with regard to small transfers of
water rights and increased traffic.

The investment of resources is a necessary step toward compliance with
enviromental standards. All six of the semifinal treatment alternatives
would be expected to provide such compliance, as Would all capacity alterna-
tives of 95,000 gpd or less. If EPA funding is lifihited or not provided, the
TWSD would still be responsible for the improvements necessary to meet the
proposed NPDES effluent standards. The absence of EPA funding would have a
negative economic impact on members of the District who would then be
responsible for all costs associated with improving the plant and meeting
appropriate standards.
6.8.2 Short—term Uses of the Environment versus Long—term Productivity
Upgrading of the treatment facility would promote long—term productivity
by improving the water quality and ecology of the Rio Hondo. In turn, this
would benefit use of the river for fishing, irrigation and other purposes.
EPA funding for the most cost—effective treatment alternative would contribute
to the achievement of these benefits.
Expanding the size of the resort would involve a tradeoff of several types
of resources, all generally involving long—term productivity. As summarized
in Table 5—6, these tradeoffs generally involve: economic benefits to Twining
and the region versus some adverse environmental changes In the Rio Hondo
watershed and along State Highway 150 (especially some adverse ecological
impacts in the river just below TWSD; probable retirement of irrigated lands
in order to transfer TSV, Inc.’s water rights into the area; congestion, noise
and exhausts from increased traffic; and possible added stresses which
influence cultural change).
No evidence has been found to indicate that these environmental changes
would cross any fundamental ecological threshold and thus in themselves alter
the character of the environment. The cultural changes could, in conjunction
with many other forces acting on the area, and if not forestalled by local
planning actions, accumulate to the point that the agrarian lifestyle of the
region would be significantly diminished. These Impacts are expected to occur
from either capacity alternative B or E and are not dependent on the level of
EPA funding (if any). Complex questions about economic development and
cultural stability which relate to the expansion of’ the ISV resort community
must be resolved by the citizens of Taos County.
6.8.3 Irreversible and Irretrievable Comitments of Resources
Major categories of resources to be utilized by the proposed treatment and
capacity alternatives were identified In section 6.7 and Include energy,
construction materials, labor and capital. These commitments are sub-
stantial, as is necessary if the pollution problem is to be solved. The
commitments are largely Irretrievable. At least some additional growth of the
area appears inevitable (irreversible); the larger capacity alternatives would
facilitate this change (but the smaller capacity options would not prevent it).


Scoping Meeting . EPA held a formal Scoping Meeting in Taos on October 2,
1979. Notice of the meeting was published August 30, 1979, in Spanish and
English. The meeting was conducted for the purpose of identifying issues for
consideration in the Environmental Impact Statement. The meeting was attended
by over 300 people; 24 made oral presentations.
A total of 197 letters were received for inclusion in the official
record. Of these, 24 were form letters supporting EPA funding of improvements
to the Twining wastewater treatment system. Eight of those were from people
at Taos Ski Valley, while one each was from Des Montes, Arroyo Seco, El Prado
and Albuquerque. Twelve of the form letters were signed, but included no
address. Of the 173 non-form letters, 167 included statements in support of
EPA funding for wastewater treatment improvements at Twining. About half of
the letters originated in Taos County, one fourth from other parts of New
Mexico, and one fourth from out of state. One of the original letters
included with it a number of petitions expressing opposition to “the issuance
of a 1980 Step 2 and 3 federal grant to the Twining Sanitation District, Taos
Ski Valley, for purposes of constructing a sewage treatment plant” and “to the
further pollution of the Rio Hondo by another sewage treatment plant at the
Taos Ski Valley.” The petitions had six different wordings, one of which was
in Spanish, and they had a total of 605 signatures.
A number of groups and individuals participated in the scoping process and
many have remained involved throughout the development of the facilities plan
and this draft ElS. Involvement by the public in these processes has been
encouraged and welcomed by EPA. The largest single source of input from
outside the District has been provided by the Cocm ittee to Save the Rio Hondo
(CSRI-1), a well—organized group of’ lower valley residents concerned about the
envirornental quality of’ the Rio Hondo watershed. Many are members of
families that have lived in the valley for several generations.
Section 7.2 discusses the issues raised at the Scoping Meeting and EPA’S
Citizens Advisory Committee . In order to maximize public input during the
ElS process, the Twining Water and Sanitation District Board appointed a
Citizens Advisory Committee consisting of representatives of the various
public sectors potentially affected by any proposed action. The group was
formally organized on October 1, 1979. The Committee is comprised of persons
in substantially equivalent numbers from the following categories: private
citizens, public interest groups, public officials and those with substantive
economic Interest in the project. Membership on the committee is not limited
to TWSD residents, but includes residents of the affected areas, including the
Rio Honda Valley and the Town of Taos. The committee has been continuously
involved in the EIS process, including review and comment on: (1)

alternatives examined; (2) the preferred alternative; and (3) Impacts of the
major alternatives.
A list of’ committee members follows.
1. Public Officials Representing
Charles Kleiner Twining Water and Sanitation District
Sonny LaSalle U.S. Forest Service
Richard Romero Taos Pueblo
Jack Suttle Taos County
2. Economic Interests
Lisa Harner Rio Hondo Condominiums, Twining
Mike Rice Chamber of Commerce and El Pueblo
Motor Lodge, Taos
Doug Terry Terry’s Sports, Twining
Ron Oest Downstream irrigation interest
3. Public Interest Organizations
Manuel Ortiz Hondo—Seco Development Association
Faby Teter Committee to Save the Rio Hondo
.Jeri Vargas Taos Coordinating Council
(substitute: Larry Frank) Committee to Save the Rio Honda
4. Citizens
Roy Bernal (home: Arroyo Seco)
Jim Levy (home: Arroyo Hondo)
Paul Sears (home: Taos)
Larry Taub (home: Taos)
Following the Scoping Meeting, the CAC took the lead in the public
participation process and accomplished the following.
1. Depositories for written information were established as follows:
A. CAC office, initially at First Northern Plaza, Taos; now at the
home of Jack and Doris Schact, Public participation coordinators,
Taos (505—758—3864);
B. TWSD Administration Office, Twining;
C. Harwood Foundation Library, Taos;
D. Taos Pueblo Administration Office, Taos Pueblo.
All minutes and other documents identified in this chapter are
available at these depositories.
2. Frequent committee meetings were held (21 by mid—May, 1981), with
every meeting open to the public and announced In the Taos News and
on Taos radio station KKIT.

3. On February 5, 1980, a public meeting was held at Taos to discuss the
existing situation based on information gathered by the consultants.
As with the Scoping Meeting, attendance was large and input was
extensive. The emphasis of questions and statements was on the need
to effectively resolve present and future environmental problems,
especially with respect to water quality. The Responsiveness Summary
of this meeting is available for review.
4. On July 15, 1980, on the recommendation of’ the CAC, a contract was
negotiated between the Twining Water and Sanitetion District and Mesa
Consultants (Jack and Doris Schact) of Taos to act as public
participation coordinators. At this same time, the committee
recommended that Paul Robinson of the Southwest Research and
Information Center in Albuquerque serve as Technical Advisor for the
5. To be better able to digest and evaluate the substantial amount of
documentation provided the CAC by the consultants, CAC Chairman Larry
Taub appointed sub—committees on Growth, Envirorinent and Facilities.
Fifteen sub—committee meetings were held between the regular CAC
meetings. Reports on sub—committee findings were provided to all
committee members and are available for review.
6. on August 19, 1980, these sub—committees sponsored an “open house”
meeting at Taos to seek further public input. This was advertised in
the Taos News and announced on Station KKIT. A summary of the
proceedings is available for review.
7. On September 16, 1980, there was a second public meeting at Taos,
with the major emphasis on alternative types of facilities being
considered. This was advertised in Albuquerque and Taos newspapers
and Station KKIT. Again, attendance was large and public input was
substantial. A major thrust of questions and statements was to
oppose regional treatment alternatives, and to stress reliability and
water supply as major issues. The Responsiveness Summary of this
meeting is available for review.
8. A third public meeting was held on March 31, 1981, at Taos, with
emphasis on the question of’ growth as affected by the size of a new
facility. This was advertised in Albuquerque and Taos newspapers and
Station KKIT. Questions and statements emphasized the desire for
little or no growth in Twining in order to protect the environment of
the Hondo Valley and the cultural traditions of the area. The
Responsiveness Summary is available for review.
9. A recommendation from the CAC may be provided to the TWSD before
formal selection of the type and size of a facility has been made by
the Twining Water and Sanitation District Board. This may be a
consensus reconinendation if a consensus can be reached. If a
consensus cannot be reached, it may take the form of majority and
minority recommendations.

Table 7—1 presents specific issues raised at the Scoping Meeting. Major
areas of concern included: water quality of the Rio Honda, water quantity and
rights, socio—economic impacts on the Taos area, costs of proposed new
facilities, and overall impacts of growth in Twining.
Certain areas of concern were raised at the Scoping Meeting which were
addressed specifically by the State of New Mexico and EPA: legality of the
District; eligibility for funding; lack of enforcement of the District’s NPDES
permit; and questions as to Forest Service responsibilities In water quality
and growth management. The history of all four issues Is discussed in
Appendix A and summarized below.
Basically, the questions of legality and eligibility were resolved by the
New Mexico Attorney General and EPA regional counsel, which found the District
to be an appropriate recipient for EPA funding. EID agreed to take the lead
in enforcement and negotiated an Assurance of Discontinuance with the District
several months after the Scoping Meeting. The Assurance was successful in
leading to improved facilities and water quality until early 1981, when
aerator problems were encountered. Resolution of these problems is ongoing;
section 5.4.8 discusses mechanisms for assuring active permit enforcement of
the criteria.
The Forest service response to questions about water quality enforcement
is discussed on page 5—42. Questions concerning growth due to ISV, Inc.’s,
plans were addressed in the ISV master plan (Fiance, 1980) and In a Forest
Service EIS on the master plan (USFS, l981a and 198ib), wherein a limit to
growth of 4800 skiers was established (see section 6.6.3). In addition, the
Forest Service is a cooperating agency for this EIS.
CAC Issues . over the months that followed, additional Issues were
raised. Table 7-2 lists issues addressed by the CAC during their many
meetings, and the response to them. The Index also provides guidance In
locating discussion of major issues.
Table 7—3 lists agencies, organizations, and individuals with which
coordination has been Ongoing and/or which will have an opportunity to review
the Draft EIS. The complete mailing list has not been reproduced here as it
contains about 1,000 names. The list is available for review at depository A
(see pg. 7—2).
EPA sent notices to those on the mailing list Identifying the upcoming
availability of this draft Els. Recipients of the notice were asked to
identify to EPA If they wished to receive a copy of either a summary or a
complete draft EIS. PublI 0 notices of availability of this draft ElS and of a
public hearing on this draft EIS and the related facilitIes plan will appear

in the Feceral Register and in various newspapers including the Taos News.
The draft EIS will also be available for review at the following locations:
5. Supervisor’s Office
Carson National Forest
Cruz Alta Road
Taos, New Mexico
2. Twining Water and Sanitation
District Offices
Above the Fire Station
Taos Ski Valley, New Mexico
7. New Mexico Environmental
Improvement Division
Crown Building
725 Saint Michael’s Drive
Santa Fe, New Mexico
Copies of the summary of the draft EIS in both English and Spanish can be
obtained from Jack Schact, Post Office Box 2956, Taos, New Mexico 87571, phone
505—758—3864; or from Clinton B. Spotts, Regional EIS Coordinator, U.S.
Enviromental Protection Agency, Region VI, 1201 Elm Street, Dallas, Texas
75270, phone 214-767-2717.
The draft facilities plan will be released at approximately the same time
as the draft EIS and will be made available at each of the above seven
locations. The public hearing on the draft [ IS will be conducted jointly with
TWSD and will encompass the draft facilities plan. Appendix E contains
official letters received during the [ IS preparation process; responses are
provided as appropriate. These letters include: comments of Taos Pueblo; the
U.S. Fish and Wildlife Service; the U.S. Army Corps of Engineers, and the
State Historical Preservation Officer.
1. Harwood Foundation
Public Library
LeDuex Street
Taos, New Mexico
6. New Mexico Environmental
Improvement Division
Taos County Health Building
Paseo De Pueblo Sur
Taos, New Mexico
3. Taos Pueblo Administrative
Taos, New Mexico
4. Taos Ski Valley, Inc.
Taos Ski Valley, New Mexico

A transcript of the meeting is on file at Depository A, listed on page 7-2.
I. Existing Situation
A. History of present treatment plant and associated problems (discharge
violations, lack of proper operation and maintenance).
B. Legality of formation of the Twining Water and Sanitation District.
C. Eligibility of the Twining Water and Sanitation District for EPA
funding under the Clean Water Act.
0. Government (both state and federal) enforcement of permits and
regulations regarding treatment plant discharges. See Appendix A.4
E. Current effects of plant discharge on Rio Hondo water quality and
possible health and other impacts on downstream residents.
F. Water consumption in the ski valley area.
G. Sludge disposal,
H. Non—point sources of pollution (septic tanks, agriculture,
silviculture) both in the ski valley and downstream.
I Measures to reduce pollution on an interim basis.
II. Possible New Wastewater Treatment Facilities
A. ProDlems with infiltration and inflow to the current system.
B. Possible expansion of wastewater treatment facilities.
C. Operation and maintenance of any new facilities.
0. Costs of new facilities and related state and federal funding and
parts B and C of chapter 5.
E. Future impacts of discharge from new facility on the Rio Honda,
including the possibility of future overloading.
F. Enforcement of permit and regulations relating to a new plant.
C. Water conservation.
H. Energy conservation.
I. Impacts of construction of a new facility. See Table 6—1.
J. Mitigative actions to be taken until a new system can be installed.
K. Impacts of non—point sources of pollution, both in the Ski Valley and
downstream in the lower valley.
III. Other Issues
A. Delineation of area affected by project.
B. Ef ’f’ects of a new system on growth in Taos Ski Valley.
C. Possible changes in land use in Taos area.
D. Economic and social impacts
1. Tax payments (direct and indirect) of ski valley
2. Jobs ano personal income generated by ski valley operation
3. Changes to traditional lifestyle
4. Increases in traffic.
E. Overall economic impact on Taos County (income versus expenditures,
especially relating to government funds (local, state, federal) spent
on schools, roads, police and fire protection, etc.].
F’. Impact on water rights in ski valley and downstream.
C. Impacts on the uses of Carson National Forest and Wilderness Area,
including recreation.
H. Impacts on the Taos Pueblo lands and activities (including religious
cerem njes).
I. Changes in the Rio Honda watershed (increased runoff, erosion,
flooding, mudslides, and change in climete).
, Possible changes in energy use, noise generation, air quality, etc.
K. Limitations to growth in the Twining Water and Sanitation District and
Taos Ski Valley.

The CAC identified the following issues )iring Its n etings -
1. Issue: What is the role and authority of this cQlTnittee?
Response : To gather public irçut and relay its findings in its
advisory role to the District and indirectly to EPA and EID.
2. Issue: w were CAC members selected?
Response : In accordance with EPA guidelines and with EPA approval.
3. Issue : What is the history and geographic limits of the TWSD’?
Response : A presentation was made by Charles Kleiner, member of
the TWSO Board, and circulated to comittee rnee ers through the
minutes of the August 9, 1980 meeting of the Facilities
4. Issue: What are the existing facilities?
Response : A field trip to the waStewater site and the ski slopes
was sponsoreo by the Facilities sub—c miiittee for all CAC members,
on July. 9, 1980.
5. Issue: What are the water resources available to the Rio -1ondo
Response : Information was provided the CAC through Lee Wilson &
Associates, the NM Environmental Improvement Division, and the l4
State Engineer.
6. Issue: What are the economic and cultural impacts of growth within
the Dounoaries of the Twining District?
Response : Information was provided by Lee Wilson & Associates, the
Growth sub—comittee, and a presentation by Sylvia Rodriguez, Taos
native and professional anthropologist, listing what she considered
to be the main concerns of the Kispanic residents of the area.
7. Issue: What are the possible types of alternative facilities to be
Response : The CAC and the Facilities sub—c inittee reviewed a
total of 16 possible alternatives. In conjunction with conTnittee
technical advisors, the CAC reduced the list to six semi—final
1 — New Plant 4 — Compost toilets! greywater treatment
2 — Rehabilitation 5 — Total recycling
3 — Aquaculture 6 — Snowmaking
8. Issue: What are the various funding possibilities for plant
construction and maintenance?
Response : EPA and SID representatives presented various funding
A - Planning, design and construction, total eligible costs
1 — U.S. Environmental Protection Agency 75%
2 — State of New Mexico 12 1/2%
3 — District 12 1/2%
B - Operation and Maintenance
Community 100%
9. Issue: What is the effect of skier traffic on the air Quality of
f irea?
Response : EID representatives assured the com iittee that no air
quality standards are being violated.
10. Issue: What assurances are therm that TWSD will comply with stream
standards even with a new plant?
Response : ElD will continue current sampling program and use
whatever mechanisms are required to assure compliance.
11. Issue: What should be the size of a new plant?
Response : Of the several sizes included in the study, EID has
stated that the maximum size in which it would participate in
funding was 95,000 gpd.
12. Issue: Will the size of the treatment plant be an effective limit
to growth?
Response : Lee Wilson advisea the committee that while a mnall
plant might be a deterrent to growth, it would not be a controlling
factor such as county zoning cwld be.
13. Issue: Who is ultimately responsible for control f both ooint and
6 oint source pollution in the District?
Response : The Twining Water and Sanitation District is.
14. Issue: Would the incustrial cost recovery concept apply to a new
Ii at Twining?
Response : Congress repealed the industrial cost provision in
October, 1980, according to Dave Neleigh, EPA.
15. Issue: Would a special tax or surcharge on users be feasible to
generate revenue for the TWS0?
Response : Special legislation to authorize this failed to pass in
the 1981 legislature.
16. Issue: Do new stream stanoards now in effect downgrade the water
Ilty of the Rio Hondo?
Resoonse : Dave Tague of NI ID assutea the committee that there is
no weakening of the criteria; they are just applied in a more
reasonable way.
17. Issue: what will be the effect of a larger wastewater facility on
one quantity of water availaole to downstream users’?
Response : Water quantity is largely a function of precipitation
anl uomountain vegetation, according to Forest Service
hyorologists, with the sewer plant capacity having minimal effect.
18. Issue: Should CAC consultants conduct an in—depth house—to—house
survey to determine the opinions of the area residents as to the
socjo—econcmic effects of TSV on the cultural values cf the people?
Response : within the mancate of this particular EPA grant, this is
not possible. A rmjlti—dimensional analysis of this area—wide
problem would sore oroperiv be the resoonsicility pf the Taos
County goverrment.
19. :ssue: What is the relationship between the U.S. Forest Service
pro csed Taos Ski Valley master develooment plan anc this EIS?
Response : The Forest Service plan deals only witfl federal land
involveo, while the EIS includes privately owned land as well.
20. Issue: What type of hookup policy should TWSD adopt?
Response : Some type of phased expansion dependent on successful
performance at flows which are initially set at existing levels.

.istea oeio ars :cr”ne ’ts. :t ciic— .. -teres: :r:u:s *ni:r’ wii.. recieve a
OOpy of tre SiC; in ;oci:icn .:ver CC vtner :rcvcs soc inc1 icuaCs are oenc
notifiec of :re SISS cuolication. An sterisK •) ircicates aoencies or
rouos witr wnicn cooroination took oiace curing toe oisr’ni’c orocess.
r ur,cer of toase -oti jec ‘ave rscuestec arc i1i recev,e either a surnarj or
tonciete copy of toe craft 513.
Fece ral
• L. . Forest Service, Carson National Forest
Sarmers noise i oministration
5oi. Ccnservaticn Service
u.S. Ceot. of irterior
1.S. Dept. of oceerce
5. Deot. of Traaspcrtatjon
Feoeral Aviation Rcmin.
Feceral rlionway Acmin.
.S. 1)ept. of Rgriculture
Aater Resources Council
ogrLculture Staoilization enc Conservation Service
CS. Deot. of Energy
Seceral Energy Regulatory Corn.
AbviSory Counci. on Historic Preservation
u. s. Dept. of Housinc sr uroan Ceve1ocoent
i.E. Public riealth Servire
u.S. Deot. of health ano Human Services
—eritage Conservation anc Recreation Service
national Park Service, S W ecion
Cccrcmic Develoci iert Acitin.
Scros of Engineers
• .S. isn a eiioli e Service
iureau of nciar ffairs
bureau of Reclamation
eoiocical Survey uSCS
• . SGS, water Resources Dlvi 5icn
nO fl real;r Service
• sreau of anc Manaçe nt
—on. ?ete s. D enici, .3. Senator
-on. Harrison Scroitt, u.S. Senator
—on. Manuel Lujan Ir., U.S. Recresentative
• Envirornen:aj Inorovsnent l ision
State nealtr ogency
State Plar .ir Cfficer
• e t. of sane Fisn
• State E c:near
ar s & Recreation Cornission
‘ Sept. of Agriculture
• Tr anc Touros r Division
• North entral New 4exico Economic Development i tsicr .
• State .-4i way DeDaltment
• NM Sect, f -ealtn eric Environment
non. Francisco Gcnzales, Senator
—or.. eCesti o Ronero, epresentative
ining aster ano Sanitation District
Cacs town Scuncjl
‘aos :cunty :rirnission
ioe sf toe ‘laycr, aos
ncCoc Interest Ircups
* Comittee to Save toe Rio - oncc
• -,onoc—oeco Cevelopinent 0 5;n,
Fr enOs of Thcs Iaj.e,
acs corOinat!nc Couitci.
Enviromentai -eaitr .$Sn.
NM Citizens for Clean Air & aSter
NM iCciife Feoeraticn
NM .unc Assn.
NM Ccr.servaticn Cocrcinatino Ocuncil
Sierra Ciuo
ailcl:fe Societ
NM •iloerneas St y Ccrctiss:cr,
zaac aaltor League
‘.at:cra_ AuOuoon Socoet,
The a lzerness Society
Envi:crloenta_ e er.se ono
_eacue of corer voters
<. Ac
c 0 —.< 5 i jnstrnctorS
- .3. Ski
acs ::vnt , e::naLs As n.
• Thos C- ’arr:er tf cc-eroe
..oronacc Ski CI..c
NM vcuntair lu , Ire.
Skj Areaa ssn,
Airerican CC:_zens TccezTier
ii;rt Nort’e:n ci .r ueoics Councti
eo c_we; E’j —:ea
• .os
• noivOoro


Name Education Experience Responsibility
Environmental Protection Agency
Clinton B. Spotts B.S., Agrigultural 11 Regional EIS coordinator
Norm Thomas B.S., Chemistry 4 Chief, EIS preparation
Presley B. Hatcher B.S., Biology 5 Twining EIS coordinator,
public participation
David Neleigh M.S., Environmental 7 Chief, Oklahoma-New Mexico
Engineering section, Municipal Facilities
Stuart Gray B.S., Civil 2 Project engineer, Municipal
Engineering Facilities branch
Jan Horn J.D., Law 2.5 Enforcement
Ben Longoria M.S., Environmental 5 water Programs
Rosemary Henderson BA., Economics 7 Public participation
Rich Gentry M. Public Affairs 2 Public participation
Lee Wilson and Associates, Inc .
Lee Wilson Ph.D., Geology 10 Project director; all
Principal sections; alternatives;
water resources
Stevan Anderson M.A., Geography 7 All sections; physical
Senior Environmental environment; other alter—
Scientist natives; graphics super-
Ann Claassen B.S., Chemistry 5 Water resources, irrpacts; air
Environmental quality, energy and other
Scientist resources; biology; non—point

rarole Cristiano M.U.A. Urban Affairs 6 Water supply biology; water
Environmental rights
Carolyn Cupp B.A., Biology 5 Biology; water rights;
Technical Staff editing; glossary; biblio-
Linda Durante BA., Psychology 3 Sensitive resources
Diane Flock B.A., Geography 10 Population, land use, soclo—
Environmental economics; capacity alterna—
Scientist tives
Marilyn Forrest M.A., Education 10 Word processing
William McDonald BA., Behavorial 9 Graphics
Technical Staff Science
Sally Rodgers 18 Editing
Administrative Staff
Lydia Roybal 3 Word Processing
Administrative Staff
Priscilla Visarragn 5 Word Processing
Administrative Staff
Mimbres & Associates
Karen Lyncoln B.A., Urban Studies 14 Soda—economics
Mesa Consultants
Jack Schact B.A., Business 11 Public participation with
Education Citizens Advisory Comittee
Doris Schact B.A., Home Economics! 11 Public participation with
Journalism Citizens Advisory Coninittee


Adams, john, 1981. Personal communication. Director, Tourism and Travel
Division, New Mexico Department of Commerce, Santa Fe, New Mexico,
April—May, 1981.
I\naya, Toney, 1976. Opinion of Toney Anaya, Attorney General, regarding
the Taos Ski Valley Water and Sanitation District. No. 76—33, September
22, 1976, Attorney General of Santa Fe, New Mexico.
Armentrout, Betty, 1980. Personal communication. Director, Taos Chamber of
Commerce, Taos, New Mexico.
BEER, 1977. New Mexico Statistical Abstract. Bureau of Business & Economic
Research, University of New Mexico, Albuquerque, New Mexico
BEER, 1979 — 1980. New Mexico Statistical Abstract, Bureau of Business and
Economic Research, University of New Mexico, Albuquerque, New Mexico.
BEA, 1981. BEA farm income and expenditures, Taos, New Mexico. Bureau of
Economic Analysis, University of New Mexico, Albuquerque, New Mexico.
Beardsley-Davis, 1973. Taos Ski Valley: Kachina Valley master plan.
Beardsley—Davis Associates, Inc., Denver, Colorado
Bernal, Paul, 1981. Statement of concerns of the Taos Pueblo Council and
Community. Letter to Citizen’s Advisory Committee, Twining Sanitation
District, Public Meeting, from the Tribal Council Secretary, Taos Pueblo
Tribal Council, dated March 31, 1981.
Best Way Realty, 1980. Personal communication. Espanola, New Mexico, May,
ELL, 1979. Proposed Twining treatment plant modifications, Twining Water and
Sanitation District. Burton, Leyendecker and Leyendecker, Inc.,
Albuquerque and Las Cruces, New Mexico.
BLL, 1979a. Technical report #2, Twining facilities plan, infiltration—inflow
analysis conclusions. Burton, Leyendecker and Leyendecker, Inc.,
Albuquerque and Las Cruces, New Mexico.
BLL, 1980. Twining Water and Sanitation District water system improvements,
preliminary engineering report. Burton, Leyendecker and Leyendecker,
Albuquerque and Las Cruces, New Mexico.
BLL, 1981. Twining draft facilities plan, preliminary engineering report.
Burton, Leyendecker and Leyendecker, Inc., Albuquerque and Las Cruces, New
Brooks Loomax Realtors, 1981. Personal Communication. Santa Fe, New Mexico,
May, 1981.

Brown, H.G. VI, 1971. Surface geology of’ east division — Carson National
Bryan, Tony, 1980. Numerous personal communications. Bryan Realty, Twining,
New Mexico.
Chappell, Willard R., Robert E. SieVerS, and Robert H. Shapiro, 1981. The
effect of ozonation of organics in wastewater. EPA—600.Sl—81—005, Health
Effects Research Laboratory, U.S. Environmental Protection Agency,
Cincinnati, Ohio.
CEQ, 1978. Regulations for implementing the procedural provisions of the
National Environmental Policy Act. Council of Environmental QualIty, 43
FR 55978—56007, November 29, 1978; 40 CFR, parts 1500—1508.
CID, 1981. Tourism and travel. Composite, Commerce and Industry Department,
Santa Fe, New Mexico, March, 1981.
Coltharp, Ceorge B. and Leslie A. Darling, 1975. Livestock grazing — a
non-point source of water pollution In rural areas? A chapter in: Water
pollution control in low density areas, proceedings of a rural
environmental engineering conference, University Press of New England,
Hanover, New Hampshire, pp. 341—358.
Cooper, Dennis, 1981. Personal communications. Water Resources Division,
State Engineer’s Office, Santa Fe, New Mexico, May and July, 1981.
Cunico, John, J., 1980. Letter and attachment to U.S. Forest Service, Taos,
New Mexico, indicat ng 100—yr. floodplain. From Chief’ of Floodplain
Management Branch, Engineering Division, U.S. Army Corps of’ Engineers,
Albuquerque, New Mexico, dated May 16, 1980.
Dick—Peddie, William A., et al., 1978. New Mexico unique wildlife ecosystem
concept plan. Prepared by Natural Resources Department and New Mexico
State University in cooperation with New Mexico State Heritage Program.
Prepared for U.S. Fish and Wildlife Service, Region II.
EC, 1980. Design and selection of small wastewater treatment systems. Report
No. EPS 3—WP—80—3, Water Pollution Control Directorate, Environmental
Protection Service, Environment Canada.
EIB, 1979. Liquid waste disposal regulations. Environmental Improvement
Board, Santa Fe, New Mexico.
EID, 1975. Water quality of’ the Rio Hondo. Envirorriental Improvement Divi-
sion and U.S. Forest Service, 1974—1975 survey.
EID, 1980. Letter to Water Quality Control Commission from David F. Tague,
Environmental Improvement Division, Santa Fe, New Mexico, dated November
7, 1980.

EID, l981a. Letter to George Gonzales from Joe Pierce. Environmental
Improvement Division, Santa Fe, New Mexico, dated January 23, 1981.
EID, 1981b. Letter to Roger C. Hartung from Joseph A. Pierce. Environmental
Improvement Division, Santa Fe, New Mexico, dated April 28, 1981.
EID, 1981c. Letter to George Gonzales from Charles Nylander. Environmental
Improvement Division, Santa Fe, New Mexico, dated May 5, 1981.
EID, l981d. Point source waste load allocation for the Twining Water and
Sanitation District (Milestone 6.2.a.). Water Pollution Control Bureau,
New Mexico Environmental Improvement Division, Santa Fe, New Mexico,
July, 1981.
Ernmons, Jeff, 1981. Personal ccxnmunication. Environmental Improvement
Division, Taos, New Mexico, March, 1981.
Engineering—Science, Inc., 1980. Upper Eagle Valley non-point source
assessment and control plan, volume 1: assessment of nonpoint sources.
EPA—908/3—8O—OOl, Engineering—Science, Inc., Arcadia, California; prepared
for U.S. Environmental Protection Agency, Region VIII.
EPA, 1974. Permit No. NMOO221O1, Authorization to discharge under the
National Pollutant Discharge Elimination System. U.S. Environmental
Protection Agency, Dallas, Texas, dated May 3, 1974.
EPA, 1975. Non—point source pollution in surface waters: associated problems
and investigative techniques. EPA—680/4—75—O04, National Environmental
Research Center, U.S. Environmental Protection Agency, Las Vegas, Nevada.
EPA, 1977. Environmental effects of septic tank systems. EPA—600/3-77—096,
Ecological Research Series, Robert S. Kerr Environmental Research
Laboratory, Office of Research and Development, U.S. Environmental
Protection Agency, Ada, Oklahoma.
EPA, 1979. Novel methods and materials of construction. EPA—600/2—79—O79,
Office of Research and Development ( ERL), U.S. Environmental Protection
Agency, Cincinnati, Ohio.
EPA, 1979a. Public participation in programs under the Resource Conservation
and Recovery Act, the Safe Drinking Water Act and the Clean Water Act,
Final Regulations, 44 FR (Federal Register) 10285—10297, February 16,
1979; 40 CFR (Code of Federal Regulations), part 25.
EPA, l979b. National municipal policy and strategy. U.S. Environmental
Protection Agency, Office of Water Program Operations, Washington, D.C.,
dated October, 1979.
EPA, l979c. Implementation of procedures on the Nationai Environmental Policy
Act. Environmental Protection Agency, 44 FR 64174—64193, November 6,
1979, 40 CFR, part 6.

EPA, 1979d. State and local assistance —— grants for construction of
treatment works. U.S. Environmental Protection Agency, sub—part E, 40
CFR, part 35.
EPA, 1979e. Crant funding of projects requiring treatment more stringent than
secondary. PRM 79-7, Program Requirement Memorandum by Thomas C. Jorling,
Assistant Administrator of Water and Waste Management, U.S. Environmental
Protection Agency, Washington, D.C.
EPA, 1980. Innovative and alternative technology assessment manual. MCD—53,
Office of Research and Development (MERL), Environmental Protection
Agency, Cincinnati, Ohio.
EPA, l980a. Design manual, on—site wastewater treatment and disposal system.
Office of Research and Development UvERL), Environmental Protection
b genc , Cincinnati, Ohio.
EPA, ‘80b. Biological assessment for EIS wastewater treatment facilities,
nort east El Paso, Texas. Letter to Fish and Wildlife Service,
New Mexico, from Clinton B. Spotts, Environmental Protection
Agency, dated April 24, 1980.
EPA, 198Cc. Small wastewater systems, alternative systems for small communi—
ties and rural areas. FRD—l0, Office of Water Program Operations, U.S.
Environmental Protection Agency, Washington, D.C.
EPS, 1979. Cold climate utilities delivery design manual. Report No. EPS
3-WP—79—2, Northern Technology Unit, Environmental Protection Service,
Environment Canada, dmonton, Alberta.
ESD, 1973. Manpower resource report, Taos County, New Mexico. Employment
Security Department, Smaller Communities Program, Albuquerque, New Mexico.
ESD, 1981. Personal communication. Employment Security Department,
Albuquerque, New Mexico, April, 1981.
Feliciano, D.V., 1980. National municipal policy and strategy: tightening the
screws. Journa] Water Pollution Control Federation 52(1): 3 7.
Fisher, Carla 3. and Charles 0. Ziebell, 1980. Effects of watershed use on
water quality & fisheries in an Arizona mountain lake. Eisenhower
Consortium Bulletin 7, U.S. Department of Agriculture, Forest Service,
Rocky Mountain Forest & Range Experiment Station, Fort Collins, Colorado.
Flack, 3. E., and P. 3. Corder, 1975. Design of water and wastewater systems
for resorts and boom towns. Selected papers of the workshop, March 6—7,
1975, University of Colorado, Boulder, Colorado.
ilancc, 1980. Taos Ski Valley Master Development Plan, Stephan R. Fiance and
Associates, Inc., Santa Fe, New Mexico, January 9, 1980.

Folks, James, 1980. Letter to Lee Wilson and Associates, Inc., Santa Fe, New
Mexico. Dated May 22, 1980.
Gonzales, Joe, 1981. Personal communication. North Central New Mexico
Economic Development District, May, 1981.
Gonzales, Nancie L., 1967. The Spanish—Americans of New Mexico: a distinctive
heritage. Division of Research, Graduate School of Business
Administration, University of California, Los Angeles, California.
Gosz, James R., 1975. Final report for the effects of’ road salting on the
functioning of a forest ecosystem. Biology Department, University of New
Mexico, Albuquerque.
Gosz, James R., 1977. Effects of ski area development and use on stream water
quality of the Santa Fe Basin, New Mexico. Forest Science 23(2): 167—178.
Hadeed, S. J., 1981. Sludge treatment/handling, preliminary treatment, and
instrumentation top 0 & M problem list. Journal Water Pollution Control
Federation 53(4): 412-420.
Hansel, M. J., and R. E. Machmeier, 1980. On-site wastewater treatment on
problem soils. Journal Water Pollution Control Federation 52 (3): 548—558.
Harrison, James S., 1962. State—wide fisheries investigations, basic survey
of Rio Hondo river. Job completion report investigations projects,
project no. F-22--R—3, job no. A—2(3), as required by Federal Aid in Fish
Restoration Act, New Mexico Department of Game and Fish.
Hayes, Don, 1981. Personal communication. State Highway Department, Santa Fe,
New Mexico, April, 1981.
Heckroth, C.W., 1974. Sonics and ozone a winner? Water and Wastes Engineering
11(6): 41.
Hibbert, Alden R., 1977. Potential for augmenting flow of the Colorado River
by vegetation management. Proceedings, 21st Annual Arizona Watershed
Symposium, Arizona Water Coitililsion Report No. 10, Tucson, Arizona.
Hitt, Sam, 1980. Biological Solutions. Sunpaper , Bulletin of the New Mexico
Solar Energy Association 5(6): 16—18.
Isaacs, Bill, 1981. Personal communication. New Mexico Heritage Program,
Santa Fe, New Mexico, June, 1981.
ISC and SEO, 1975. Taos County profile, water resources assessment for
planning purposes. New Mexico Interstate Stream Commission and New Mexico
State Engineer’s Office, Santa Fe, New Mexico.

Jacobi, Gerald Z., 1979. Preliminary report, biological (benthological)
survey of the Rio Hondo, Taos County, New Mexico. Prepared for New Mexico
Ervironmental Improvement Division, Water Pollution Control Section, Santa
Fe, New Mexico.
Jacobi, Gerald Z., 1981. Letter to Jack Crellin, Carson National Forest.
Surveillance Section, New Mexico Environmental Improvement Division, Santa
Fe, New Mexico, dated March 4, 1981.
Jacobi, G. Z., S. J. Oppenheimer, and L. R. Smolka, 1980. Effects of organic
pollution from a ski area on the Rio Hondo, Taos County, New Mexico.
Water Pollution Control Bureau, Environmental Improvement Division, Santa
Fe, New Mexico.
Jenkins, David N., 1981. Letter to Lee Wilson & Associates, dated April 16,
Jiron, Terasino, 1974. Letter to William 0. Hurst, Regional Forest, U.S.
Forest Service. From the Taos Pueblo Council Governor, dated June 24,
Johnson, Ronald D., 1978. Alaska wastewater treatment technology. Office of
Water Research and Technology Project No. A—058—ALAS, Institute of Water
Resources, University of Alaska, Fairbanks, Alaska.
Kleiner, Charlie, 1980, 1981. Numerous personal communications. Rio Hondo
Condominiums, Twining, New Mexico.
Lansford, Robert R., e al., 1979. Sources of’ irrigation water and irrigated
and dry cropland aLreages in New Mexico, by county, 1973—1978.
Agricultural Experiment Station Bulletin 405, New Mexico State University,
Las Cruces, New Mexico.
La Salle, Sonny, 1980, 1981. Numerous personal communications. Questa, New
Leyendecker, Gene, 1980, 1981. Numerous personal communications. Burton,
Leyendecker and Leyendecker, Inc., Albuquerque, New Mexico.
McNall, Warren J., 1980. Personal communication to Larry Frank of the Twining
Water and Sanitation District Citizen’s Advisory Committee, July 7, 1980.
McNall, Warren J., 1981. Personal communication. Fisheries Research and
Management, Department of Game and Fish, Santa Fe, New Mexico, May, 1981.
Merlan, Tom, 1981. Personal communication. State Historic Preservation
Officer, Santa Fe, New Mexico, May, 1981.
Miller, Peter, 1976. Taos, New Mexico. Ski Magazine, January 1976.

Mimbres, 1978. Taos County comprehensive planning program, working paper #3,
socioeconomic factors. Mimbres and Associates, Santa Fe, New Mexico,
December, 1978.
Moehn, William H., 1981. Personal cclTlmunication. Forest recreation and fire
staff officer, U.S. Forest Service, Carson National Forest, Taos, New
Moore, Douglas, James P. Cosz, and Carleton S. White, 1977. Impact of a ski
basin on a mountain watershed part II: heavy metals, Department of
Biology, University of New Mexico, Albuquerque, New Mexico.
Moore, Gordon T., et al., 1969. Epidemic giardiasis at a ski resort. The
New England Journal of Medicine 281(8): 402—407.
Moser, Walter, and Jeannie Peterson, 1981. Limits to Obergurl’s growth, an
alpine experience in environmental management. Amblo 10 (2—3): 68-72.
New Mexico State Highway Department, 1980. Personal communications. Santa
Fe, New Mexico, June, 1980.
NMBJ, 1979. New Mexico Business Journal, September 1979.
NI €SD, 1978. Table B — Labor information series, non-agricultural wage and
salary information. New Mexico Err loyrnent Security Department, Research
and Statistics Section, Albuquerque, New Mexico.
NMESD, 1979. Affirmative Action Information, 1979, Taos. New Mexico
Department of Human Services, Employment Security Department, Research and
Statistics Section, Albuquerque, New Mexico.
NMSU, 1972. The New Mexico State University Agricultural Experiment Station’s
research bibliography. Report 237, July 1972, Las Cruces, New Mexico.
NMWQCC, 1976. Upper Rio Grande basin plan. New Mexico Water Quality
Control Commission, Santa Fe, New Mexico, August, 1976.
NMWQCC, 1980. Water Quality Control Commission regulations. WQCC 77—1,
Amendment #1, New Mexico Water Quality Control Commission, Santa Fe, New
NMWQCC, 1981. Water quality standards for interstate and intrastate streams
in New Mexico [ proposed]. New Mexico Water Quality Control Commission,
Santa Fe, New Mexico.
Nordlinger, Stephen E., 1980. Municipal water treatment falls on hard times.
Conservation Foundation letter, May 1980.
Nordwall, Paul, 1979. Letter to Diane Fanelli, Lee Wilson & Associates, Santa
Fe, New Mexico. U.S. Forest Service, Taos, New Mexico, dated December 10,

NWCCOG, 1978. Draft areawide water quality management plan for Eagle, Grand,
Jackson, Pitkin, Routt and Summit counties, Colorado. Prepared by Comarc
Design Systems and Wallace, McHang, Roberts & Todd for the Northwest
Colorado Council of Goverments, Frisco, Colorado.
Oppenheimer, Steven J., 1981. Letter to Jack Crellin, Carson National Forest,
Taos, New Mexico, regarding the draft EIS for the Taos Ski Valley Master
Plan Proposal. New Mexico Environmental Improvement Agency, Santa Fe, New
Mexico, dated March 4, 1981.
Perrine, Richard L. and Robert A. Mah, 1979. Water quality in mountain
recreational areas. American Water Resouces Association, Water Resources
Bulletin 15(3): 612—627.
Pierce, Joe, 1980. Numerous personal communications. Environmental
Improvement Division.
Pierce, Joe, 1981. Numerous personal communications. Environmental
Improvement Division.
Price, Joan, 1979. Reply to Forest Supervisor’s responsive statement in
Appendix GG, Arizona Snow Bowl Ski Area Proposal and Snow Bowl Road.
Colorado Plateau Project, Colorado Springs, Colorado.
Rabosky, J.G., 1972. Disinfection of water and wastewater. Pollution
Engineering 4(9): 1323.
Reeser, Warner K., Jr., nd Lane W. Kirkpatrick, undated. The air pollution
carrying capacities P selected Colorado mountain valley ski communities.
Air Pollution Controi Division, Department of Health, State of Colorado,
Denver, Colorado
Romero, Anthony E., 1978. A study of air pollution from fireplace emissions at
Vail Ski Resort. Journal of Environmental Health 41(2): 117—119.
Rubin, James S., 1981. Letter to J. Christopher Stagg, Twining Water and
Sanitation District. Mitchell, Alley and Rubin, Attorneys at Law, dated
July 22, 1981.
Ryczak, Robert S. and Roy, D. Miller, 1977. A review of phosphorus removal
technology. Technical report 7706, U.S. Army Medical Bloengineering
Research and Development Laboratory, Fort Detrick, Frederick, Maryland.
Sayre, Doug, 1981. Personal ‘communication. Turney, Sayre and Turney,
Engineers, Santa Fe, New Mexico, May, 1981.
SBP, 1979. Sales and Marketing Management Magazine. Survey of Buying Power
Data Service.
Schaafsma, Curtis F., 1981. Personal communication. Director, Museum of New
Mexico, Laboratory of Anthropology, Santa Fe, New Mexico, May, 1981.

Schilling, John H., 1960. Mineral Resources of Taos County, New Mexico.
Bulletin 71, State Bureau of Mines and Mineral Resources, New Mexico
Institute of’ Mining and Technology, Campus Station, Socarro, New Mexico.
Seidler, Ramon 3., 1979. Point and non—point pollution influencing water
quality in a rural housing community. WRRI—64, Water Resources Research
Institute, Oregon State University, Corvallis, Oregon.
SEO, 1980. File notes and calculations on snowmaking. State Engineer’s
Office, Santa Fe, New Mexico, May, 1980.
Serfling, S. A., and D. Mendola, 1979. The solar aquacell AWT lagoon system
for the city of Hercules, California. Solar AquaSystems, Inc.
Siegrist, R. L., 1977. Segregation and separation of black and grey household
wastewater to facilitate on—site surface disposal. Small Scale Waste
Management Project Report, University of Wisconsin, Madison, Wisconsin.
Solomon, Rhey M. and L. Schmidt, 1979 draft. Water yield increase
opportunities; a focus on national forests in Arizona. Soil and Water
Staff Unit, Region 3, U.S. Forest Service, Albuquerque, New Mexico.
Stagg, 3. Christopher, 1981. Letter to Larry Taub, Citizens Advisory
Comittee. Twining Water and Sanitation District, dated June 26, 1981.
Stagg, 3. Christopher, 1981a. Numerous personal communications. President,
Twining Water and Sanitation District.
Stephenson, C.R., and L.V. Street, 1978. Bacterial variations in streams from
southwest Idaho rangeland watershed. Journal of Environmental Quality
7(1): 150—159.
Stewart, W. C., et al., 1978. Pilot studies of the solar aquacell controlled
aquaculture process for wastewater reclamation. Applied Aquatic Resources
Institute and Solar AquaSystems, Inc.
Stevens Irish Company, 1980. Personal communication. Realtors, Las Vegas, New
Mexico, May, 1980.
Tague, David F., 1981. Limiting nutrient assessment of the Rio Hondo, Taos
County, New Mexico. New Mexico Environmental Improvement Division, Santa
Fe, New Mexico.
Taos Architects, 1970. Comprehensive plan, Twining — Arnizette. Taos
Architects, Taos, New Mexico.
TCC, 1978. Corrrnunlty profile, Taos — Taos County. Taos Chamber of Commerce,
Taos, New Mexico.

ilsworth, T., et al., 1977. Cold—climate water/wastewater transportation and
treatment-—a bibliography. Completion report, Institute of Water
Resuurces, University of Alaska, Fairbanks, Alaska.
TN, 1981. Pattison proposes new ski area. The Taos News, June 18, 1981.
Trujillo, Steve, 1980. Personal Communication. First Northern Savings and
Loan, Taos, New Mexico, May, 1980.
TWSD, 1980. Memorandum to Mitchell, Alley and Rubin. From Robert Gott,
Twining Water and Sanitation District, dated September 4, 1980.
TWSD, 1981. Letter to Citizens Advisory Committee. From Chris Stagg,
President, Twining Water and Sanitation District, dated May 4, 1981.
TWSD, 981a. Letter to Frances E. Phillips, U.S. Environmental Protection
At cy, and Joe Pierce, Environmental, Improvement Division. From Chris
Stagg, President, Twining Water and Sanitation District, dated April 27,
Uiga, Ants, and Ronald W. Crites, 1980. Relative health risks of activated
sludge treatment and slow—rate land treatment. Journal Water Pollution
Control Federation 52(12): 2865-2874.
U.S. Bureau of the Census, 1950. Census of the population, New Mexico, P—A31.
U.S. Bureau of the Census, 1960. Census of the population, New Mexico, vol. 1,
pt. 33.
U.S. Bureau of the Census, 1970. Census of the population, New Mexico, vol. 1,
pt. 33.
U.S. Bureau of the Census, 1979. Statistical abstract of the United States.
U.S. Bureau of the Census, 1980. Census of’ population and housing, advance
reports, New Mexico, PHC8O—V—33.
U.S. Huresu of Economic Analysis, 1980. Survey of current business, U.S.
Department of Commerce, vol. 60(4).
USD1, 1979. American Indian Religious Freedom Act Report, P.L. 95—341.
Federal Agencies Task Force, U.S. Department of Intedor, Washington, D.C.
USD1, l 9 79a. Letter to Clinton B. Spotts, U.S. Environmental Protection
Agency. From R.F. Stephens, Acting Regional Director, Fish and Wildlife
Service, u.s. Department of the Interior, Albuquerque, New Mexico.
USFS, 1969. Reconnaissance hydrologic survey, Rio Hondo Drainage. Questa
Ranger District, Carson National Forest, U.S. Forest Service, U.S.
Department of Agriculture, Washington, D.C.

USFS, 1971. Soil resource inventory for the east half’ of Carson National
Forest. Division of’ Watershed Management, State and Private Forests,
Region 3, Questa, Taos and Penasco Ranger District, U.S. Forest Service,
Southwestern Region, U.S. Department of Agriculture.
USFS, 1974. Draft environmental impact statement, Taos Ski Valley expansion
proposal. U.S. Forest Service, Carson National Forest, Southwestern
Region, United States Department of Agriculture.
USFS, 1979. Letter to Lee Wilson and Associates. From Carveth V. Kramer,
Acting Forest Supervisor, U.S. Forest Service, Carson National Forest,
Taos, New Mexico, dated November 14, 1979.
USFS, l979a. Letter to Lee Wilson and Associates. From Carveth V. Kramer,
Acting Forest Supervisor, U.S. Forest Service, Carson National Forest,
Taos, New Mexico, dated November 15, 1979.
USFS, l981a. Draft environmental impact statement for the Taos Ski Valley
Master Development Plan proposal. U.S. Forest Service, Taos, New Mexico,
January, 1981.
USFS, l981b. Final environmental impact statement for the Taos Ski Valley
Master Development Plan. U.S. Forest Service, Taos, New Mexico, April,
White, Carleton S., James R. Gosz and Douglas J. Moore, 1977. Impact of a ski
basin on a mountain watershed, part I: bacteriological water quality,
Department of Biology, University of New Mexico, Albuquerque, New Mexico.
Wilcox, Lloyd V., 1962. Salinity caused by irrigation. Journal of the
American Water Works Association, February: 217—222.
Wilson, 1978. Water availability and water quality, Taos County, New Mexico.
Lee Wilson and Associates, Inc., Santa Fe, New Mexico, September, 1978.
Wilson, 1980. Future water issues, Taos County, New Mexico. Phase B report,
prepared for the Taos County Board of Commissioners by Lee Wilson and
Associates, Inc., Santa Fe, New Mexico, December, 1980.
Wilson, 1981. File notes. Lee Wilson & Associates, Inc., Santa Fe, New
Wombold, Lynn and John Temple, 1979. Population estimates and projections:
1970—2000, counties and wastewater facility planning areas. Bureau of
Business and Economic Research, University of New Mexico, Albuquerque, New
Mexico, October, 1979.
Yguado, 1972. Economic base analysis, final report, Taos Planning Area, New
Mexico. Yguado Association, Albuquerque, New Mexico.


Common Abbreviations
AF Acre—feet
AFY Acre—feet per year
BOD Biochemical oxygen demand
CAC Citizens Advisory Committee
cfs Cubic feet per second
COD Chemical oxygen demand
CWA Clean Water Act
DO Dissolved oxygen
EIB Environmental Improvement Board
(NM)EID (New Mexico) Environmental Improvement Division
EPA Enviromental Protection Agency (U.S.)
kwh Kilowatt hours
mgd Million gallons per day
mg/i Milligrams per liter
NEPA National Environmental Policy Act
NMWQCC New Mexico Water Quality Control Commission
NPDES National Pollutant Discharge Elimination System
OSS On—site system
TCDWSA Twining Cooperative Domestic Water and Sewer Association
TDS Total dissolved solids
TOC Total organic carbon
ISS Total suspended solids
ISV, Inc. Taos Ski Valley, Inc.
TSVW SD Taos Ski Valley Water and Sanitation District
TWSD Twining Water and Sanitation District
USFS United States Forest Service
WRD Water Resources Division
Acre—foot. 1 acre—foot is the amount of water which covers one acre to a depth
of one foot.
Acre—foot per year. Equals 325,851 gallons or 43,560 cubic feet; this unit is
used to quantify amounts of water rights.
Advanced secondary treatment. Treatment more stringent than secondary
treatment but not to advanced waste treatment levels (see definitions of
secondary treatment and advanced waste treatment).
Advanced waste treatment. Treatment providing for discharges with BUD and TSS
of less than 10 mg/i (each) and/or total nitrogen removal of greater than
50 percent.
Aerobic/anaerobic microorganisms. Microorganisms that either thrive on air
(aerobic) or do not (anaerobic). Aerobic bacteria are more efficient at
consuming organic matter while anaerobic bacteria produce humus and gases,
such as foul—smelling methane.

Aeration. The process which brings about contact between air and water by
natural or mechanical means such as spray, bubbling, or agitation.
Aerated lagoon. A method of treating sewage by placing it into a lagoon and
introducing mechanical aeration. The oxygen supports microorganisms
feeding on the organic matter in the sewage, and at a more Intense level
than would occur naturally.
Basal area. The area occupied by timber in square—feet per acre.
Biochemical oxygen demand (BOO). The oxygen demand of a sample of water is
the amount of elemental oxygen required to react with oxidizable or
biodegradable material dissolved or suspended in the sample. When the
agency through which the oxidation is affected is a population of
bacteria, the oxygen required is called the biochemical oxygen demand
(E D). BOO tests are usually run for 5 days, hence c3005. SOD load is
thn oollutant content of a body of water, usually expressed in pounds of
oxygen required to break down the pollutants.
Black wastes or blackwater. Waste from a toilet or urinal or garbage disposal.
Chemical oxygen demand (COD). (See BUD). A quick (and only approximate)
measure of loads of oxidizable matter in water (in milligrams per liter)
in which a strong oxidizing agent is used instead of microbial life. Like
BOO, COD is an oxygen demand parameter; however, results cannot be used
interchangeably with BUD values. COD can quickly Identify water with very
low or very high BUD potential.
Chlorination. The app2 ation of’ chlorine to water or wastewater, generally
for the purpose of disinfection, but frequently for accomplishing chemical
results, such as oxidation of odor—producing compounds.
Chlorine residual. Chlorine remaining in water or wastewater at the end of’ a
specified contact period as combined or free chlorine.
Clarif ’iers. Mechanical devices for removal by gravity (settling out) of
;uspe ded particles in a liquid such as sewage.
Conductivity. The ability to carry an electrical charge, in ions. The
conductivity of aqueous solutions is increased by dissolved salts and thus
is a measure of’ the amount of ionized salts in solution.
Consumption. The amount of’ diversion of water not consumed, but returned back
to the stream; also called discharge.
Cubic feet per second (cfs). Units used to measure flow at a gaging station;
equals the rate of’ flow In a channel with a one—square—foot cross—section
and velocity of’ one foot per second. One cfs for a 24—hour period equals
86,4000 cubic feet or 1.98 acre—feet.

Digester. In a wastewater treatment plant, a closed tank that decreases the
volume of solids and stabilizes raw sludge by bacterial action.
Discharge volume. The quantity of liquid flowing per unit of time in a stream
channel, conduit, or orifice at a given point.
Dissolved oxygen (DO). DO concentration of unpolluted water depends primarily
on atmospheric pressure and temperature. Therefore, it is greater at sea
level and when water is cool than at high altitudes or when water is
warm. In the course of breaking down excess organic matter in water,
microbes may deplete the oxygen causing stress from lack of’ oxygen on fish
and other aquatic life. In extreme depletion, water may become anaerobic
(literally without air) stagnate, and stink.
Diversions. The amount of’ water taken from a stream (or spring, well); also
called withdrawals.
Effluent. Wastewater or other liquid, partially or completely treated,
flowing out of a reservoir, basin, treatment plant, or part thereof.
Effluent limitation. Means any restriction established by a state or EPA
on quantities, rates, and concentrations of chemical, physical,
biological, and other constituents which are discharged from point sources
into navigable waters, the waters of the contiguous zone, or the ocean.
Extended aeration. A method of’ treating sewage involving 24 hours of
mechanical aeration in a tank to Introduce oxygen and support anaerobic
bacteria feeding on the organic matter in the sewage. In the subsequent
settling stage, the mass of bacteria drop out to form a sludge. A portion
of this “activated” sludge is recycled for treatment of fresh sewage.
Fecal Colif’orms. A large and varied group of bacteria. The fecal coliform
bacteria flourish in the intestines and feces of warm—blooded animals,
including man. Escherichia coli CE. coil) is largely of fecal origin and
has been the indicator organism most commonly cited as indicating sewage
or feedlot pollution. The coliforms apparently do not themselves cause
disease, but their presence in water suggests that disease—causing
organisms (pathogens) may also be present. Coliform bacteria are used as
indicators of pollution because they are abundant and their presence is
fairly easy to detect. The coli—aerogenes group is also ar ong indicator
organisms and is not usually distinguished from other fecal coliforms.
Enteric viruses are pathogens round in animal wastes. Methods for their
identification in water remain provisional. The presence of fecal
coliform bacteria suggests that pathogenic and viruses may be
present——hence the concern over danger of bacterial inf tion whenever
large numbers of fecal colif ’orm bacteria are detected in water.
Greywater. Water—carried waste from the kitchen or bathroom sinks, showers,
bathtubs, or washing machines; all household wastewater other than

Grit. The heavier mineral matter, such as sand, gravel, etc., in water or
Groundwater. Subsurface water that completely fills (saturates) all available
space ‘dth1n an aquifer and below the top of the zone of saturation.
Groundwater does not occur in subsurface “lakes” nor move in subsurface
“rivers” except those in a few caves in limestone.
Interceptor. Trunk line, usually at least 12” in diameter, which carries
wastewater from smaller collection lines to the treatment plant.
iifluent Raw or partially treated wastewater flowing 1 ito a sewage treatment
Milligrams per liter (mg/l). One part by weight of dissolved chemical, or
suspended sediment, in 1 million parts by volume (= 1 liter) of water.
5 • Part per million.
lilon ,ja J iOflS per day (mgd). A unit of measurement for expressing the flow
rate of sewage treated at a plant.
Monitoring. Periodic or continuous determination of the amount of pollutants
• present in the environment.
National Pollutant Discharge Elimination System (NPDES). Means the National
perniittlng system authorized under section 402 of the Clean Water Act,
including any state or interstate program which has been approved by the
Administrator, In ‘ le or in part, pursuant to Section 402.
Nitrogen. ee Nutrient.
Non—point source. A type of pollution that cannot be pinpointed to a specific
source. Pollution whose source is general rather than specific In
Nutrient. An element or compound required by an organism for growth and/or
rt€ nance ( nmonly, when referring to water quality, “nutrient”
:.‘ecifically means phosphorus and nitrogen.
on-site system (OSS). Individual facilities for treatment and disposal of
wastewater, as opposed to a public wastewater treatment facility.
Oxidation lagoon. A process for the prolonged detention of sewage in shallow
ponds. Natural (as opposed to mechanically induced) contact with air is
designed to support aerobic microorganisms which digest sewage.
P art er m lljon (ppm). One part by weight of dissolved chemical, or
uspended sediment, ifl 1 million parts by weight of water. Roughly
equivalent to milligrams per liter (mg/i) between 0 and about 7,000 ppm.
pH. Measure of’ hydrogen—ion activity in solution. Expressed on a scale of 0
(hiqhlj acid) to 14 (highly basic). pH 7.0 Is a neutral solution, neither
cic nor h sic.

Phosphorus. See Nutrient.
Point source. Any discernible, confined and discrete conveyance, including
but not limited to any pipe, ditch, channel, tunnel, conduit, well,
discrete fissure, container, rolling stock, concentrated animal feeding
operations, or vessel or other floating craft, from which pollutants are
or may be discharged.
Primary treatment. The physical treatment of sewage, such as by sedimentation
(settling out of solid material), screening, etc.
Return flow. The amount of diversion water not consumed, but returned back to
the stream; also called discharge.
Secondary treatment. Treatment level meeting effluent limitations for BOO and
TSS of 30 mg/i (each) on a maximim monthly average basis. Secondary
treatment removes virtually all floating and settleable solids and most
BOO and TSS from the wastewater.
Septic wastewater. Wastewater in which material is undergoing decomposition
under anaerobic conditions.
Settleable solids. The matter in wastewater which will not stay in suspension
during a preselected settling period, such as one hour, but either settles
to the bottom or floats to the top.
Sewage. A combination of liquid and water—carried wastes from residences,
commercial buildings, industrial plants and/or institutions; wastewater.
Sludge. A concentrate in the form of a semi—liquid mass deposited as a result
of the treatment of sewage.
Sulfate. The sulfate ion is one of the major anions occurring In natural
waters. Sulfate has a laxative effect upon humans when it is present In
excessive amounts. For this reason, the u.s. Public Health Service
Standards recommend an upper limit of 250 mg/l in waters intended for
human consumption. Waters containing appreciable amounts of sulfate tend
to cause odor and corrosion problems.
Total dissolved solids (los). Theoretically, the anhydrous residues of the
dissolved constituents in water. Actually, the term is defined by the
method used in determination. in water and wastewater treatment, the
Standards Methods tests are used.
Total organic carbon (bc). A direct measure of carbon, which is the major
constituent of organic matter. unlike BOD and COD which are indirect
measures of organic matter, TOC can be used successfully as an organic
load parameter .

Total suspended solids (TSS). The sum of the solids which either float on the
surface or are in suspension in water, wastewater, or other liquids, and
which are largely removeable by laboratory filtering, usually stated in
milligrams per liter.
Turbidity. Defined as capacity of material suspended in water to scatter
light. Measured in arbitrary Jackson turbidity units (JTU) or, more
recently, Formazin turbidity units (Flu). Highly turbid water is often
called “muddy,” although all manner of suspended particles contribute to
Wastewater. The spent water of a community. A combination of liquid and
water—carried wastes from residences, commercial buildings, industrial
plants and/or institutions; sewage.

In keeping with U.S. Environmental protection Agency policy, metric units are
used in this report. These units may be converted to common English units by
using the following conversion factors:
Metric Unit Metric N! English Unit
m meter 39.3700 in.
m meter 3.2810 ft.
cm centimeter 0.394 in.
km kilometer 0.6215 mi.
1 liters 0.2642 U.S. gal.
m 3 cubic meters 264.2 U.S. gal.
m 3 cubic meters 6.29 Barrels (Ba.)
m 3 cubic meters 8.104 x 10 acre feet
kg kilogram (l0 grams) 2.2046 lb.
g gram 0.002205 lb.
h hectare 2.471 acres
Volumetric Flow
m 3 s cubic meters per second 35.3 cubic feet per second
m 3 s cubic meters per second 22.8 million gallons per day
mg/i milligrams per liter 1 part per million
Temperature in degrees Celcius (°C) can be converted to temperature in
degrees Farenheit (°F) by the following formula:
(°F) = 1.8 (°C) + 32


Table of Contents Pane
A.l Regulations and Permits A—2
A.2 Existing Facilities
A.3 Wastewater Characteristics
A.4 Management and Enforcement History A—5
A—i Permits and Orders Impacting the TWSD
A—2 State of New Mexico and NPDES Treatment Plant
Effluent Limitations A—8
A—3 On—site System Regulations: Site Conditions and Lot Sizes A—9
A—4 Description of Existing Facilities, Twining, New Mexico A—lU
A—5 Summary of Effluent Quality, 1973—1981, Twining Treatment Plant A—12
A—6 Permit Violations A13
A—7 Pollutant Characteristics of Greywater, Blackwater, On—Site A—l4
Systems and Treatment Plants
A—8 Chronology of Wastewater Management and Enforcement History

The wastewater treatment system of the Twining Water and Sanitation
District (TWSD) is operated under the conditions of: a) two permits, issued
by the U.S. Enviromental Protection Agency (EPA) and the U.S. Forest Service
(USFS); b) an Administrative Order issued by EPA; c) the regulations of the
New Mexico Water Quality Control Commission (NMWQCC); and d) an Assurance of
Discontinuance negotiated between TWSD and EID. Details of all documents are
provided in Table A-i. Two other permits have been Issued to Taos Ski Valley,
Inc. (TSV, Inc.) by the Forest Service. These permits do not affect TWSD
directly but do address water quality above the TWSD treatment plant and are
also summarized in Table A—i.
Forest Service Permits . Because the TWSD treatment plant Is on National
Forest Land it is subject to USFS regulatory control. However, it Is the
position of the Forest Service that EPA is the regulatory agency with respect
to violations of water pollution regulations. Therefore the Region 3 Forest
Service and EPA Region 6 have agreed that EPA should take the lead In enforc-
ing any federal water quality requirements which apply to Twining. The Forest
Service retains responsibility for overseeing stormwater runoff control from
non—point sources, as discussed in USFS (1981a and 1981b) and chapter 6.2.2 of
this EIS.
Surface Water Discharges . EPA’S enforcement responsibility stems from the
agency’s administration of the Clean Water Act NPDES permitting system (see
Glossary and section 3.2). The NPDES permit specifies terms and conditions
which must be met by the effluent discharged from a sewage treatment plant
(Table A—2). To check !I. at the requirements are met, Twining must monitor the
quality of Its effiL rt discharge. Periodically, EID does independent
monitoring; EID and EPA also inspect the plant to see If it is being operated
and maintained properly. If conditions of the permit are not met (for
example, effluent quality is worse than specified), EPA is empowered to take
enforcement action against the permnittee (In this case, the Twining Water and
Sanitation pistrict). Specifically, EPA can send a letter to the permittee
citing the tv iolations. The agency can also serve an Administrative Order on
the perrnittEe, which mandates certain actions by the permittee. Generally,
specific actions are ordered, such as additions to the facility, hiring
certified operators, or Installation of water conservation devices. If the
Administrative Order is not obeyed, EPA can go to court to obtain injunctive
relief which would effectively require compliance with terms of the permit.
The law also provides for fines of up to $10,000 per day for each day of
Although the State cannot enforce the NPDES permit, it can assume
enforcement authority under state water quality regulations 30 days after EPA
notifies the permittee of non—compliance and the permittee takes no remedial
action. Enforcement actions can Include an Assurance of Discontinuance of
violations of State water quality regulations, which is a contract between the
New Mexico Water Quality Control Comision (NMWQCC) and the permittee that the
perrnittee will meet certain standards of performance. I? these standards are
not met, EID can seek an Injunction or court-ordered action; fines up to $1000
per day can be Imposed by the court.

Subsurface Discharges (On-site system regulations) . EID also administers
on—site system (OSS) regulations (EIB, 1979) which cover all systems receiving
2,000 gallons or less of liquid waste per day; systems discharging over 2,000
gallons per day require more thorough review by EID pursuant to state
regulations controlling discharges to ground water.
A permit and inspection is required for all OSS installations and modif 1—
catlons. The permit can be denied if EID feels “the system is located,
operated and maintained so as by itself or in combination with other sources,
to potentially contaminate any drinking water supply, potentially pollute or
cause high nutrient levels in any body of water, potentially degrade any rec-
reational resource, create a nuisance, or cause a potential hazard to public
health”. The regulations forbid the installation or modification of cess-
pools, requiring instead (as a minimum) the installation of a dual—chambered
septic tank with drainfield or seepage bed, or an acceptable alternative sys-
Table A-3 includes key elements from the regulations describing the rela-
tionship between environmental conditions and lot sizes. Lots must be sized
to allow for sufficient setback distances and to prevent the accumulation of
nitrate in the ground water. Water with over 10 mg/i nitrate is believed by
regulatory authorities to pose a health hazard to infants; large lots are
required in an atterr t to ensure that concentrations of on—sites do not
overwhelm the ground water’s ability to dilute nitrate to 10 mg/i.
The existing wastewater facilities at Twining are described in the draft
facilities plan. This section contains only major points of importance to the
evaluation of alternatives.
Collection and Treatment Facilities . Table A—4 sunmarizes Information on
the existing collection and treatment system and on—site systems in the area.
Treatment Plant Influent . There are no industrial users of the collection
system. Average infiuent values are as follows (Leyendecker, 1980):
Temperature: 1°C (10°C without Infiltration)
Biochemical oxygen demand (5 day): 200 mg/l
Chemical oxygen demand: 275 mg/i
Suspended solids: 150 mg/i
Total Kjeldahl nitrogen: 17 mg/i
Ammonia nitrogen: 17 mg/i
Phosphorus: 25 mg/i

Treatment Plant Effluent . Prior to June, 1974 there were no federal
requirements placed on effluent quality at the Twining Plant (state
limitations are given on Table A-2). NMEID sampled effluent quality on four
occasions during this period; the results are listed in Table A—5, along with
results gathered since 1974.
Table A—6 summarizes data concerning violations of the permit, compared to
number of samples. The table divides the data into the ski season
(November—April) and summer (May—October). Major conclusions reached from
study of Tables A—5 and A—6 are: 1) the most common violations have been for
biochemical oxygen demand, total suspended solids, fecal coliforms, and
chlorine residual; 2) violations are more common in the ski season than In
summer; 3) Twining and EID data disagree for chlorine residual; 4) the
frequency of violations had not changed much in the last few years. Effluent
quality was excellent during most of 1980, but mechanical problems led to
permit violations again in late March and April 1981.
A new NPDES permit is expected to be issued in 1981, and will contain
limits for biochemical oxygen demand (BUD 5 ), total suspended solids (TSS),
pH, fecal coliform, chlorine residual, ammonia—nitrogen, and total
phosphorus. Refer to Appendix B and Table 4—1 for a discussion of wasteload
allocation and probable permit limitations.
Wastewater Characteristics of On—site Systems . Table A—7 characterizes
the greywater and blackwater components of raw sewage and allows comparison of
these to various stages and types of treatment (septic tank, drainfield,
treatment plant). Septic tanks commonly reduce solids levels and oxygen
demand levels by roughly fifty percent. Without disinfection, bacteria are
found in quantities o” en exceeding millions per deciliter of water, and
nutrients and metals at levels only slightly less than found in raw
sewage. Given a properly designed and installed drainfield and unsaturated
soil conditions, most remaining pollutants will be removed by bacterial
breakdown In the drainfleld or by adsorption to soil particles. However,
bacteria and viruses may surface or pass to the ground water if a drainfield
Is not working properly, and nitrate nitrogen is likely to pass through the
soil unaffected regardless of system design. Phosphorus is normally
considered to be completely removed by the soil, though exceptions may occur
in areas of seasonal, high—water table and/or coarse soils.
Traditionally, contamination by bacteria has been the type of on—site sys-
tem pollution emphasized by public health officials. However, epidemiologists
are often hesitant to identify wastewater disposal as the specific cause of a
disease pattern, due to the Influences of other variables such as personal
hygiene. Other types of pollution such as nitrate, dissolved solids, iron and
manganese have been thought to result from on—site systems, though confirming
on—sites as the source is difficult because impacts from agriculture or runoff
from roads can be similar in nature.

Many studies have focused on nitrate pollution, as nitrate is especially
mobile in soils and ground water. The significance of nitrate as a nutrient
source in eutrophication (oxygen depletion of water) is well known; Its public
health significance is less clear. Some persons feel that fear of nitrates is
exaggerated because the primary disease of concern affects infants only, is
not fatal if attended to, and has been rare. However, other effects of ni-
trate poisoning may exist, such as physiological stress (EPA, 1977). Further-
more, the lack of reported nitrate poisoning cases may reflect Inexperience
and misdiagnosis.
Table A—8 gives the chronology of wastewater management and permit
enforcement at Twining, as summarized below.
Early developments at Twining utilized individual on—site systems from
1956 until 1966, at which time the Twining Cooperative Domestic Water and
Sewer Association (the Association) was formed, obtained public funding, and
(in 1967) built a wastewater treatment plant. In 1973 the Taos Ski Valley
Water and Sanitation District (isvwsD) was formed to provide eligibility for
funding under Public Law 92—500. The procedure used by the District to annex
the Association was found to be technically incorrect, but a second attempt
was made in 1977, resulting in the present Twining Water and Sanitation
District (TWSD). In 1981 the District absorbed the facilities and
indebtedness of the Association, which was then dissolved.
In the meantime, the Association had been issued an NPDES permit (1974).
Violations of the permit were numerous, resulting in EPA serving an
Administrative Order on the Association in 1976. Association attempts to
comply with the Order were unsuccessful. As a result, EPA and the State of
New Mexico agreed that the State should exercise its power to enforce state
water quality regulations. In 1979 the New Mexico Water Quality Control
Commission (NMwQCC) and the District entered into an Assurance of
Discontinuance whereby state regulations would be met. After extensive
reworking of treatment facilities and operation and maintenance procedures,
effluent quality improved considerably. However, problems with the surface
aerator developed in the winter of 1980—1981, which resulted in two violations
of the regulations. As a result of these violations, the NMWQCC filed a
complaint, and a Judgment by Consent was made, whereby TWSD was required to
pay a $500 penalty, expend $3,000 on plant improvements, and take weekly BOO
and fecal coliform samples. Sample results can be used to enforce the terms
of the Assurance, which remains in effect.
The Assurance was not intended to represent a permanent solution to
wastewater problems in the TWSD; i.e., it will not enable the District to meet
the strict long—term phosphorus requirements described in Table 4—1. However,
it may be several years before a new plant is designed, built and in
operation, and until then the existing treatment plant is required to meet
existing effluent limitations.

1. United States Iorest Service Special use Permit , No. 4042, dated December 5, 1977. This permit is granted to the
Twining Cooperative Domestic Water and Sewer Association (predecessor of TWSO) and is reviewed by the Forest
Service on an annual basis. It covers 3.02 acres, the land with the treatment facilities. Major requirements of
the permit are the following
a. The facility must comply with federal, state and local laws and
requ1 tions related to water and effluent quality.
b. The facility must comply with applicable NPDES effluent requirements.
c. The operator of the facility must be certified by the State.
d. Each year the District must prepare an operation and maintenance plan for Forest Service review, setting forth
in detail measures for complying with their NPO€S permit.
2. United States Forest Service Term Special—Use Permit , No. 4035. The term permit was issued to the Taos Ski
Valley, Inc. on June 30, 1976 for a 30—year period. It covers 36.17 acres of land around permanently Installed
facilities (ski lifts, tows, shelters, telephone communication system and support systems). The permit allows
long term use and access to the facilities. The regulations address:
a. care, upkeep and repair within permit area;
b. protection of scenic and aesthetic values and prevention of pollution or deterioration of lands or waters
within or adjacent to the permit area;
c. safety and health regulations relating to fire protection, control and prevention, refuse disposal, and
protection of stream quality in compliance with standards of local, state and federal authorities;
d. construction standards, and conditions under which construction can commence;
e. required lift Inspection and maintenance;
f. terms of payment and financial reporting;
g. scope and authority of u S with respect to compliance with other provisions of the permit.
3. United States Forest Service Special Use Permit , No. 2721, dated June 30, 1976. This permit was issued to Taos
ski Valley, Inc. and Is reviewed annually by the Forest Service. It covers approximately 1044 acres used for ski
slopes, trails and parking areas. This permit is issued for the purpose of clearing, grooming, and maintaining
these areas. Provisions of the permit incorporate many of the Term Permit provisions and are substantially the
4. United States Enviromental Protection Agency, Authorization to Discharge under the National Pollutant Dischmr
Elimination System (U DES), No. NM 00 2102, dated May 3, 1974. ThIs permit authorizes and regulates t
bistrict’s use of’ the Rio Hondo for elimination of pollutants. The permit expired in May, 1979, but its
limitations are enforceable under the AcWiinistratlon Procedures Act until a new permit Is granted. Its major
provisions are:
a. regulation of amount of u .scharge of sewage effluent into the Rio Hondo;
b. limitations on the amount of pollutants allowed in sewage effluent;
c. monitoring and reporting requirements related to effluent composition, frequency of monitoring and levels of
d. provisions for state water pollution control agency (EID) to inspect District equipment, and records;
e. provisions for non—compliance and compliance schedules and conditions.
The effluent limitations contained in the permit are those normally applied to secondary treatment plants. The
permit limits biological oxygen demand (9005); total suspended solids (TSS); bacteria levels; 1; chlorine
residual and flow. BOO is a measure of organic pollution, which may lower the dissolved oxygen levels in
receiving streams to a point where aquatic animals will be killed. TSS measures potential effects on the clarity
of a stream.
5. United States Envirorniental Protection Agency, Adeinistrative Order , Docket Nunber VI—76—l50, August 16, 1976. In
response to violation of the NPEES permit, the order directed TWSO to take immediate action to efficiently operate
and maintain its treatment facility and to avoid further non—compliance. After discussions with the Envirormental
Improvement Agency (now E ) the Forest Service and concerned citizens, the predecessor to TWSD agreed to:
a. retain the services of a professional engineer to design plant modifications;
b. require commercial users to install grease traps;
c. continue to insist that surge flows be reduced;
d. hire better trained personnel.
The Association voluntarily imposed a hook-up moratoriun, and took legal action to enforce the moretoriun. The
Association also ordered the installation of commercial grease traps, and mode modifications to the system.

6. New Mexico Water ( Jality Control Co rmission (P 4WQCC) Assurance of Discontinuance 1 December 11, 1979. Despite the
actions taken under the administrative order, and espite additional construction in 1977 (equalIzation basin,
aerated sludge holding pond, chlorine contact chamber), OES violations continued. This led to enforcement
actions by Eli). The Assurance is an agreement between the TWSD and the Coaadssion (through Eli)) describing
certain steps the District must take to achieve certain levels of treatment (M DES arid State effluent limitations)
by certain dates. By February 15, 1980, biochemical oxygen demand (BOO) in the effluent from the plant was not to
exceed 60 mg/i more than once in 30 days, and fecal coliform bacteria were not to exceed 500 organIsms per 100 ml
at any time. By November 1, 1980, the effluent limitations to be net were 30 lag/ i BOO, 500 fecal coliform per 100
ml; 125 mg/i COO (chemical oxygen demand), 0.5 mg/i settleable solids, and a pH of 6.6 to 8.6. The last four
requirements are State effluent limitations (see Table A—4). Self—monitoring is required of the District by
taking composite samples of BOO and fecal coliforms on either a Saturday or Sunday during each week of the ski
season; results must be provided to Eli) within 30 days. If the District fails to comply with any of these
provisions, I 1WQCC retains the right to take appropriate legal action.
Suggested improvements and resulting actions fell into four categories.
a. Measures (such as water conservation) to reduce flows into the treatment plant, and thus reduce hydraulic
overloading. Action: a flow meter was installed at the plant; additional low—flow fixtures were installed,
as were water meters.
b. Steps to reduce the emount of pollutants in the sewage which flows to the plant. Action: partially
accomplished by item 1 above and by a continued ban on the use of phosphate detergents.
c. Changes to improve the efficiency of the treatment plant itself. Action: the equalization basin was
converted to an aeration basin; the package plant was converted to a clarifier (thus both aeration and
clarifier capacities were increased).
d. Improvement in the level of management and operation by the District. Action: the District developed an
operation and maintenance manual for the remodeled plant; hired a bookkeeper and full—time certified
operator; and increased the wastewater budget from $50,000 to more than $100,000 per year.
A- 7

Applicable effluent limitations for Twining prior to June, 1974, were those of the State of’ New Mexico, as derived
from the New Mexico Water Quality Control Comeisslons stream standards (NI4WQCC, 1981) and effluent regulations
(NMWUCC, 1980). Since then, applicable standards have been as follows.
June 1974—Dec. 1976: “interim” NPDES limitations (see below).
Jan. 1977—Dec. 1979: “final” NPDES limitations (see below).
Dec. 11, 1979—Nov. 30, 1980: 60 800 (under the authority of the Assurance of’ Discontinuance).
Dec. 1980—June 1, 1981: State limitations and final NPDES limitations, (under the authority of the Assurance
of Discontinuance).
Since DeC. 1979, weekly self—monitoring has been required by the State, in addition to Quarterly monitoring by ElD
for the NPDES permit.
kg kilogram (1 kg 2.2 lbs). eg/l = milligrams per liter (= one part per million). ml = milliliter.
Biol. Oxygen Demand (leg/i)
once every
three months
Total Susp. Solids (mg/i)
once every
three months
Fecal Coliforms (colonies
per 100 ml)
once every
three months
Chlorine Residual (mg/l)
twice per week
Settleabie Solids (mg/ I)
twice per week
Chemical Oxy. Demand (mg/l)
Flow or Discharge (gallons
per day)
no more than
75,000 on any
given day
each day
*Note on BUD and TSS limits: EPA defines secondary treatment as that which results In an effluent quality of
30 mg/l BOO and 30 mg/i 155 (30/30). From surveys of existing effluent quality In New Mexico at the time that
l PDES permits were Issued, the €10 I t that 60/60 would be a reasonable level for interim effluent quality,
and that 2.5 years would be enough tilT to upgrade treatment plants so that they could meet the 30/30 standard.
Sources: tMWQCC, 1980; EPA, 1974

The minimum lot size required is determined by the most limiting condition under
which a soil characteristic rails. For exafiple, if for a certain soil all site
limitations were slight to moderate, except that the slope was over 25%, then either
an alternative absorption field would be required or a holding tank or recycle system
would be necessary. Where black water is confined to an enclosed system (composter,
holding tank), required depth to ground water can be reduced by two feet and
absorption field size can be reduced by forty percent.
SOIL LIMITATIOWS Sjicht Moderate Severe
Percolation rate (minutes/inch) 0 — 15 16 — 30 30 — 60 More than 60
Slope (feet/bC feet) 0 — 8 8 — 25 8 - 25 More than 25
Flooding potential Less than 1 in 25 More than 1
(overfloi frequency in years) in 25
Soil depth (depth of suitable soil More than 4 Less than 4
below trench bottom in feet)
Depth to seasonal water table In More than 10’ (or 6’ If Less than 10’
feet, from bottom of excavation documented) (or 6’ if
(lot sizes less than 2.5 acres) docUmented)
Depth to seasonal water table in More than 4’ Less than 4’
feet, from bottom of excavation
(lot sizes over 2.5 acres)
SIGN FLOW (PD) Miniaum Lot Size (Acres)
Comeunity water and on—site sewerage
0 - 375 0.33 0.40 0.50 No convention..
376 — 1000 0.50 0.75 1.00 al absorption
1000 — 1500 1.00 1.20 1.50 field allowed
1500 — 2000 1.25 1.50 2.00 (see below)
On—site water and on—site sewerage
o - 1000 0.75 1.00 1.25 No convention—
1000 — 1300 1.25 1.60 2.50 al absorption
1500 — 2000 1.70 2.23 3.25 field allowed
(see below)
LIMITING CH RACTEPI5TIC Alternative Absoretion Field Methods
Soil Depth —— Mounds or sand filters to maintain a suitable
soil depth below trench or excavation bottom of
at least four (4) feet.
Percolation Rate —— Alternating fields, seepage pits, deep trenches
(between 60 - 120 mm/in) or beds. Pits or trenches car be used to get
below a slow percolating soil. All
systems shall prevent surface ponding.
Slope —— Deep trenches or terracing which will, not allow
(between 23 — 50%) any sidewall seepage.
Seasonal Ground—Water Table—— Mounds or sand filters which allow compliance
with the requirements for seasonal ground water
Source: adapted from EIB (1979)

Treatment Plant
Treatment facilities originally consisted of a 32,000 gallon per day package plant. An equalization basin (with
diffusers) and chlorine contact chamber were added in 1977. In 1979, a surface aerator was added to the equalization
basin and return sludge pumps were added to the aeration chamber of the package plant, thus converting the package
plant into a clarifier. Modifications in 1980 Included installation of pressure sand filters for effluent polishing,
and improvements made to the chlorination system to increase detention time and frequency of chlorine feed.
At present the treatment plant consists of a manual bar screen for grit removal, an aeration basin which has
potential for equalization of flows as well as removal of’ organic matter, clarifiers for settling of solids, pressure
sand filters for effluent polishing, a hypochlorinator and two 1,000 gallon chlorine contact chambers connected in
series, and an outfall line to the Rio Honda. The facility has an aerated sludge pond for reduction of solids
byproducts of the treatment process. There Is no alternate power source available at the plant. Sampling of the
effluent is performed regularly by IWSO. Daily records are kept by the operators; The District employs both a Class
IV (highest rating) and a Class III operator certified by the State of New Mexico. Assistance is available for
records keeping and management of the District’s budget. The 1980 wastewater budget was $102,482.
Several major design inadequacies exist. Though the original package plant structure is in fair condition, its
use as a clarifier is Inadequate and inefficient in terms of sIze and shape. The headworks to the plant are too low
in grade, causing backups during high flow periods, Disinfection time is insufficient due to the inadequacy of the
two septic tanks now used as contact chambers. Disinfection using chlorine is cuestionable for a high—quality stream
due to the potential for chlorine residuals and the need to eliminate such residuals at hicih cost. There are
existing facilities for phosphorus removal. The aerated sludge pond serves only a holding function and requires
periodic removal to a disposal area near the Taos treatment plant. Treatment effectiveness has also been adversely
influenced by the volume of sewage inflows, which in winter and spring may be greater than the design capacity of the
plant. Were the infiltration problem to be resolved, it appears that the maximum flows experienced on busy weekends
would be reduced from the vicinity of 100,000 gallons per day (gpd) at present, to very near 58,000 gpd.
Collection System
Existing sewage collection facilities consist of’ about 7,500 feet of vitrified clay pipe six to eight inches in
diameter. There are twenty—one service connections, including thirteen conrnercial and nine residential; all but one
of the major lodges/condominiums is connected. The collection system was examined in a pre]iminary
infiltration/inflow study (I/I) in August, 1979, to estimate leakaçie of water Into the system. Inflow of surface
water during rainstorms was found to occur at several badly-built manholes, but calculations indicate that the amounts
of water involved are relatively insignificant. However, infiltration of ground water through cracks or pipe joints
is very significant. During the testing period infiltration amounted to two—thirds of the total flow into the
treatment plant, or about 25,000 qallons per day. This is a rate well over twenty times the amount allowed by
State regulations, indicating that the existing sewers are in very poor condition. This condition stems from poor
installation in 1967, as well as ongoing protrierns of high ground water and frequent freeze—thaw cycles.
Recent Improvements
During the past two years, the following improvements have been made at the treatment plant.
1. Hired two certified operators, one to maintain all operations and one to
run analytical lab (NPEES parmrneters and process control parar’eters).
2. Set ip spare parts inventory d preventative maintenance systems.
3. ModIfied headworks hydraulics so that varied flows can be accommodated.
4. Ordered phase protectors for headworks and clarifier buildings.
5. Painted headworks, clarifier, and chlorine buildings.
6. Extensive repairs made on diffuser system in aeration basin.
7. Established system to monitor levels in aeration basin.
8. Tnsi.ilation and heat tapes installed on the exterior piping of the waste—
activated sludge and return activated sludge systems.
9. Purchased submersible pump for the purpose of cleaning contact chambers
and detention tarks.
10. Improved process control monitoring system at the plant.
11. Improved chlorine system to prevent complications in winter.
12. Modified diffuser system in chlorine detention tanks.
13. Analyzed decant system and found improperly installed electrical network.
14. Sized and ordered water flow meters for commercial and residential
15. Conducted a review and compiled maps of water system.

TABLE A-4. (continued).
16. Increased the aeration system In the digester.
17. Modified the large clarifier to improve the hydraulics and thereby
improve settling.
18. Purchased spare parts for aeration basin surface aerator.
19. Installed pressure sand filters to provide effluent polishing.
20. Repaired aeration basin (cracks, diffusers).
Q! S1te Wastewater Systems
On-site systems (055) include all methods of wastewater disposal that do not discharge to a shared collection
system leading to a public treatment plant. Although cesspools and privies are often used, the most common on—site
System is the septic tank and drainfield. The septic tank is normally a metal, concrete or cinder block container,
corrçletely enclosed, and capable of holding 1000 gallons on the average. Household (or business) sewage drains via a
pipe to the septic tank. The sewage is held In the tank lone enough to allow solids to settle out; foam and grease
float to the surface. Anaerobic (non—oxygen requiring) bacteria digest and reduce the bulk of the settled solids,
which Is termed septage. Crease end septage remain in the tank while the now relatively clear effluent enters the
drainfield, which is a series of perforated pipes or open tile pipes buried in trenches or in a pit in the soil.
Additional treatment by anaerobic bacteria occurs in the trench. The effluent from the drainfield percolates into the
soil where remaining impurities are either filtered out physically, adsorbed onto soil particles, utilized by plants,
neutralized by bacterial attack, or pass unchanged to the underlying ground water. Grease and septage must be removed
from the tank every few years to prevent overflow and resulting drainfield failure.
The effectiveness of a typical drainfield depends on factors such as soil conditions, slope, depths to water table
and bedrock, potential for flooding, lot sizes and setbacks. Soils should pass water (percolate) at a moderate rate.
Slow, very fine—textured soils can result in saturated ground and sometimes surface ponding; ground that is saturated
below the drainfield can reduce the effectiveness of pollutant removal. Fast, coarse soils do not provide adequate
time for removal of pollutants. Steep slopes can result in lateral flows and surface seepage. Flooding and shallow
depths to ground water or bedrock can also cause or aggravate soil saturation, ground—water pollution and/or surface
seepage. Small lots may not allow for safe distances to wells, drainageways, foundations and the like. Specific
drainfjeld conditions that most be met are described in Table A—3.
In urban areas, even where enviromental conditions for on—sites are good, too many on—sites may result in
saturation of soils or overwhelming of the ground water’s ability to dilute pollutants that may pass through
drainfields, such as nitrogen. Results can Include surface and ground—water odors and degradation or contamination of
Shallow ground—water supplies.
Several types of OSS are used in the lower Rio Hondo Valley. Cesspools, and some privies, are likely to be cannon
in the older communities of Arroyo Honda and Valdez. Conventional septic tanks with drainfields probably make up less
than one half of the systems in these communities. From the Forest Service boundary up to Twining, septic tanks are
more prevalent, with a few holding tanks and privies (for seasonal cabins) in use as well.
The Twining Water and Sanitation District contains fifty—nine ncabinsN, only fLve of which are connected to the
Sewer system. Most cabins utilize septic tanks with. drainfields. At least five cabins use holding tanks and one has
an aeration tank. Kandahar condominiums use septic tanks with dry wells. An additional 94 building sites are
available for cabins, and Taos Ski Valley plans to add a snack bar and “up—mountain” restaurant which would probably
use an oss.
Host future 055 are likely to be alternative systems due to environmental conditions (See Appendix 8.5). The best
building sites have been built on and remaining lots are located on either the Presa-cryaquolls or the Marosa—Rock
Outcrop soil associations. The former has Slopes of 5 to 50 percent and Is also likely to have groundwater within a
few feet of the surface. Shallow ground—water results in saturated soils and an easily contaminated aquifer. The
t4arosa-Rock Outcrop has greater slopes, from 20 to 100 percent, and is likely to have bedrock near the surface;
combined, the slope and bedrock can result in lateral flows and surfacing of westewaters. Most remaining lot sizes
are less than half an acre.
EXO cannot designate whole areas as requiring alternative Oss, but most examine each permit request individually.
However, the more recent OSS installations have been alternative systems, and as building sites become more difficult
to build on, the trend towards requiring alternative ass Is likely to continue (Emmons, 1981). New condominiums will
also be required to use alternative. OSS unless they are willing to underwrite appropriate improvements in the
District’s treatment plant (Em, l981a).

Parameter Unit
Flow (mgd)
biological Oxygen
Demand (rag/i)
Total Suspended
Solids (mg/i)
Fecai ColiforntsW
(no.1100 ml)
Chlorine residual
Settleabie Solids-
Chemical Oxygen
demand (mg/i)
(mg/i as P)
Total Phosphorus
(mg/i as P)
Nitrate (mg/ I as N)
Ameonia Nitrogen
(mg/i as N)
Total Kjeldahl
Nitrogen (mg/i)
lotal Nitrogen
Total Organic
caitron (mg/i)
leaperature (°C)
Dissolved Oxygen
13.3 — 15.06
— - 27.75
15.8 — 8.6
3.3 - 7.25
a. Ore saiple
b. Expressed as powers of ten. E.g., 3x10 4 = 3xlOxi OxiOxl O = 3x 10, 00 0 = 30,000.
c. April data was not irtluded in tie average, since the n&.mter of sanpies is Ls known. The average April
value was 0.67.
ii. “Less then” values ware averaged In as teif the given value. For ex le, it 0.1 would be averaged in as
e. Average Includes Dec. values of 2,300 & 440. Excluding these two measurements, average is 4.76.
f. Includes values for nitrite & nitrate. Nitrite is quickly oxidized to nitrate In the stream.
g. Influent 800 measured as 158 mg/i by grab sanpie.
Eli) s np1e data
baeei on T 4SD’ s self—monitoring somple data
It ies ti . tr trace. mg/i = mi1iitjr s per liter. tagd = million gallons per day.
1976 1977
ETU o1f
Eli) Self EID Self Eli) Self Eli) Self ELi) Self SIC Self EID Sr
0.061 0.05 - 0.04 - 0.L
- 0.02
- 0.05 0.05 0.0-4 - 0.025
— 97.3 27.6
— 28.7 22.25
it 0.1
p 1
- 0.065
- 7.0
— it 0.22
— 131
it 0.1
it 0.01
- 7.0
- 0.8
100 60.2
94.2 74.6
7 4 (X)
— it 0.01
it 0.01
1x10 5
- 32.r’
— 23.I T
— 392.5
— it 0.01
7.3 7.03
3.3 — 2.8 —
0.10 - 0.91 —
168 209.5 305 102.5 42 50
— 248.5 263 41.5 6.3 17
7x10 3x10 4 6x10 4 7x10 5 — lxl O 4
0.62 tr 1.2 It 0.01 - It 0.01
6.8 6.53 6.8 6.62 - 7.0
2.0 0.7 — 2. / -
110 — 569 - 90 33
1.92 —
0.65 - — — - 4.46
10.54 — — — — lii
— 3.29
15.85 — — 3.29
41 — 132 — — 24
7.8 — 3.3
209 - 271
6.3 -
6.26 -
0.82! 1
30.08 i9.7 ’
- -
- 2O.7 ’
6.0 -

Table indicates the number of violations/number 0 f samples. For example, 2/4 means that of four samples, two had
excessive values. In some cases the self—monitoring reports give the month’s average and maximum values, but are not
clear as regards the nunber of samples which were in violation. “A” means that the average value for the month
exceeded the permit limitations. “N” means that the maximum limitation was exceeded. NP means that no values were
reported, though required by the permit.
74 sulmler 0/? 2/4 0/? NR 0/2 0/2 0/1
74—75 ski A, N Dec—April 0/3 1/2 N, March 1/2 1/2 1/2
75 summer A, M May, June 1/84 0/12 MR 0/2 0/2 1/2
75—76 skI A, N Dec—AprIl 0/? A, H Dec—April MR 2/2 1/2 2/2
76 suenner A, N May 0/157 A, N May—July, Sept. 1/19 0/2 D/2 0/2
76—77 ski A, N Dec—March 0/161 4, N Dec, Jan 0/91 2/2 2/2 2/2
77 sumer N, Aug 0/178 A, N June 0/94 0/3 2/3 1/4
77—78 ski A, M Feb—April 1/169 A, N Jan—March 0157 4/5 4/5 3/3
78 surmier £‘ A, May 0/? MR 0/? 1/1 1/1 2/?
78—79 ski A, N Dec—April 0/117 MR 0/54 2/3 3/3 0/2
79 sunnier A, H May—July 0/68 FIR 0/58 0/1 0/1 0/1
79-80 Ski A, N Dec-April 0/125 NR 0/40 23/27 26/27 3/21
N, May & June
80 summer A, Nay—Aug 0/158 HR 0/63 0/20 0/19 0/17
80—81 Skl: / A, Dec—Mar 0/89 NP 0/24 5/13 4/15 5/13
N, Jan—Mar
74 winter ois — 2/2
74 sumner 0/5 1/1 — 1/2
74—75 ski 0/4 1/1 6/8 1/1 — 6/11
75 sumner 0/6 — 5/5 0/1 — 3/7
75—76 ski 3/3 0/3 3/3 4/4 4/4 3/4
77—78 ski 2/2 4/4 2/2 1/2 2/4
78—79 ski 2/2 - 2/2 — 2/2 2/2 0/2
79—80 ski 1/1 0/2 6/8 .10/10 9/10 7/9
80 summer — 0/1 2/3 1/3 0/3 0/3
80—81 ski 1/1 0/ 1 — 1/3 2/3 —
a. “sumner” = May through November. “ski” = December through April.
b , The permit requires monitoring for settleable solids, but does not set a limit on the value. Violations are based
on New Mexico State standards.
c. No reports for July and August were aveIlab1e.
d. Does not include April.
A- 13

Septic tank values are for tanks treating total waste stream, and for effluent directly
from the tank. rag/i milligrams/liter.
Nitro er
= Total
I l14 = Ammonia
NO 3 = Nitrate
Source and Parameter
TKN = Total
Greywater . 1
% total waste stream

Oct., 1966 Twining Cooperative Domestic Water end Sewer Association formed.
1967—1968 The Association received en Fn -lA loan of $118,624 and a Federal Water Pollution Control
Administration grant of $16,360 to construct a package sewage treatment plant; construction
was completed in early 1968.
Jan., 1973 Taos Ski Valley, Inc., and Pattison Trust introduced a master plan for development of
private land and additional ski facilities.
May, 1973 The Pattison family, which owns land in the area, filed a petition for the formation of the
Taos Ski Valley Water and Sanitation District to serve a portion o$ the proposed
development; a court order forming the District was Issued the following January. To
become eligible for funding under Public Law 92—500, TSVWSD sought to annex the
Association. In response to a request from a State legislator, the New Mexico Attorney
General issued a legal opinion with respect to the formation of the District and the
annexation. The opinion stated that it was suitable to form a sanitation district which
represented primarily commercial establishments, that the District was properly formed and
that it would be eligible for federal funds. However, the Attorney General cited
irregularities in the District’s annexation procedure and the District never became an
active organization.
May, 1978 The Association received an NPcES permit from EPA.
Aug., 1976 EPA served an Administrative Order on the Association mandating compliance with the NPDES
permit, and suggesting installation of grease traps and reduction of surge flows. Steps
toward compliance included construction of a large equalization basin and installation of a
lift station, an aerobic digester and a chlorine contact chamber; a $35,000 loan was
received from F1rHA to fund construction, which was completed in 1977. TWSD also
established a moratorium on hookups to the wastewater treatment system In an attenpt to
improve the situation. However, permit violations continued.
May, 1977 As a follow—up to the unsuccessful TSVWSD, the Twining Water and Sanitation District (the
District) was formed, questions were raised concerning possible irregularities in the
formation of the District, but the Attorney General responded that both statutory and case
law prohibit challenging the legality of a special district 30 days after it is formed.
Nov., 1978 An EPA memo dated November 21, 1978 states that the TWSD has the legal authority to carry
out the functions required of a grantee under the construction grant regulations.
June, 1979 TWSD received a Step 1 FacilitieS Planning Grant from EPA, to plan new facilities.
Sept., 1979 EID informed TWSD of ElD’s Intent to seek compliance with straight water quality
regulations through legil action. 8elow is a suumrary of EID correspondence regarding
operation and maintenance problems.
1. Lack of routine maintenance: continuously from 3/68 — 1/78.
2. Lack of trained operating personnel: continuously from 3/68 — 5/73. In 1973, the
General Manager attended a training session. In Dec., 1979, Twining hired a certified
3. Lack of a trained operator, maintenance schedule and records: continuously from 3/68
* 4/75. In May, 1975, Twining stated that such procedures had been put into effect.
4. Lack of basic lab equipment: continuously from 3/68 — 5/78.
5. NumerouS operational problems, indicating lack of trained personnel, inadequate time
commitment from operators: continuously from 3/68 — 2/77. In May, 1975, Twining
responded to ElO, implementing operational reconvnendatiofls.
6. Failure to report results of tests on effluent: sporadically from 4/75 — 12/78.
Twining submitted other monitoring reports on schedule.
Subsequent letters more clearly defined water—quality goals and requested that TWSD enter
into an Assurance of Discontinuance with the Water Quality Control Commission to meet
specific effluent limitations in accordance with state water quality regulations.
Dec., 1979 The New Mexico Water quality Control Conaiission approved the Assurance of Discontinuance
between IWSO and EID to end violations of Section 2—101 of the New Mexico Water quality
Control Commission regulations.
1980 TWSD instituted the provisions of the Assurance, including flow reduction, reductions in
the pollutant load, major structural/process alterations in the treatment plant, and
hiring of full—time operator and records personnel.
Mar., 1980 E1D files a complaint against IWSO in District Court because of’ violations of the
Assurance. TWSD and EID agree to a stipulation that the complaint would be dropped if
TWSD meets the Assurance between April 7 and May 15, 1980.
Apr., 1981 EID informs District it is out of compliance with Assurance.
A- 15


Table of Contents PaQe
8.1 Treatment Objectives B— 2
B.2 Equalization Basins B 3
8.3 Dollar Costs B— 3
B.4 Wasteload Allocation for Phosphorus B— 4
8.5 On-Site System Alternatives B 8
List of Tables
B—i Cost of Fifteen Treatment Alternatives
8—2 Cost of Six Semifinal Alternatives 840
8—3 Alternative Methods of On—Site Disposal and Treatment B—li
4st of Figures
B—i Effect of Equalization Basins on esign Flow B 12

The evaluation of the alternatives was complicated because late in the
planning period it was announced that regulations Influencing treatment
objectives were to be changed. In the final analysis all alternatives must be
judged according to their ability to meet the proposed effluent standards
listed in Table 4—1. The essential requirements are for conventional
secondary treatment (reduction of organic matter and solids), advanced
treatment to reduce phosphorus content, and disinfection to control bacteria.
However, when the facilities planning process began the state stream
standards for high mountain streams were different than those listed in Table
4-1, and it was expected that any treatment plant in Twining would be required
to reduce the total amount of nitrogen in the effluent. Subsequently It was
proposed that the standards be amended to require control of phosphorus or
nitrogen, depending on which nutrient is critical to improving river qualit 7
(see section 6.2.2). For the Rio Honda, the New Mexico Environmental
Improvement Division (EID) has determined that phosphorus Is the critical
nutrient affecting the river. Nitrogen removal is not likely to be required
at a new facility (EID, 1981d).
Two major changes occurred in the analysis of alternatives In response to
the elimination of a nitrogen—removal requirement.
1. Nitrogen treatment contributed to high dollar costs (energy,
chemicals, personnel) for so—called ‘conventional’ processes. These high
costs made it feasible to consider many otherwise exotic alternatives; In
fact, many of the fifteen treatment alternatives were suggested only as a way
of sQiving the nitroger problem without all of the problems associated with
conventional treatment. (Example: alternative 8 was conceived as a means of
avoiding nitrogen treatment entirely, since It would convey Twining effluent
along a 13—mile pipeline and discharge it to the Rio Grande, a less environ-
mentally sensitive river than the Rio Hondo.) Elimination of the nitrogen—
removal requirement led to revisions of and lower costs for the conventional
alternatives, while most of the others were unchanged. Thus conventional
treatment became much more cost—effective compared to most other options.
2. Because nitrogen removal Is complex, the Initial analysis cast substantial
doubts as to whether or not many of the proposed options would work as
jntended and also indicated the potential for unreliable plant performance for
most alternatives. Elimination of a nitrogen—removal requirement Improved
reflability ratings and enhanced confidence that any new facilities built by
TWSD would work as intended.
Were nitrogen removal to’ be required at some time in the future, the
selected alternative would have to be retrofitted with an anaerobic reactor,
clarifier, methanol feed equipment, and heating for the aeration basin In
order to attain nitrificatlon. This would be expensive but capable of
implementation. The likelihood of nitrogen removal being required in the
future is considered low due to the degree to which the stream is phosphorus

During the planning process the State imposed the requirement that any
treatment plant be designed to treat average sewage flows, not peak flows.
Figure B—i Illustrates this concept. Peak flows (weekend) are stored in a
tank (equalization basin) and treated during off—peak periods (mid—week).
Plant capacity is set at the average flow for the entire week. There are two
major ‘cycles’ of activity which could be used for design of an equalization
basin. Figure B..1 reflects the weekly cycle, for which this approach is
cost—effective. The other cycle — winter/summer — would require a basin
sufficient to store most of the ski season flow for discharge In summer. This
would require several acres of storage, which is not available in the area
(see BLL, 1981).
Dollar costs are contained in the draft facilities plan and summarized
here in Tables B—i and B—2. In each table there are five dollar values given,
as follows.
A. Cost to build. This is the total price for design and construction of’
a facility. A portion of this amount could be eligible for EPA and EID
B. Annual payment. The total cost is restated in terms of the annual
payment. This Is just like stating the total cost of a house in terms of’ the
annual mortgage payment. The mortgage on a Twining plant is assumed to be
paid off over 20 years, at 7.25 percent interest (these numbers are consistent
with EPA regulations).
C. Annual cost of’ resources. This is the amount of money which Twining
would be expected to pay for energy and chemicals to run a treatment plant and
related facilities. This cost is not adjusted for inflation.
D. Annual cost of personnel. This is the expected amount of salaries and
benefits paid to the technicians who would run the plant. This cost Is not
adjusted for Inflation.
E. Total annual cost. This is the sum of items B, C and 0. It
represents the annual budget to pay the construction and operating costs of’ a
new facility, in 1980 (uninflated) dollars. Note that some of this budget
could be paid by grant funds.
The costs do not include any costs which Twining might have regarding the
rest of’ the fac1lffl s in the Sanitation District, such as the cost of putting
in new sewer lines or regulating septic tanks. The costs of water rights
(which would be required by some alternatives) are also not included.

Tab B—i presents the initial cost estimates developed during the
faciliti S planning process. For purposes of havinQ a common basis for
estimati g costs, the plant was assumed to have a design flow of 112,000 gpd
and to ave no equalization basin. For discharge to the Rio Hondo, both
nitrogen and phosphorus treatment were included.
As iscussed in the text, design concepts shifted during the planning
process; also, many alternatives were screened out. Table B-2 presents the
second set of cost estimates developed during the facilities planning
process. The costs reflect two design flows: 116,000 gpd (approximately the
District’s original goal); and 80,000 gpd (approximately existing flows). In
both cases, flow equalization is included and there is no requirement for
nitrogen removal. The engineering analysis of alternative 12 (rehabilitation)
is ongoing as additional data on existing plant performance are developed;
thus, the cost of this option may be adjusted in the final facilities plan
(Leyendecker, 1981).
This section explains ElD’s decision that a design flow of 95,000 gpd at a
central treatment plant in Twining is consistent with acceptab1e’
water-quality conditions (see also section B.2). Each of the factors which
influences the flow calculation are reviewed; despite the use of nunters,
these calculations are not precise. The calculations given below are based on
the phosphorus standard. EID also did a wasteload allocation calculation for
ammonia (EID, 1981d); from this it was determined that no treatment for
ammonia removal was likely to be necessary. However, EID has proposed an
effluent limitation of 30 mg/i total ammonia in order to assure that stream
standards are met.
The Wasteload Allocation Equation . EID’s equation for the wasteload
allocation assumes thafthe design flow of a plant is known; using the flow
and other information, EID then calculates the amount of phosphorus treatment
which is required. The calculations Øescribed here apply to phosphorus, the
critical pollutant in plant design and’ river protection. The equation can be
rewritten so that if the amount of treatment is known, the maximum design flow
can be determined. In the revised form, the equation is as follows:
Qe = Qa (Cs-Ca )
where: Qe = design discharge of treatment plant,
in cubic feet per secor4i (multiply
by 646,316 to get gallons per day)
Qa = flow of stream at point that
effluent discharge occurs, in cubic
feet per second

Cs = stream standard for a given
pollutant; the allowable maximum
concentration, in milligrams per
Ca = existing or projected concentration
of pollutant in stream above
treatment plant discharge, in
milligrams per liter
Ce = concentration of pollutant in
treatment plant effluent, in
milligrams per liter.
In this appendix, values are given for each of the above variables: Qa =
3.3 cfs; Cs = 0.1 mg/i; Ca = 0.06 mg/i; Ce = 1.0 mg/i. Based on these values
the equatl6h can be solveTas follows.
Qe .= 3.3 (0.1 — 0.06 ) = 0.13
1—0.1 0.9
= 0.1467 cfs
x 646,316 = 94,793 gallons per day, or about 95,000 gpd.
Allowing for infiltration, this indicates that the average sewage flow
from all hookups should not exceed about 95,000 gpd during the peak week of
the ski season. As discussed subsequently, this capacity can be exceeded by
the District in the future if certain conditions are me€ However, as a
maximum design flow, the value of 95,000 gpd is appropriate. As stated above,
ElD’s approach is to assume the flow as known, then calculate the necessary
phosphorus removal. A flow of 100,000 gpd would require phosphorus removal to
0.95 mg/i, which rounds to 1.0 mg/I. Therefore, EID feels that a 100,000 gpd
plant Is acceptable.
The next sections of this appendix discuss each of the parameters used in
the equation.
Qa. ElD has determined that the stream discharge used in the wasteload
allocation shall be the lowest seven—day flow expected in a ten—year period.
This is more conservative than the normal approach, which uses the two—year
seven—day low flow. The value of Qa at Twining was calculated by Louis
Reiland, a retired usos hydrologist, who Is New Mexico’s expert on this
subject. He used the long gaging station record at Va].dez to estimate
variations In flows In the Rio Honda, and used four specific measurements made
at Twining to correlate flows there with those at Valdez. His results were as

Month 10—Year 7—Day Low—Flow (cfs )
January 3.57
February 3.53
March 3.99
April 5.60
May 11.2
June 11.4
July 7.3
August 6.57
September 5.35
October 4.87
November 3.60
December 3.58
For water—quality purposes, the February flow is the lowest and therefore the
most critical.
These values of Qa could be in error on three counts. First, the flow
data for Valdez include conditions from the relatively wet 1930’s and 40’s as
well as the relatively dry 1960’s and 70’s; if only the later (more typical?)
years were used, the low-flow might be less. Second, the Valdez data are
extrapolated to Twining on the basis of only four measurements; at best the
extrapolation is Imprecise. Third, even If Qa = 3.53 cfs today, Increased
water use in Twining could reduce stream flows Tn the future.
Regarding whether or not the data are biased because both wet and dry
periods are Involved, EID has recalculated Qa using Reiland’s procedures but
only flow data since the early 1950’s drought. This has resulted in a
i’evlsion of Qa to 3 5 cfs. This low flow might be experienced in any of the
months from Novembel to March in the driest year of ten years.
Regarding Reiland’s procedures and the validity of his extrapolations,
these can be verified only if a gaging station is established In Twining and
measurements are made at both Twining and Valdez over a period of years and a
range of flows. A review of Relland’s report suggests that his correlation
conforms to acceptable practices. Moreover, since his report was completed,
USGS has revised its estimates of flow at Valdez on the four days that
measurements were made in Twining. If these revised flows were used,
Relland’S estimates of flow at Twining would be increased by as much as 10
percent. Thus, Qa = 3.7 c i ’s. This indicates that ElD’s current Intention to
use 3.3 c i’s Is very conservative. However, on April 1, 1981, EID measured a
flow of 3.8 cfs at HON4 (right above the treatment plant). This is an
unexpectedly low flow for the time of year, and demonstrates the value of
using conservative figures.
Finally, growth in water use in Twining may require the transfer of water
rights from the lower valley. The State Engineer will require a transfer
which is sufficient to offset any effects on flows at Arroyo Hondo. Thus for
the basin as a whole, there would be no change in river discharge. However,
there would be changes In the timing of water use and also in the point of

use. In particular, if Twining increases its water use considerably In
winter, then in the vicinity of the treatment plant discharge the stream flow
in the winter season could be reduced, even if there were no reduction In flow
at Arroyo Hondo for the year as a whole.
In sunmary, Qa is estimated to be 3.3 cfs, a value which appears to be
very conservativ ’or existing conditions. Quite possibly, installation of a
gaging station in Twining would lead to an eventual recalculation of this
number, and a higher value. On the other hand, any transfers of’ water rights
could lower the number. Ongoing surveillance of the situation is needed.
Cs. Cs is set by State regulation. For phosphorus, Cs = 0.1 mg/i.
QuesUonsThave been raised as to whether Twining should The allowed to
discharge pollutants such that Cs may be reached at Twining, or if instead,
some of the dilution capacity of the river should be reserved for the benefit
of downstream users. This subject Is discussed in Appendix C.7 .
Ca. At present the background level of phosphorus (natural sources,
fertilizer, septic tanks, fertilizers) is such that above the treatment plant
total phosphorus is typically less than 0.03 mg/i, or 30 percent of the stream
standard. EID assumed that with future development (for example, more septic
tanks) this value would double, and therefore used 0.06 mg/i in its Initial
wasteload allocation.
To test EID’s assumption, a series of calculations was made to ‘explain’
the existing concentration of phosphorus above the plant, and then these
calculations were then extended to future conditions for the ‘maximum’
projected development of’ the area. The calculations are summarized In
Appendix C.6.
Stated simply, it appears that natural runoff, on—site systems, fertilizer
use and runoff from the developed base area are more or less equally important
today and account for virtually all of the phosphorus in the river above the
plant. Large scale future development could lead to very large increases in
non—point phosphorus loadings, possibly to levels more than twice 0.06 mg/i.
On the other hand, were ef ’f’ectlve control techniques used (such as by control
and treatment of parking lot runoff, more advanced types of on—site systems)
then the non—point phosphorus load could decrease dramatically compared to
current condj.tJ.ons.
On balance, ElO’s prediction that background phosphorus will double is a
conservative conclusion, especially If the level of growth Is that associated
with a 95,000 gpd plant. Clearly, the loadings will need to be reviewed If
larger growth occurs, to determine whether or not water-quality problems are
likely to result. For now, Ca = 0.06 mg/i appears to be an appropriate
Ce. This is the most uncertain value In the calculations. Well—run
planE of the type proposed by alternatives 1, 2, and 12 reliably achieve 0.4
mg/i or less total phosphorus in the effluent. With ‘ordinary’ operation, the
processes will produce an effluent containing 0.5 mg/i phosphorus or less on

the average, and 0.9 mg/i or less at least 90 percent of the time. EID has
calculated a value of 1.0 mg/i, which assumes that the plant may not be
operated particularly well (as has been the case in the past). The level of
operation needed to accomplish such treatment can be achieved through
enforcement of the NPDES permit.
Ultimate capacity . The many uncertainties and basically conservative
nature of the wasteload allocations is an indication that the District could
someday expand beyond a 95,000 gpd flow. The ultimate flow depends on the
values used in the equation. As a matter of’ prudence the District would be
expected to collect evidence that the input number can be changed before
enlarging the facility and discharge. (Any other approval would run the risk
of violating the stream standards).
To illustrate the effect of just one of the factors, consider that Ce
could be 0.4 mg/i or less, on a reliable basis. If so, and if the othii
parameters in the equation are unchanged, then a capacity of over 200,000 gpd
might be possible.
Seasonal Variation . The proposed permit (Table 4—i) allows Ce to increase
in spring (Qa is rarge) and summer (when Qe is low). The purpos is to reduce
the costs resource use of wastewatefTreatment when such treatment Is not
needed to protect the river. If Qe in late summer were to increase well
beyond existing levels, the permit as stated would not ensure protection of
the Rio Honda and would require revision.
Alternatives to the conventional septic tank/drainfleld, and some of their
advantages and disadvantages, are listed in Table B—3. Alternatives either 1)
reduce the strength or amount of wastewater, e.g., commode alternatives, 2)
facilitate its disposal, e.g., drainfield alternatives, or 3) eliminate
on—site disposal altogether, e.g., total recyclers and holding tanks.
Reducing the pollutant strength of’ wastewater also facilitates disposal.
Wastewater that no longer contains wastes from toilets and garbage disposals
is termed greywater; the toilet and garbage disposal wastes are termed
blackwater. Where blackwaters have been removed, substantial reductions in
depth to ground water and drainf’ield size are allowed (see Table A—3). Thus
the use of composting toilets, for example, makes possible the installation of
(and reduces the cost of) the septic tank and drainfield on lots that have
inherent setback problems, such as depth to ground water or problems caused by
the arrangement of buildings or watercourses on a lot.

See paae Fl—4 for explanation of cost e tin tes.
nhjilber, name
Lhi t to
Itnoi ia I
R I anal,
i lnriujaJ
Tr,t i
to hui in
coct of
co t of
ar laijal
co t
NOW ph nt
$1, 101,1)00
$lOf .,55’i
c 1,5on
$1 is , ’
$ 8 4,?57
$ 82,226
$ 9 ,IIu
2 ,51I0
Sr’pt Ic tankr
$ 560,000
$ 3,902
$I?,4 11 1)
$11 I,00t
$76’ ,952
Storage, discharge
$ 529,72/
$ 511,988
$ 5,619
$ 81,161
Total detention
$ 9,1/46
Land application
$ 6,11110
Pipeline to Rio
Grar cJr
$ 7,681
$2 l4 ,4 ’/
Holding tanks
$ 341,720
$ 33,470
$//i, 55
$5 5,000
Honda rnoltrj ,al
p1 an It
$19 /i ,435
$ q,pp(I
lan re(Iinlnal
$7Jn, Q9
$71),(( Ir)
¶25 3,/ 9
Hl hRhiIItIOn
11 616,701)
$ 9,?fl3
$ 1I ,nO
$ 57, 5(t O
$ 137,68h
Total re ’v:ling
$2,1 ’ ’4 ,81l0
t511,# T ’
I 4.
Creywat.er ova 0 —
114,066,1 11)0
$390, 314
$51 ,l.U ))
i 1 c ,00IJ
‘ l’ifl’c , 376
/‘q ’iaruJtn,re
$ 11 /46

or comparison purposes, a plant of this size which accomplishes
increase costs to $202,076 per year.
Capacity: 116.000 GPO
Cost to
cost of
cost of
number, name

1. New plant
$ 887,140
$ 85,422
$ 18,720
$150,392 £
12. Rehabilitation
$ 608,870
$ 58,628
$ 13,900
2. Aquaculture
$ 97,216
$ 9,500
4. Compost tollets/
greywater treat.
13. Total recycling
$ 64,585
15A. Snowmaking
$ 413,633
$ 39,829
$ 2,600
$ 53,679
Capacity 80,000 GPO
number, nane
Cost to
cost of
cost of
1. Advanced plant
$ 612,127
$ 58,942
$ 12,420
12. Rehabilitation
$ 55,010
$ 9,591
2. Aquaculture
$ 696,638
$ 67,079
$ 6,555
4. Compost toilets
$ 78,450
13. Total recycling
$ 44,426
lSA. Snowmaking
$ 285,408
$ 27,482
$ 1,794
$ 40,526
nitrogen removal would

Alternatives Description Advantages/Disadvantages
Conasode Alternatives
Digesting Toilet
Micro—organisms digest wastes aerobically.
Hand pu’p uses effluent for flush. Small
outflow of clear—effluent.
ADV: Uses no water; produces little effluent,
DISADV: Requires small amount of electricity
(approx. $1/month) and weekly addition of
microorganism cultures ($1/month); odor potential
incinerator Toilet
Wastes are incinerated in timed cycle after
each use. Ash must be removed periodical-
ly. $50041000/unit. Used for vacation
ADV: Uses no water; produces no liquid waste.
Easily retrofit.
0ISAE : Uses energy (1/4 lb. gas or 0.08 kwh
per cycle). May require use of paper bowl
liner after each use.
Composting Toilet
Recycling Toilets
Garbage and human wastes are digested by
naturally occuring microorganimas, produc-
ing fertilizer. $l000..$2000/unit, or can
be home-made. Yearround use.
The flush liquid (oil or water) is recycled
for further flushing use after filtration,
separation, and/or aeration. Wastes are
stored in a holding tank.
Wastes collect in a pit which is covered
with soil when nearly full.
ADV: Uses no water; produces no liquid waste.
DISADV: Play require ventilating fan (110 AC,
20 to 46 W, 1-8 kWh/d; some models require
heating elements (e.g. 110 1 — 160W); odor
ADV: Uses little or no water.
DISRDV: Requires hand pump or power for
ADV: Low cost; uses no water,
DISADV: Must be moved periodically; potential
for odor, flies.
Treatment Alternatives
Aeration Tank
Resembles septic tanks but air is introduced ADV: May inVrove some aspects of effluent
mechanically to support aerobic decomposi— quality.
tion. Wastes go to a normal drainf’ield. DISADV: Greater capital, operation and main-
tenance costs than for septic tanks; no re-
ductions in volume or nutrient levels of
Recycle Systems
Holding Tank
All wastewater is treated to drinking
water standards by physical, biological
and chemical processes contained in a
large (septic tank—sized) tank.
All wasteweter is held in a large tank
for periodic removal by pumper truck.
ADV: No other treatment of wastewater is re-
quired; minimal water use.
DISADV: Energy and chemical costs and usage;
operation and maintenance requirements.
POV: No on-lot discharge thus
suitable to any lot.
DISPDV: Ultimate disposal and
treatment still required.
Absorption Field
Wide or deep
trenches, seepage
pits, alternating
Unusually wide or deep trenches or a pit
without trenches, or two fields used
alternately by season or year.
Wide trenches, seepage pits and alternating
fields are used to get below or overcome a slow
percolating (tight) soil. Deep trenches are
used to prevent sidewall seepage on slopes.
Sand mounds or sand
Sand and earth—filled beds lined at the
sides and bottoms; utilizes only evapora-
tion and transpiration by plants.
AOV : Eliminates discharges to ground water.
DISAOV: Wastes water; unsuitable for rugged,
cold or wet areas.
Sources: EPA, 1980; EPA, l9BOa.
Sand—filled trenches (sand filters or above Pretreats wastewater before discharge to
ground sand beds (filters and mounds). shallow soils, high water table or tight soils.

excess flow stored in
weekend excess
. S0 0
treated durinç week
Figure B-i.
Effect of Equalization Basin on Design Capacity.


Table of Contents Page
C.l Gaging Station Records C-. 2
C.2 Causes of Decline in Runoff C— 2
C.3 Stream Standards; 1974/75 Water-Quality Survey C— 4
C.4 Water—Quality Impacts C— 5
C.5 Non—Point Sources: General Analysis C— 6
C.6 Non—Point Source Phosphorus Budget C—li
C.7 Downstream Phosphorus Impacts c—n
C.8 Twining Water System; Per Capita Flow Estimates C—12
C-l Flow Data, Rio Hondo at Valdez C—l6
C-2 Stream Standards for the Rio Hondo c—r i
C—3 Probable Causes of Hondo Valley Water Problems C—18
C—4 Potential Water—Quality Impacts of Various Non—Point Sources C—19
C—5 Existing and Future Non—Point Sources of Phosphorus C—20
Above Twining Sewage Plant Discharge Point
C—6 Downstream Phosphorus Impacts C—21
C-7 Domestic Consumptive Water Use C-22
C— Benthic Pviacroinvertebrates in the Rio Hondo C—23

The U.S. Geological Survey has operated three gaging stations in the Rio
Hondo Drainage Basin, as follows.
Rio Honda near Valdez . Station 08—2675; drainage area 36.2 square miles;
operated 1934-present. Average flow = 25,650 acre—feet per year or 13.3
inches. Records poor/fair for winter. Table C—i summarizes the extensive
flow data available at this station.
Rio Honda at Valdez . Station 08—2680; drainage area 38 square miles;
operated 1916—1934.
Rio Hondo at Arroyo Honda . Station 08—2685; drainage area 65.6 square
miles; operated 1910-present. Average flow = 20,000 acre—feet per year or
4.03 inches; reflects considerable upstream diversions and use of water for
irriçption. A table similar to C—i is available for this station In the files
of Lee Wilson and Associates, P0 Box 931, Santa Fe NM.
Section 6.2.1 identifies a major environmental prcblem in the Rio Honda
watershed — a 25 to 40 percent reduction In runoff in the last 20—30 years.
This problem was extensively analyzed by Claassen and Anderson in Wilson
(1980, Chapter IV) and in the Forest Service EIS on Taos Ski Valley’s master
plan (USFS, l981a and l98lb). Except as noted, the discussion which follows
is taken directly from the work of’ Ciaassen and Anderson, as presented in
Wilson (1980, Chapter 1).
1. Chance . Runoff is naturally variable and some of the decline could be
the result of random chance. A statistical test (rank—sum test) compared
flows In the period 1943—1958 (Time I) to flows In the period 1959—1978 (TIme
II). The average annual runoff for Time I was 8,762 cfs, for Time II It was
6,162 cfs, a reduction of 30 percent. The test indicated that, at a
confidence level of 98 percent, the difference between the two periods is
“real”, that is, the difference is caused by factors other than random
fluctuations. Additional testing determined that spring runoff (March through
June) is significantly different between the two periods, whereas summer (July
through October) and winter (November through February) runoff Is not. A
second type of test (student—t test on least squares regression line)
confirmed that flows in Time II are significantly less than for Time I.
2. Climate . Several studies of long—term climate change in the western
u.s. suggest that the the early part of the twentieth century was character-
ized by a period of anomalously high runoff, whereas the drought which began
in the 1950’s may be as severe as any which has occurred in the last 250 or
more years. Wilson (1978) showed that there had been a decline in total
precipitation In Taos County from 1940 to the present, although there was a
reversal of the trend in the mid—1950’s. The decline in runoff parallels the

precipitation decline until the 1950’s; the improved supply of precipitation
since then has not been matched by an increase in stream flow. Thus total
precipitation alone cannot account for the change in runoff.
Analysis of other climatic factors suggests that there is no clear
explanation of the decline in flow. Factors such as a reduction in snowpack
moisture content, the timing of precipitation events, and temperature do
correlate to varying degrees with changes in runoff (as determined by
least—squares and correlation analysis). The data suggest that while total
precipitation may have increased significantly since 1960, increases in winter
precipitation have been rather small. This could partially explain why spring
runoff (snowmelt) has not recovered to pre—1960 levels. However, Wilson
(1980) concluded on balance that climate could explain some but by no means
all of the observed runoff trend.
3. Vegetation (Forest Management) . The size and density of forest within
a watershed has a significant impact on runoff, because of the large amounts
of water used by vegetation for evapotranspiration. Vegetative growth is
limited by fires, pests (e.g. budworm), and timber harvesting. In the Carson
National Forest, management practices directed toward protection of the trees
have restricted the limiting factors, thus promoting forest growth and leading
to a decrease in runoff (but probably improving water quality).
USFS (l98la and l981b) estimated this effect for the Rio Hondo watershed
where there is almost no cutting (except for the ski trails at Taos Ski
Valley) and there have been no major forest fires for 90 years or more.
Vegetative growth in the watershed, as measured by basal area, increased by 23
percent from 1963 to 1974. This would account for an increase of’ one to one
and one half inches of water lost to evapotranspiration each year, or
virtually all of the decrease in Rio Hondo runoff.
4. Water Use in Twining or Elsewhere . As discussed in section 6.2.4,
consumptive water use in TWSD and vicinity is small. Even with inflation of
the numbers given in the text, this use could account for no more than 1
percent of the 6000+ acre—feet reduction in runoff at Valdez. Effects at
Arroyo Hondo would be less, as most of the TWSD use has been offset by
retirement of lower valley water rights.
The conclusion that the change is not related to resort development is
supported by studies which show that paTt rns virtually identical to Figure
6—3 occur for nearly every stream in Taos County, and specifically: Rio
Lucero, Rio Pueblo, Rio Grande (near Lobatos, Colorado and at Embudo), Embudo
Creek, Cabresto Creek, Red River, Costilla, and Rio Ojo Caliente (Wilson,
1980). Data in Lansford (1979) indicate no major changes in irrigation
acreage which could account for the flow reduction.
The effect of ski developments on water yield would be positive because of
the cutting of water—consuming vegetation and increased snow accumulation in
the cut openings (USFS, l98la and 198lb); the effect is roughly estimated to
be a 1 percent increase in total runoff. Snowmaking activities could offset
this benefit (see 6.2.4).

5. Data Errors . USFS (l981a and 1981b) found no evidence to indicate
that the gaging station data are in error beyond the normal limits of plus or
minus 10 percent.
Prospects . Wilson (1980) summarizes the outlook for predicting future
changes in climate which could alter runoff patterns in Taos County. Despite
much research on the subject, no reliable predictions can yet be made.
However, several of the more likely scenarios Suggest that drought conditions
will persist for the next several decades.
Modification of watershed management to increase runoff is being
considered in the ongoing Carson National Forest management plan. Based on
studies elsewhere in the Southwest, the prospect is that relatively
inexpensive management practices might increase water yield by as much as 10
percent over several decades; larger increases could bring water quality or
other environmental problems (e.g., see Hibbert, 1977; Solomon and Schmidt,
Major water development projects — such as importation of San Juan—Chama
Project water or construction of new reservoirs — are unlikely to occur in the
county due to the low economic returns from the major water user, irrigated
Standards . Table C—2 explains the state stream standards which are
summarized in Table 4—1 of the text.
Survey . The bulk jf water quality data available for the Rio Hondo was
obtained by the LID and the U.S. Forest Service in 1974 and 1975. The data
are published in the EID report Water Quality of the Rio Hondo (1975). The
study was conducted to investigate; 1) how Rio Hondo water quality compares
with other mountain streams and whether more stringent stream standards would
be reasonable; 2) the impact of the Twining sewage treatment plant; 3) what
forecasts can be made as to the impact of increases in the sewered population
at Taos Ski Valley; and 4) how the impact of Twining discharge compares with
the impact of irrigation at Valdez and downstream.
The names and locations of the eleven san j1J.ng stations are as follows
(see also Figure 6-3):
HON1 Lake Fork Creek at Beaver Pond outlet
HON2 Rio Honda at the Main Lodge bridge
HON4 Rio Hondo 50 yards above the sewage treatment plant
Hct J6 Sewage treatment plant discharge !“
a. These data were çollected by the surveillance section of EID and cannot be
used to enforce the NPDES permit; see Appendix A for compliance data.

H ON8 Rio Hondo 300 yards below the sewage treatment plant
HcNlO Rio Honda 2.4 miles below the treatment plant (Italianos
HON12 Rio Honda 1.5 miles above Valdez (mouth of Canyon at USGS
HON14 Rio Honda at the Valdez bridge
HON16 Rio Honda 1 mile above Lady of’ Sorrows church
HON18 Rio Honda at Highway 3 bridge
HON2O Rio Honda at its confluence with the Rio Grande
Stations HON1 through HON12 represent the mountainous region of the Rio
Honda. HON6 is the treatment plant discharge; HON8, HON1O and HON12 are at
various distances downstream of’ the discharge. HON2 and HON4 were located
above the treatment plant to provide background data, but note that these two
stations are within the ski valley and may be affected by non—point sources
such as automotive exhaust, litter, sediment washed down from roads and cabin
construction, and various other products of human activity. HON1, which is on
Lake Fork Creek, was added later in the study to provide better background
data; however, there are cabins in the vicinity of this station, and so it
also may be subject to small amounts of non—point source pollution. In 1979,
station HON3 was established on the North Fork of the Rio Honda. The North
Fork passes through very little development, and so is probably repre-
sentative of true background levels. Stations HON14 through HON2O represent
the agricultural stretch of the Rio Honda, and are placed to show the impact
on irrigation and other cultural activities at Valdez and Arroyo Honda.
The results of the survey are sumarized in Table 6—2 and Figures 6—3 and
6—4; see also report entitled ‘Rio Honda Water Quality’, December 5, 1979,
which is on file at all the depositories listed in chapter 7.
As noted in the text, downstream residents in the Honda Valley are aware
of many possible adverse changes in the quality of river water. Table C—3
su marizes the problems noted by residents and their probable causes. Except
as noted in section 6.2.2, most of the changes could not be attributed to sew-
age flows (or other effects) from TWSD and Taos Ski Valley. The following
summary highlights the investigations conducted concerning problems which do
not appear to result from the resort complex.
1. A survey of medical and public health personnel in Taos indicated that
gastrointestinal disease is no higher in the Hondo Valley than elsewhere in
Taos County. Specific reported Instances of disease outbreaks were found to
result from local sanitation problems rather than water—supply contamination.
Nonetheless, as discussed In the text, the water in the river (and indeed all
natural water in all rivers and aquifers anywhere) is not suitable for drink-
ing without disinfection. If enough people drink enough river water without
first treating it, some small proportion would be expected to experience
health problems.

2. Discussions with New Mexico Department Of’ Fish and Came personnel
inoicate that complaints have been received about Sick and diseased fish in
the river, but that water pollution was not found to be a cause of the prob-.
lern. At least some of the complaints are associated with the stocking of the
river with hatchery trout, which many persons find less aesthetic than native
fish. However , the state agency is concerned about potential impacts of’
stream degradation which could adversely affect populations of’ cutthroat
trout, a sensitive species requiring pristine environmental conditions (and
currently reproducing above the main developed area in Twining).
3. Soil samples were taken from six fields in the Hondo Valley and were
analyzeo at New Mexico State University. All the samples showed normal soil
conditions. As was stated to one resident, “nothing in the [ water quality]
tests have shown anything to be in the water which is not ‘normal’ in irriga-
tion water in northern New Mexico . . . the problem you have reported [ poor
water penetration] is not related to the presence of sewage in the water. Or,
if there is a relationship, it is different than has been reported elsewhere.
For purposes of’ the EIS, we will proceed with the assurrption that the sewage
from Twining is not causing a clearly—defined problem with regard to the use—
fullness of irrigation water (although it does have effects such as odors).”
A retired SCS soils scientist (James Folks) visited each field and took the
samples; he observed no special or unusual conditions to support or explain
the observations made by the farmers (Folks, 1980).
4. Discussions with Extension Service personnel, local veterinarians, and
EILJ personnel all inaicate that, except as noted, none of the other problems
noted in Table C—3 were attributable to Twining’s discharge.
Table C—4 lists many categories of non—point sources which could have an
impact on the Honda Valley, identifies the types of pollutants associated with
each, and provides a general indication of the relative importance of each
source— pollutant combination. The table, and much of’ the text which follows,
draws on information in several references, most notably EPA (1975).
Information on timber harvest and grazing on National Forest Land was provided
by Carson National Forest (Nordwall, 1979).
Agriculture — runoff . The major pollutant from this source is sediment
resulting from erosion of cropland. Also, application of’ fertilizers (chemi-
cal or natural) in excess of crop needs can result in nutrient—rich runoff
from the cropland. Runoff from cropland is also a major source of pesticides
in surface waters. See also subsequent discussion of irrigation return
There are 2736 acres of irrigated land in the Rio Honda valley, extending
from the mouth of the canyon to the Rio Grande. The major crops raised are
alfalfa, pasture grasses, small grains, orchard trees and garden vegetables.
Use of pesticides and fertilizers in the area is reported to be minimal.

Agriculture — animal waste . Animal wastes contribute nutrients, oxygen—
demanding matter and pathogens (bacteria, viruses) to water. The problem is
greatly increased if the animals are confined in feedlots or corrals. Few
studies have addressed the effect of unconfined grazing on wildiand water
quality; the studies which have been done indicate that livestock, deer and
other large animals do affect water quality, especially bacterial levels, if
they have access to the stream or stream bank (Coltharp and Darling, 1975;
Stephenson and Street, 1978).
There is little information available to quantify the potential impacts
from this source. In the mountain area wildlife is abundant; however, live-
stock use is minimal (about 20 to 75 animals per month, during the summer, for
the entire upper watershed. Presumably the wildlife accounts for background
levels of bacteria (non—zero counts) above the ski valley.
Moderate numbers of cows, horses and other stock animals are kept by resi-
dents of the lower valley. Elevated levels of some nutrients and bacteria
(see Figure 6—4) are probably attributable to this source.
Agriculture — irrigation return flows . As much as 65 percent of applied
irrigation water is lost via evaporation. This results in a concentration of
dissolved solids in the remaining water, thus irrigation return flows tend to
increase the salinity of the receiving waters (Wilcox, 1962). Irrigation
return flows can also carry increased levels of pesticides, nutrients,
sediments, pathogens and other pollutants (see discussion of agricultural
The lower Hondo valley depends on irrigation as a water supply for crops.
Approximately 6836 acre—feet of Rio Hondo water are used for irrigation each
year, and 2734 acre—feet are returned. The major source of’ pollution expected
from the return water is an increase in dissolved solids; this is shown by
increases in conductivity of the water at downstream monitoring stations.
Automobiles . The major water pollutant from automobiles is lead. Lead
compounds are added to gasoline and thus are present in automobile exhaust.
These and other exhaust components settle on or near the road and are then
washed into the stream by rain and snowrnelt. In the same manner, oil, grease,
rust and rubber can enter and pollute the stream.
From the mouth of the, canyon (along Valdez) to the ski area, the road runs
right by the stream, so automobile pollutants have easy access to the Rio
Hondo. Annual average automobile traffic along the Taos Ski Valley road is on
the order of 600 vehicles per day. Calculations made as part of this EIS
(Wilson, 1981) indicate that. automobile exhaust could contribute 16,300 grams
of lead per year to the environment along the 8 mile stretch from the cattle
guard to the ski area. If all this lead entered the stream, it would add an
average of 0.00052 mg/i, whIEFi is well below the U.S. Public Health Drinking
total of 0.05 mg/i. Similar calculations can be done for other automobile
pollutants; the conclusion that the current level of traffic has a negligible
effect on the stream water quality would apply for any increases in traffic
which are less than 10—fold.
C —7

Construction . Construction activities (building roads, houses, parking
lots, etc.) generally disturb the soil on and around the construction site.
Thus, the major contaminant due to construction is sediment which washes from
the construction site into nearby waterways. Suspended sediment increases the
turbidity (decreases the clarity) of the water and generally increases salin-
ity. Sediment which settles out of the water can silt up the stream bottom,
causing changes in the biological community of the stream (see section 6.4).
In addition, sediment can carry with it other constituents which had previous-
ly been stabilized in the soil, e.g., nutrients, pathogens, and heavy metals.
A number of other water pollutants can be associated with construction,
for example, exhaust and oil from machinery (see automobiles), tar paper,
paint, etc.
Construction differs from the other types of non—point sources in that it
has a temporary, site—specific impact. Information on this source, as it per-
tains to possible wastewater management alternatives, is provided in section
6—1 (see especially Table 6—1).
Forests and Wildlife . Runoff from forest land carries nutrients and salts
leached from leaves and1 umic soil. Organic debris suspended in the water can
create an oxygen demand (affecting dissolved oxygen levels). Animal wastes
from wildlife can contribute nutrients and pathogens in much the same manner
as described above, under agriculture. Fisher and Ziebell (1980) discuss a
mountain watershed in eastern Arizona where a lake was overloaded with organic
matter of largely natural origin. Bacteria from campgrounds also affected
this lake.
The quantity of cor aminants in forest runoff is generally much lower than
in runoff from other types of land use. As part of the phosphorus budget
given in Table C-5, it was calculated that forest land contributes on the
order of 0.025 pounds of phosphorus per acre per year. This value is at the
lower end of published values for phosphorus export from forest lands. The
high quality of Rio Honda water at station HON12 (mouth of the canyon) indi-
cates that forest contributions remain minimal throughout the upper reach of
the stream.
Mining . The major pollutant from mining is “acid mine drainage”, a
lcw—pH, saline solution resulting from the oxidation of sulfide minerals
(especially iron sulfide and pyrite). Heavy metals are most soluble at low
pH, and so may be transported in the acid drainage. Mining may contribute
sediment from fine tailings or strip—mining operation. Salinity may also be a
The Rio Hondo Valley was• a site of intensive mining activity around the
turr of the century. Copper and gold mines were opened at Twining, Amizette,
and South Fork; tailings from the Frazer copper mine are visible above
Twining. The last actual mining activity occurred ii, 1956, when the Taos
Uranium and Exploration Company built a mill to leach ore at the Frazer mine;

the mill was operated only briefly (Schllling, 1960). More recently, about a
dozen exploratory cores have been drilled in the Gallina Creek area. (This
creek joins the Rio Honda below Valdez.) To date, no mining claims within the
Rio Honda watershed have been filed with the Bureau of Land Management.
On-site 5ysterr . The concept behind sewage disposal via septic tanks and
drainfields or cesspools is that the sewage will be purified by biological
degradation and physical/chemical interactions as it percolates through the
soil. However, even under ideal conditions some contaminants (e.g. nitrates
and chlorides) will reach the groundwater. If soil conditions are poor, very
little treatment of the sewage may occur. In areas with a high density of
on—site systems, the ability of the ground water to dilute and flush away con-
taminants may be overwhelmed. Such contaminated ground water may then flow
Into the stream.
Numbers and types of on—site systems in the Rio Honda Valley are estimated
as follows:
Area Number of Systems Major Types (Approximate )
Arroyo Hondo 135 60% cesspools; 40% septic tanks
Valdez 150 60% cesspools; 40% septic tanks
Amizette 22 10% privies; 90% septic tanks; 1 hold-
ing tank
Twining lodges 3 septic tanks with dry wells; (similar
to but somewhat better than cesspools)
Twining cabins 54 85% septic tanks; 15% holding tanks or
other systems
The extent of pollution from these sources is unknown. It is likely that
on account of steep slopes, high water table, and rapid groundwater movement,
much of the contamination from Twining on—site systems reaches the river (see
Table C—5). Concentrations of nutrients, salts and bacteria increase in the
Rio Hondo as it passes through the lower valley (Figure 6—4); on—site systems
probably account for a portion of this increase, but it is difficult to separ-
ate their contributions from that of livestock, irrigation return flows, etc.
Although there are some problems with cesspools and density of septic tanks in
portions of the lower valley, the soils are generally more favorable for
on—site systems than are soils in Twining. The scientific literature often
suggests that on—site systems should not have an impact on stream flows if
soil treatment works effectively. However, system failure (overflow) is
common where drainfields are not properly constructed and/or soil conditions
are unfavorable. Such impacts are not unusual. For example, one recent study
In Oregon showed that total coliform, fecal coliform and Salmonella all
increased 10 to 100 fold as a river flowed from a protected watershed through
a populated valley with homes on septic tanks (Seidler, 1979).

Road Salting . In a study of the impact of Santa Fe Ski Basin on the’
Tesuque watershed, Gosz (1977) concluded that the major impact on water qual-
ity came from road salting. Clearly, salts washed into a stream from the road
will raise the salinity of the stream. Sodium from road salt will displace
other cations (e.g. calcium) in the soil, causing breakdown of the soil struc-
ture. This results in increased sediment being washed into the stream.
Effects of road salting are seen in stressed roadside vegetation.
The Rio Hondo is de—iced with a mixture of scoria (red sand) and salt.
The Forest Service EIS concluded that road salting has created no water qual-
ity problems, based on conductivity measurements, and no evidence of soil or
vegetation stress (USFS, l98la and l981b). However, data from the ‘74-75
survey show conductivity in the Rio Hondo to be higher in winter than in
summer; this may well be due in part to the effects of road salting. It may
also be due to natural seasonal differences in mineraiization of rock, e.g.,
winter flow is primarily due to groundwater contributions, which may be more
saline than surface runoff. The treatment plant contribution to the
summer/winter salinity difference is on the order of 5 percent (Wilson, 1981).
Ski Area Runoff . Clearing for ski trails disturbs the soil; until vege—
tation is re—established, runoff from trails will carry increased loads of
sediment and nutrients. Fertilizer, which is applied to the trails to assist
vegetation, may contribute nitrogen and phosphorus to runoff. Other possible
pollutants associated with a ski area (beyond those of construction, auto-
mobiles, etc.) include oxygen—demanding material from paper litter, oil,
grease and heavy metals from ski lift and maintenance equipment.
Proposed development of Taos ski Valley will involve the clearing of
about 60 additional pr res for ski trails and lift corridors over the next ten
years. As part of t phosphorus budget (Table C—5) it was established that
fertilization may have contributed 50 to 100 kilograms of phosphorus to the
stream in 1980. Future impacts of fertilizer will depend on the amount used
and the method of application; EID personnel have expressed concern that use
of calcium hydroxide to increase fertilizer phosphorus availability may also
increase phosphorus runoff into the stream (Oppenheimer, 1981). This effect
will probably be very small, especially since application of lime reduces the
amount of phosphorus application needed.
Timber Harvest . Significant soil disturbance occurs during timber har-
vesting, resulting in increased sediment loadings from harvested areas. In
addition, the cleared area is more affected by rainfall and receives less ero-
sion—controlling forest debris. Temperatures of runoff and streams may in-
crease due to cleared areas receiving more sunlight.
Currently there are no contracts or permits for the sale of timber within
the Rio Hondo watershed. The only timber harvest that has occurred within the
past decade has been a small amount of clearing for ski trails at Taos Ski
Valley. As discussed in section 6.1, these areas and those cleared earlier
may still have a small effect on stream sediment loads.

As part of the wasteload allocation research (Appendix B.4), Lee Wilson
and Associates, Inc. prepared a detailed budget for point and non—point source
phosphorus discharged within TWSD, for existing and future conditions. This
study is summarized in Table C—5, which includes extensive footnotes to ex-
plain the methodology. It should be noted that existing conditions were
calculated using data for the period November 1979 through October 1980. The
major implications of the budget are discussed in Appendix B.4.
As noted in Appendix B.4, Twining’s wasteload allocation allows phos-
phorus pollution up to the stream standard. Below Twining additional inflows
to the river would dilute the phosphorus to below the standard, so that there
would be ‘room’ for additional discharges without violation of the standards.
It is possible to calculate the downstream impacts of TWSD’s discharge and
thus determine how much of the downstream waste assimilation capacity would be
used up by the District, and how much is left over for others.
Table C.6 contains these calculations, as prepared by Dave Tague of EID.
The table shows the concentration of phosphorus near Vaidez (HON12) and at
Arroyo Honda (HON18) which would be attributable to Twining. (“Attributable
to Twining” includes both sewage discharge and non-point source loading from
activities in the ski valley.) The table indicates that at Arroyo Honda, con-
centrations of phosphorus due to Twining would amount to a maximum of 40
percent of the standard; the average amount would be 24 percent. At Valdez
the maximum effect is 50 percent of the standard and the average is 31
Although Table C—6 would indicate that Twining’s phosphorus allocation
has a moderate impact on the lower Rio Honda, several other perspectives
should be brought to bear on the calculations.
First, the concentrations at HON8 were calculated assuming that Twining’s
effluent would be treated to 1 mg/i throughout the year, and that the plant
flows would be lower in the summer months. Since then, EID has decided to
recommend a permit which allows less phosphorus treatment in months with
higher stream flows and lower discharges (see Appendix B.4). Thus, Twining’s
contribution may be higher than shown on the table for the summer months; this
effect still assumes the area does not become a summer resort (in which case
even greater changes would occur). Were the concentration at HON8 to be 0.1
mg/i in every month of the year, the concentrations at Valdez and Arroyo Hondo
attributable to Twining would average about 0.05 mg/l and 0.03 mg/i, respect-
ively, or 50 percent and 30 percent of the stream standards.
Second, EID’s current policy is to allocate downstream phosphorus waste—
loads on a first-come, first-served basis; phosphorus treatment of new point
sources will not be required until all of the wasteload is allocated. The
result of this approach is that approval of a few small new point sources
C -.11

would fully use up the allocation, leaving no room for growth of the many
non—point sources in the downstream area. This Conclusion can be illustrated
by consideration of the proposed NPDES permit for the La Hacienda Condominiums
near Valdez, a new development seeking approval for an approximately 15,000
gpd package treatment plant. As proposed by EID, the permit would not require
phosphorus removal.
Assuming that La Hacienda effluent contains 10 mg/i of phosphorus (a typ-
ical value for such treatment plants), their discharge during low—flow condi-
tions (7.2 cfs) would increase stream phosphorus by nearly 0.03 mg/i. Under
these same low-flow conditions, Twining would be contributing 0.05 mg/i.
Water quality data suggest that existing non—point sources in this area might
add another 0.01 mg/i. Thus, the phosphorus concentration could amount to
0.09 mg/i, or 90 percent of the stream standard.
A comprehensive analysis of this subject would require consideration of
many additional factors. For example, phosphorus is readily adsorbed onto
soil particles; therefore, stream sediments act as a phosphorus sink and ef-
fectively reduce the amount that is available for algal growth. Also, EID has
assumed that there is no net removal of phosphorus by aquatic organisms
(algae). In reality, the blomass may provide a net uptake of phosphorus.
Alternately, the biomass could take up phosphorus during some periods
(blooms), release it at others (when the plants die), and complicate the rela-
tionships of Table C—6, whereby phosphorus shows up downstream immediately
after its discharge by Twining.
History, Water RightS . In 1967, a predecessor of TWSD, the Twining Water
and Sewer Users AssociaH n , received a Farmers Home Administration loan of
$40,000 to construct a community water system. A 100 foot deep domestic well
was drilled as a part of that project near the TSV, Inc. office but did not
produce water adequate to serve the area and was eventually abandoned. In-
stead, the Association decided to hook up to the existing Pattison Trust Water
System which had been developed to serve the 0. E. Pattison subdivision. Ar-
rangements were made with the Trust to lease the water lines, an agreement
which is still In effect. The Twining Water and Sanitation District was
formed in 1977 for the purpose of’ obtaining grant monies from the state and
EPA to upgrade the exist flg wastewater system constructed in 1967. Transfer
of ownership of portions of the water and sewer system owned by the
Association to the District has been completed.
Neither the Twining Water and Sewer Association nor the Twining Water and
Sanitation District own any water rights. Due to the lease agreement with the
Pattison Trust, the Association has use of the Pattison water right, which
amounts to a diversion right of 218.2 acre—feet per year and a consumptive
right of 10.91 acre—feet per year.
Water Facilities . The facilities owned by the Pattison Trust include
three sources for water — Upper Infiltration Gallery, Schwendi Infiltration

Gallery an Beaver Pond Infiltration Gallery — and the system up the valley
from the junction box located east of the base area. The TWSD system begins
at the junction box and serves most of the buildings below (BLL, 1980). The
system serves 14 commercial customers and 59 residential customers. The di-
verted water which enters buildings is either consumed or returned as sewage;
except for sewage disposed of on—site (mostly by cabins and the Kandahar), the
return flows are all treated at the TWSD sewage plant and discharged to the
Rio Hondo. However, by far the largest portion of the diversions is not used
for domestic purposes, but becomes what is known as by—pass flows. Because
many of’ the water pipes are not deeply buried and are therefore vulnerable to
freezing, many lodges, condominiums and private residences have a by—pass
pipe. This pipe runs outside each building, with water continuously flowing
through it. The continuous flow of water usually prevents pipes from
freezing. Most by—pass pipes discharge to the Rio Hondo; however, some pipes
discharge onto the ground, to a septic tank or to a back—up water storage
container, some users shut off their by—pass valves in the summer, but many
do not.
Improvements are planned to correct the current inadequacies of the
system. They include installation of meters, replacement of one infiltration
gallery, provision of storage facilities, and improvements to the distribution
system and development of water supply sources.
Sewage Flows . Meter records have been insufficient to permit accurate
measurement of diversions, by—pass flows and return flows. Thus, reliable
direct data on water use and sewage flows are not available. To provide at
least approximate estimates of water use and sewage flows within TWSD, Lee
Wilson and Associates (LWA) developed estimates of’ yearly and daily sewage
flows in the following manner.
An initial review of the literature indicated that at a number of other
ski areas, sewage flow is estimated at 15 gallons per capita day (gpcd) per
day skier or employee and 90 gpcd per overnight resident or guest (Wilson,
1981). Sewage flow is approximately 70 percent of diversion in most rural
Interviews were conducted by LWA with all condominiums, lodges, apart-
ments, cabins and Taos Ski Valley, Inc., to provide information about numbers
of yearlong, summer and winter residents, guests and day skiers using the
water system. This information was correlated with actual sewage flow data
obtained at several peak periods, including the Thanksgiving and Christmas
holidays of the ‘79—80 season. Despite the variability in data obtained at
different times, the most consistent interpretation of the results indicated
that: infiltration into the system averages about 22,000 gpd; the per capita
sewage discharge is 10 gpcd for day visitors and employees; and the per capita
sewage discharge is 50 gpcd for overnight occupants. The literature indicates
that the gpco numbers are the minimums which could be expected at a ski area.
The inconsistencies found during the course of measurements seemed to be
the result of problems with the metering equipment and/or significant variabi—

lity in infiltration rates. High infiltration rates create difficulties in
determining the proportion of actual sewage flows. However, on the basis of
the data collected, the 50:10 gpcd sewage flow ratio appears to be reasonably
Water Use . If one assumes that 70 percent of water diverted for domestic
use is return flow, and 30 percent is consumed; and if return flows for day
visitors average 10 gallons per day and return flows for overnight residents
average 50 gallons per day; then the average day Visitor requires a water di-
version of 14 gallons per day of which 4 gallons are used consumptively; and
the average overnight resident requires a water diversion of 71 gallons per
day, of which 21 gallons are used consumptively. As a further test of the
assumptions used for this study, daily water meter readings were taken at
several area residential facilities. These readings were then correlated with
the number derived by applying the estimated 14 and 71 gpd to populations at
each facility. There was less than a five percent variation between actual
readings and the derived figures, thus confirming the reasonableness of the
assumptions. When these numbers are used in conjunction with population data
(Table 6—7), it is possible to calculate both peak water demand and annual
water use (diversions, return flows, consumptive use). The latter — expressed
in acre—feet per year — is critical to discussions of water rights.
Table C-7 provides estimates of annual domestic cc nsumptive water use in
TWSD, for existing conditions and two of the population projections given in
Table 6-7 (those for alternatives B and E, respectively). For existing condi-
tions, diversion is estimated at 31.1 acre—feet per year (AFY); 30 percent or
9.3 AFY would be consumed and 70 percent or 21.8 AFY would be returned as
sewage. For the two projections, the same assumptions were made, with the
exception that water cc servation was taken into account, thus reducing
consumptive use of all ne development by one third.
These estimates do not include bypass flows, which must be considered in
evaluating the total water system. Attempts by WRD to obtain accurate inform-
ation on amounts of diversion for bypass flows thus far have been unsuccess-
ful. Most such diversion occurs around individual cabins. Measurements of
total diversion between June and November 1980, which WRD used to arrive at an
annual diversion of 141.1 AFY, would suggest that 105 AFY was used for the
bypass system, since 31.1 AFY was used for domestic diversion and about 5 AFY
is the estimated diversion for snowmaking. However, the results of the inter-
views of’ all water users in the ski valley indicated 532 AFY in bypass flow
based on pipe diameters and reported duration of use. It appears that it is
not possible to determine the exact amount of’ bypass flow within this approxi-
mate 105—500 AFY range based on the information gathered thus far. Clearly
accurate determination of return flows would require monitoring of all or most
of these bypass lines (plus measurements at the sewage treatment plant,
Kandahar etc.). The State Engineer probably will not require such
measurements to be made.
There are no accurate data regarding water use for snowmaking. On
2..ll...81, WRO ordered that diversion of water for snowmaking be stopped for the

reason that it does not fall within the category of’ sanitary/domestic use.
WRD determined that for the time period 12—3—80 to 2—10—81, six acres were
supplied with snow at a rate of 30 gpm over 315 hours. A total of 1,134,000
gallons of water was diverted for snowmaking, or 3.48 AF. Assuming that this
rate of use had extended for 100 days (the approximate number of days the
snowmaking equipment is used each season), about 5 AF would have been divert-
ed. WRD calculates that 30 percent of diversions for si’iowmaking are consumed;
this is based on the net evaporation of natural snow during the winter at
Twining’s elevation. The District disagrees on the basis that most of the
snow is used at the beginning of the season to create a base, is not exposed
during most of the year, and therefore only about 10 percent evaporates. This
disagreement is as yet unresolved.
In order to resume snowmaking in the future, TSV, Inc. may have to apply
for a permit from the State Engineer, unless it is able to reestablish use of’
the water—system permit. This has not been done as of July, 1981; it would
require transfer of already purchased irrigation rights on the Rio Hondo.

Figure 14.
Stream Name Rio Hondo near Valder. N. M . USGS Number 8267 5 Period of record August 1934 to present
Basin area 36.2 sq. ci .
Gage location
36° 32’3O b 1050 32’ 21W Other data none
Factors affecting record Footnote I
Comments minimum result of freezeup
Lowest mean discharge
of consecutive days
90—days: lowest low
median low -
highest low -
30-days: lowest low -
median low -
highest low -
1—day lowest low
median low
highest low
35 cIs
25,360 AF/year
701 AF/SM/year
for a given period
6.9 cfs
10.7 cfs
17.6 cia
6.7 cia
10.0 cfs
15.3 cf
1931—1973 as adjusted by USGS
Basis of adjustment: 8—2765,8—2763 —
Flow exceeded following percent of the
0.1 __cfs
1.0 237 cfs
5.0 cis
10.0 83 cfs
50.0 17.7 cia civ
9G.O 10.1 cfs
95.0 8.8 cia
99.0 6.8 cfs
99.9 4.9 cfs
Highest mean discharge for a given
period of consecutive daya
90—days: highest high 205.0 efa
median high 72.7 cfs
lowest high 23.6 cfs
30—days: highest high 291.0 cIa
median high 108.0 cfs
low .st high 32.1 cIa
7—days: highest high 361.0 efs
median high 121.0 cfs
lowest high 34.4 cfs
3—days: highest high 4nLp cIa
medLin high 125.0 cfs
1ow st high 35.0 cIa
1—day : highest high 416.0 cfs
median high 132.0 cfa
lowest high 36.0 cfs
I. Records poor/fair in winter.
Average flow: —
Avg. flow 1955—1974: 30.7 cia
or: 22,240 AP/year
or: 614 AF/SM/year
Maximum: 541 cIa on May 13, 1941
Minimum: 1 cfs on January 27, 1942
January: 614.45AF .__ .
February: AF
March: AF
April: ________________
t 1ay : 4 ’ 39650 AF
July: 2 ’ 37795 AF
August: ____________________
September: 1 ’ 27345 AF
October: 1 ’° 4210 AF
lowest low
median low
highest low
1owe t low
median low
highest low
November: 821.2OAF
4.0 cia
i .n cfa
n cfs
December: 68S.4SAF
1 flow runoff season —
3 flow atom season 31
I flow winter season 13
C-i 6

All standards are maximum allowed levels except dissolved oxygen (which is a minimum) and pH (which is an acceptable range).
lt = less than; gt = greater than; mg/l = one milligram per liter (. one part per million).
Parameter (symbol )
Un-ionized Anmnonia
Nitrogen (M4 3 -N)
fish culture; coidwater
At concentrations above 0.02 mg/l,
un—ionized anronia is toxic to fish,
particularly trout.
Dissolved Oxygen
Total Inorganic Nitrogen
6.0 mg/I
1.0 mg/I /
6.6 — 8.8
fish culture; coldwater
fish culture; coidwater
fishery; secondary contact
Reflects natural stream quality based on
sampling data. Excessive increases in
conductivity could result in changes In
the stream’s biology.
5 mg/i is the minimue level to protect
aquatic species, particularly trout.
6 mg/i leaves a margin of safety.
Inorganic nitrogen is primarily nitrate,
nitrite, and acanonia. These are the
biologically available forms of N.
1 mg/I or less total N avoids excessive
growth of nuisance algae.
Typical natural values, based on
sampling data. Values outside this
range could result In decreased
species diversity and could change
the stream chemistry.
Ten erature
Total Chlorine Residual
20° C
(68° F)
0.002 mg/i
fish culture; coldwater
fish culture; coldwater
Temperatures above 200 C place stress
on trout and other coidwater fish.
At levels above 0.002 mg/l chlorine
is toxic to aquatic organisms,
particularly trout.
Total Organic Carbon
7 mg/I
fish culture; coldwater
Protects against excessive organic
loadings which would lower dissolved
Total Phosphorus
0.1 mg/i as P
25 FlU £
fish culture; coldwater
fishery; secondary contact
To prevent excessive algal growth. This
level is the lowest which is reasonably
obtainable, given natural stream quality.
Turbidity generally indicates how
clear the water is. The standarJ
reflects stream conditions for NM
mountain streams.
Fecel Coliform Bacteria
(fecal coli.)
100 per 100 ,ml
(monthly logarithmic
mean); no more than
10% of samples may
exceed 200 coliforins
per 100 ml.
domestic water supply;
Irrigation; livestock water-
Ing; recreational value
Fecal coliform, not itself harmful, is an
indicator organism for more dangerous
bacteria and viral forms. At levels over
200/100 ml, there is a sharp increase in
the number of disease-producing organisms
found in the same sample.
0.02 mg/l !!
Water Use(s) Protected Basis
Conductivity 400 Micrombos
a. This is the revised standard adopted by the NMWQCC in April 1981; State Attorney General and EPA approval are pending.
Previous standard was 0.2 mg/I for total aimnonia nitrogen.
b. As per note a. Previous standa wis 0.8 mg/i for nitrate nitrogen.
c. FTU is an arbitrary unit used to measure turbidity levels.

Problem Probable Causes
Poor penetration of Injection Decrease In runoff has lowered
water, More frequent irrigation water table enough to increase the
needed, amount of water needed to Saturate
the soil. Excessive application
of marsjre can clog the soils.
Health problems (gastro— Poor hygiene and/or pollution of
intestinal disease) well water by cesspools. Medical
professionals indicate general
Improvement in cOewmJnity health in
recent decades.
Cattle deaths Copper deficiency (related to
copper In the soil).
Dying vegation along ditches Oyster scale (a common tree
disease). Experimental
herbicide application by
Extension Service. Fruit
trees don’t do well with high
water table.
Dead, sickly, and bad—tasting Difference between native and
fish, stocked fish. Unusual problems not
confirmed by New Mexico Fish and
Came Department.
Suds in the water Surfactants produced by natural
proteins. Possibly surfactants
from 055.
Slime on the stream bottom. Nutrient enrichment from a varelty
of sources including Twining
Ducks and geese seen less frequently Not confirmed by New Mexico Fish
along the river, arid Came Department. Rio Hondo has
never been a good habitat for water
c-i 8

Nt.r ber of asterisks reflect relative sicinificance of problem in Rio Rondo watershed; ‘ most sicmnificarit.
Non—point source Water Ojality Problem
Sediment Salinity pH Heavy Notals Notrients
Oxyoen—Pemandino Other (Pesticides, oil, etc.)
Hat eria 1
—runoff ** * ** 4*
—animal wastes
— lrrioation
return flows *4* 4 * * ft
Constr iEtion ft * *
(houses, roads)
Forests & wildlife ft * * 4
Mining * * *4* *44 * *
Septic tanks & cesspools * * *** *
Road salting *
Ski area runoff **
Timber harvest 4 4* *4

Assusptions used to develop figures are given in footnotes; more detailed calculations e.
are on file at Lee Wilson and Associates, Inc., Santa Fe, New Mexico.
teturaj. ’
Base Area /
2 0fl
Sewage !
Total, normal
Total, low fiows!l”
Normal Flows.J/
Low Flows !
0.016 0.067
0.008 0.134
i servedi ’
Allocatior& ’
a. Existing conditions were calculated using data for the period November 1979 through
October 1980. This is the period over which EID collected santles from the Rio
Honda on a rronthly basis, the resulting data being used as their basis for wasteload
Runoff data for Rio I- rndo at Valdez were obtained f row the USGS office in Santa Fe
(provisional data). Valdez flows were converted to Twinina values using Louis
Reiland’s curves.
b. Future conditions: to reflect worst—case, assnjaes extensive development of area
(3500+ pillows).
C. Low and High estimates: precise calculations of loading are not possible; therefore
a range of likely values Is given. It is not certain that this range encoepasses
actual loading rates.
d. Based on measured loading, North Fork of the Rio Hondo ( (-e)N3). Runoff at this point
was assumed to be in the same proportion to runoff at 1044 as the sizes of their
respective watersheds. The average measured phosphorus concentration at l0N3 for
1960 was 0.005 mo/I. This calculates out to a loading of 0.025 pounds per acre
year, a value In agreement with published estimates of phosphorus loading in runoff
f row forested watersheds.
Represents loading from ‘urban runoff’. Calculated by multiplying acres of
developed land times a factor which indicates phosphorus loading per acre. For an
EIS for Norman, 0k., LWA has done extensive work to develop loadings for various
parameters from different types of land use areas. For phosphorus from creaaercial
and residential lands, the loadings are 4.8 lbs/ac/yr and 3.8 lbs/ac/yr.
respectively. We considered the base area to have 55.6 acres of “commarcial” land
(loooes, parking lots, etc.). and 50 acres of “residential” land (cabins).
We assumed the resulting loadings to be at the upper end of the likely ranne, since
“urbanization” at Taos is less intensive than in Norman. Calculations based on USFS
measurements of sediment yield for the parking lot indicate that the loading may
actually be much less, so we reduced the above figure by an order of magnitude to
use as the “low estimate’.
For future conditions, the low estimate assumes that Twining implements a
well—functioning system to control runoff from the parking lot and other disturbed
areas. The high estimate reflects a worst—case situation in which our “existing”
high estimate is correct, a large amount of development occurs in the base area, and
no runoff controls are implemented.
f. Represents runoff of fertilizer used by TSV, Inc. 12.5 tons of 16.20.6 fertilizer
were applied to the trails in summer of 1979. he assumed that five to ten percent
of the phosphorus in this fertilizer reached the Rio Honda in water year 1980. This
assunption seems reasonable, given the steep slopes, rocky soils, and high water
table. For future conditions, the low estimate reflects better controls on
fertilizer application practices.
g. Represents phosphorus in ground water contributed by septic tanks and cesspoois.
The gross discharge of phosphorus is based on an actual count of facilities in the
District, estimated to discharge 3,028,000 gallons per year, and assuned
concentrations of P in effluent (10 mg/i); the range in net values reflects
assunptions as to how much treatment occurs as the wastewater seeps throuah the
soil. Normally, one would expect most of the phosphorus to be retained by the
soil. However, Twining is unusual in having rocky 50115 and a very high water
table. LID personnel have noted evidence of “breakthrough” of phosphorus from the
discharge of one lodge’s OSS. Therefore, our low estimate assumes that about half
the phosphorus is retained by the soil; the high estimate assumes that nearly all of
it passes through into the stream.
The future low estimate reflects elimination of many existing CSS due to new
hook—ups to the plant. The high estimate assumes development in Twining with new
cabins/lodges using OSS.
h. For normal flows, the total reflects the contribution from all sources. For low
flows, it is assumed that natural and trail contributions will become neoligible due
to lack of runoff.
i. Equals total wasteload oivided by annual flow.
For existing conditions, the 1980 water year flow: 15 cfs = 1.3 x 1010
liters/year. For future conditions, the average of 1960—1979 flows: 10.5 cfs = 9.4
x l0 liters/year.
k. Using a value for a hypothetical “low—flow” year, calculated by weighting EID’s
revised monthly low flows: 5 cfs = 4.5 x liters/year. For critical low—flow
conditions in winter, flow would be about 35% less. Wastelands would be expected to
be even smaller in proportion, since most loading occurs in association with runoff.
1. Averaoe of values measurea for 1980 water year.
Low EstimateE! High EstimateE ! Low EstimateE ’ High EstimateS !
70 70 70 70
Lnw Estimates.! Hiqt Estimatel!
0.015 0.036
Low Estimate!” Hind Estimate.t”
0.010 0.093
m. Value used by EIC in its wasteload allocation.

Table indicates amount (kilograms/month) pi-osphorus discharged from TWS [ ) and the relative effect (mi11igramsJlit er) of this discharge at
three locations (Twining, Valdez, Arroyo hondo) during low—flow conditions.
Change in P flux, kg/no Flow, cm P, mg/i Flow, cnin P, mg/i Flow, cm P, mg/i % P, Valdez % P, A. 1-londo
Jan 81.0 to 26.0 262 0.10 546 0.05 910 0.03 50 30
Feb 65.4 to 23.5 237 0.10 493 0.05 754 0.03 50 30
Mar 102 to 26.0 262 0.10 607 0.04 1290 0.02 40 20
Apr 121 to 25.2 335 0.08 690 0.04 352 0.04 40 40
May 73.7 to 25.3 686 0.04 1670 0.02 311 0.02 20 20
Jure 93.2 to 24.5 665 0.04 1610 0.02 382 0.02 20 20
July 16.8 to 10.5 468 0.02 1060 0.01 387 0.01 10 10
Aug 21.9 to 14.5 437 0.03 986 0.01 410 0.01 10 10
Sept 5.4 to 5.9 368 0.02 807 0.01 382 0.01 10 10
Oct 33.5 to 19.4 343 0.06 743 0.03 417 0.03 30 30
Nov 8.5 to 25.2 253 0.10 631 0.04 506 0.04 40 40
Dec 42.4 to 26.0 262 0.10 546 0.05 910 0.03 50 30
Totals 665 to 252 31 24
Based on calculations made by Dave Tague, EID, 1981.
Change in P flux: estimated kilograms/month of phosphorus discharged from TWSD (including non—point sources and treatment plant); first
ruriber is present value; second number assumes increased non—point sources (due to growth), major decrease in treatment plant discharge
(due to construction of new facilities) and net contribution which just meets stream standards In each month. Values assume major use
of area is in ski season; if TWSD becomes sumner resort, flux in sumer would increase substantially.
Flow: seven-year, 10—day low flow in cubic meters per month (CP-* 4).
F, mg/l: maximun concentration of phosphorus (milligrams per liter) due to effects of Twining.
% P: portion of stream standards (wasteload assimilation capacity) allocated to Twining. Remaining percent is available to downstream

Existing Lowest Projection / Moderate Projection ‘
Person Days FY Person Days AFY Person Days AFY
Day Only 220,437 2.84 358,071 4.62 403,886 5.21
Overnight 77,238 5.04 201,824 21.99 260,015 14.54
Summer: 21,964 1.44 36,533 2.39 44,167 2.89
Total 319,639 9.32 596,428 19.00 708,068 22.64
a. Normal increase based on non—peak skiing and addltonal cabins; capacity alternative B.
b. Increase treatment plant to 95,000 capacity; capacity alternative E.
C -22

PLECOPTERA (stoneflies) HEMIPTERA (true bugs) DIPTERA (true flies)
Perlodidae Corixidae Chironomldae Genus A and B
Megarcys signata
Isoperlinae OLEOPTERA (beetles) Chironomus sp. A and B
Hesperoperla pacifica Glyptotendines sp. A and B
Elmidae Genus A and B Calospectra sp. A, B, and C
Chloroperlidae A and B
Nemouridae WONP.TA (dragon—damsel flies) Procladius sp.
Zapada haysi
Prostoia besametsa Zygoptera Diamesinae
Diajnesa sp. A and B
Taenionerna sp. OLIGOCHAETA (worms) Orthocladinse
Pteronarcella badia
Brillia sp.
TRICHOPTERA (caddisflies) Eukiefferlella sp. A and B
PLATYHELMINTHES (roundworms) Corynoneura sp. A and 8
Rhyacophila acropedes Psectrocladius sp.
R. angelita Polycelis coronata Cricotopus sp. A and B
R. tucula
coioraaensis Simuliidae
R. unknown L. HYDRACHRINA (water mites)
flgophlebodes sp. Tipulidae A and B
Pseudosten hylax sp. Genus A and B Tipula sp.
rachycentrus sP. Hexatoma sp.
Micrasema sp. Dicrancta sp.
Arctopsyche grandis GASTROPODA (snails) Antocha sp.
G1ossoso na sp.
Dolophilodes SP. Blepharoceridae
NEMATOMORPHA (horsehair worms)
EPHEMEROPTERA (mayflies) Pericoma sp.
Protoplasa fltchii
Epeorus longirnanus Hemerodromia praecatorla
E. sp. Wiedemannie sp.
Stenacron sp.
Cinygmula sp.
Rithrogena robusta
b3et.is sp.
Ameletus sp.
Paraleptcphlebia sp.
Ephemerella inermis
E. doddsi
Source: Gerald Jacobi, New Mexico Environmental Improvement Division


Table of Contents Page
D.l Revenues and Employment Generated by Taos Ski Valley D— 2
D.2 Employment in TWSD D- 3
D.3 Tax Subsidy Issue D-. 4
D.4 Impact of Taos Ski Valley on Property Values o— 7
D.5 Buying Power D— 9
D—l Land Values D-ll

As described in section 6.6.2, the interaction between tourism and local
social and economic conditions is complex. For this EIS, research has
concentrated on major economic issues which were capable of some degree of
quantification within the research scope of the facilities planning process.
The Forest Service EIS (USFS, l98la and 1981b) developed an economic model
for quantifying economic benefits of the resort complex which accrue to the
region (see Table 6-9 for information on how economic benefits are
distributed). The following summarizes results of’ the model for the 1979—80
ski year.
1. Skier Visits 265,000
2. Revenue
Gas & Auto $1,362,000
Food & Drink 1,852,000
Retail Trade 5,976,000
Lodging 3,544,000
Other Services 8,055,000
Construction 2,171,000
All Other 3,837,000
Total Revenue $26,797,000
3. Person Years of Employment 1,300
4. Personal Income $11,532,000
a. Included in Total Revenue.

Information regarding resort employment and hiring practices was gained
largely through discussions with officials and lodge owners In the area.
Taos Ski Valley, Inc . To date, employment peaked in the 1979—80 season at
228 persons, but this figure will vary as conditions and markets change.
Summer jobs at the facility regularly drop to 50 people, as the only available
positions involve trail and lift maintenance and administrative duties.
Of the staff: 27 percent are Spanish surnamed
29 percent are female
66 percent live in Taos or the Rio Hondo valley yearround;
many have arrived in New Mexico in the last 10 years.
The positions on the TSV, Inc. staff include:
Administrative/office 10
Lift operators 20
Ticket sales and checking personnel 14
Ski patrol 19
Ski instructors 72
Lift and mountain maintenance 7
Some 86 additional persons are employed in capacities of equipment and
clothing sales and service, nursery attendants, and various other janitorial
and service positions. In recent years, the majority of new jobs have been
for instructors, ski patrol and lift operators. Although the ski area holds
no formal designation for supervisors, some 20 staff persons could be
classified as such.
Lodges and Condominiums . Interviews reveal that the total work force for
the lodges and condominiums, which Includes proprietors, maids, waiters,
cooks, etc., varies between 86 and 105 persons during the ski season. Summer
employment can be as low as 28 persons, since only the proprietors and “live—
in” maintenance workers remain on payroll.
Owners indicated that about one—half of their employees are native to the
area and of Spanish heritage. Figures for individual facilities ranged from
75 to 42 percent, and, thus, in some cases equal the county population
balance. Employed predominantly In service sector positions, the average
hourly wage for the Taoseno was $4.75 per hour inclusive of wages and tips.
This rate is relatively standard for service sector employees regardless of
background. Fringe benefits are few, which Is a characteristic of service
jobs nationwide. Persons who return for work the following year are usually
given a pay increase. Opportunities for advancement are limited, given the
fact that facility owners are also the supervisory and management personnel on
a small staff.

Local Employment . While the ski industry does provide jobs for long—time
local residents, much of the direct employment is created for persons who are
either not yearround residents of the area or persons who have moved to the
area in recent years. The native Spanish population Is somewhat at a
disadvantage when competing against newcomers for jobs in the ski valley.
Most of the winter transients come to ski. Employees with skiing skills are
an attraction to lodge and condominium owners since staff people who ski and
easily mingle with ski crowds are an advertisement for lodges and
condominiums. Few native job applicants are skiers while most newcomers
seeking jobs at the ski valley are. Work preferences of job applicants are
also significant. Lodge owners indicated that the majority of their Taoseno
job applicants preferred the standard 8 to 5 workday. In a resort area, this
choice limits available jobs and leaves an open market for job seekers who
want to locate in the area on a temporary or permanent basis and do not need
to have a regular work day.
During the summer months, few employees are retained. Although many are
absorbed into the summer employment market, quite a few of these individuals
either cannot or do not attempt to locate jobs and so are unemployed.
The issue has been raised as to whether federal, state and local tax
dollars subsidize the private enterprise which occurs in the Twining Water and
Sanitation District. A brief study of this issue reveals that skiers appear
to generate much more in tax revenues than they require from government
expenditures; if so, commercial activities In the District are not subsidized
by government funds whe viewed as a whole.
Methods and Data . As a general review of this issue, designed to
determine if a detailed analysis was required, Lee Wilson and Associates
estimated state and county gross receipts taxes collected from skiers in
1978—79 at Taos Ski Valley and compared this figure to major government
expenditures for the Twining Area. State, county and municipal expenditures
were examined. Federal expenditures have also been considered; however, since
the major identifiable revenue source in this case is the USFS permit fee
rather than gross receipts, the effect on federal expenditures is considered
seperately at the end of this discussion.
The standard assumption in a free enterprise society is that businesses
generate more tax revenues than they require. (If this were not true overall,
there would be no money left over for “non—profit” uses, such as salaries of
government employees.) Nonetheless, It is often found that the public sector
contributes quite a bit to the benefit of the private sector. To present a
worst-case analysis and help highlight this possibility, the analysis was
structured to try to overstate public expenditures associated with Twining and
to understate public revenues generated by skiing. The reasoning was that
such a bias was necessary to ensure that the analysis did account for any
small subsidies which might exist but not be readily identified among public

Gross Receipts Collected . The estimate of gross receipts tax generated by
TSV, Inc. was calculated by multiplying the number of’ annual skier days, by
the estimated number of dollars spent daily, by the tax on gross receipts:
230,000 TSV annual skier days 1978—1979
x $61.50 (the lowest estimate of’ average
daily skier expenditure)
= $14,145,000.00 annual skier expenditures
x . 04 tax on gross receipts
= $565,800.00 state collected revenue from skier expenditures
(including State collected
County gross receipts)
State Expenditures . The major expenditure of state tax funds which could
be identified as unique to the Twining area, i.e. not shared by other county
residents, is the construction and annual maintenance of’ that section of N.M.
State Highway 150 between Valdez (at the mouth of’ the canyon) and Taos Ski
Valley (New Mexico State Highway Dept., 1980).
$57,311.00 annual road construction costs amortized over 20 years
$10,000.00 annual maintenance, (includes paving, snow plowing and
fence repair)
$67,311.00 Estimated major state expenditures to support commercial
activities In the Twining Water and Sanitation District.
County Expenditures . Discussion with the county fiscal agent indicated
that there were no county expenditures that were either unique to the Twining
area nor any that were disproportional to expenditures in other communities.
Therefore, it was assumed that county expenditures for Twining were equal to
their share of the county population. In order to count tourists who, while
not county residents, do contribute to the area’s population, an annual
population equivalent was determined. To do this, total visitor days in
1978-1979 were divided by the number of’ days in a year and this figure added
to the permanent population of Twining. This resulted in the equivalent of
682 yearround people or about 3 percent of the county population. This
analysis will actually overstate the expenditures required for tourists since
they do not use many of the county’s services. Total county expenditures in
1978—1979 were $5,160,195. Much of this amount, however, was flow—through
funds, such as $2,194,600 for a federally-funded housing authority project.
Eliminating these funds, actual county expenditures were about $1,700,000.
Three percent of this figure is $51,000, roughly what can be attributed to

Municipal Expenditures . Obviously, no Town of’ Taos funds are actually
spent in Twining. In addifion , as in the county, the city clerk does not feel
the town incurs any expenditures readily attributable to the tourists as
opposed to the rest of the population. While most town expenditures will be
spent on community residents, It is assumed that anyone who uses a central,
commercial town such as Taos, places some burden on its budget. Since there
is no way to easily identify this share, for a rough estimate we have again
used the 3 percent figure. This is believed to overstate the actual
expenditures due to TSV visitors. Of the town’s 1978—1979 expendItures of
$704,290, therefore, $21,129 will be attributed to visitors and residents in
Federal Revenue and Expenditures . In order to include all government
levels which might be impacted, fedeiil revenues and expenditures attributable
to the Twining area have also been considered. The major revenue from the
Twining area is the permit fee paid by Taos Ski Valley, Inc. for use of’ 1074
acres of Forest Service land. This fee is about $ 7 0,000/year. The Forest
Service estimates that its costs directly attributable to the area are about
$15,000 per year.
Analysis . A comparison of revenues and expenditures shows that skiers at
Taos Ski Valley generated over $481,000 more in revenues than they required in
government expenditures. Considering local and state governments, the figures
are as follows:
Gross receipts collected from skiers
by the State $565,800.00
State expenditure 78-79 $ 67,311.00
County expenditure 78—79 51,000.00
Municipal expenditure 78—79 21,100.00
Total expenditure $139,411.00
Net Gain $565,800.00
— 139,411.00
Numbers for the Federal Government are as follows:
Revenue (Permit) $ 99,680 ,00
Fede I Expenditures - 15,000.00
Net Gain $ 84,680,DO

The calculations of revenue included only gross receipts tax collected by
the State and the USFS permit fee; the revenues do not include taxes on
property, gasoline, cigarettes, lodgers, liquor license fees or city sales
tax; revenues generated from indirect spending are also not included.
Summary . The question has been raised to what extent the presence of Taos
Ski Valley affects land values in the surrounding area.
A review of residential property values in Taos County and nearby
communities indicates that the Ski Valley’s Impact on land values is prominent
in the Twining—Arnizette area. There appears to be a lesser impact on land
values in the Valdez—Arroyo Seco vicinity. Beyond this area, land values do
not appear to be directly affected by the Ski Valley.
It is possible that current conditions will change with time, particularly
if pressure for development at the base of the mountain increases.
Methods and Data . To study the question of the Ski Valley’s impact, a
review f property values in the area was conducted. It was assumed that if
Taos Ski Valley was having an impact on land values, then land values in the
vicinity of Twining would be higher than for otherwise equivalent property
elsewhere. Accordingly, the price of one acre of undeveloped, non—irrigated,
resioential land was compared for three types of areas:
1) valley communities — numerous communities in Taos County, as well
as others In Rio Arriba, Mora, and Santa Fe Counties (refer to
Table 0—1);
2) non—ski mountain recreation areas — Valle Escondido, Chama, land on
State Highway 4 west of Los Alamos;
3) ski recreation areas — Twining, Red River, Angel Fire.
The residential property values in each of these areas were determined
based on research with local realtors, and are shown In Table 0—1. It is
recognized that many factors influence land values and that individual
properties will vary from the figures shown in the Table. These figures,
however, are representative.
Analysis . Referring to the table, several general relationships will be
Rural land In Isolated areas ranges from a couple of hundred dollars per
acre to a maximum of about $5,000 per acre; values are about $2,000 per acre
In rural agricultural communities.

As properties get closer to a larger town, or in areas of prime
q”lcultural lands within easy commute of a commercial center, values
increase. Communities in these areas have land values which range from
$5,000—6,000 per acre up to $lO—l5,000 per acre, with most communities in the
$7,000—8,000 per acre range. Communities characterized by more expensive land
were generally described by the realtors as having additional amenities
(example: the attractiveness of Talpa to artists). Each of the areas is
influenced by different factors which usually increase land values to the
$10,000 per acre range.
In the major, commercial communities land values are again higher, about
$l5—20,000 per acre.
Ski and non—ski mountain recreation areas exhibit a striking value
differentiation. In non—ski mountain recreation areas values are about
$5,000—6,000 per acre while in ski areas values are up to $50,000 per acre and
A comparison of values in the Taos—Twining area to the general values
described above identifies the impact Taos Ski Valley has had on land values
in the County.
Land in Arroyo Honda ranges from about $4,000-8,000 per acre, although
generally it is about $7,000—8,000 per acre. These values are in the same
price range as for most communities in the area. Since land is not more
expensive than in areas such as Ranchos de Taos, it appears that land prices
in Arroyo Honda have either not been affected to any significant degree by the
ski basin or at least h ve not been increased beyond values In other nearby
Further upstream, in / rrayo Seco and Valdez, land prices are higher,
$10,000 and $l0—15,000 per acre respectively. This is higher than in most
nearby communities, and is typical of communities (such as Talpa and
Ranchitos) which are felt to have additional amenities. In Valdez, the
additional value is reported to be largely due to the rural landscape and the
scarcity of land for sale. In Arroyo Seco the area is attractive, and Is
accessible to bath Taos and the ski valley. The effect of the ski basin on
land prices is reportedly more apparent in Arroyo Seco than in Valdez. Since
several factors are involved, the exact dollar impact on land values which is
attributable to the presence of the ski valley cannot be determined. However,
a comparison of values with those in other communities indicates that up to
$2,000 per acre could be due to the ski basin.
In the Twining-Amizette area prices are again consistent with values In
similar (ski) areas, On the other hand, as noted before, land values are much
higher than in mountain recreation areas without ski facilities, by about
$45,000 per acre. Therefore, most of the current value of properties in
Twining and Amizette can be attributed to the presence of Taos Ski Valley.
Finally, the question remains whether land prices throughout Taos County
sre higher due to the presence of the ski basin. From the above discussion It

appears that values in recreation areas are consistent with values In other
counties. With regard to valley community areas, however, a different pattern
emerges. Land values in the county are compardble to values for similar
properties in other developing areas. Taos and Espanola, both regional
commercial centers, have similar residential land values, $15—20,000 per
acre. Correspondingly in both areas outlying communities are generally in the
$7,000—8,000 per acre range. On the other hand, when compared to rural
agricultural areas where there is less pressure for development, prices are
noticeably higher. Land that would cost $5,000—lO,000 per acre near Taos
costs about $2,0004- per acre in La Madera and Ledoux. There are numerous
factors encouraging development in the Taos area, of which the ski basin is
one. It can be said that prices are higher in Taos due to the area’s
“amenities” which make it a desirable place to live for long—time residents as
well as new corners. How much of the difference in value is due to the ski
valley itself cannot be accurately determined.
One question of concern raised by the public was whether tourism, and TSV,
Inc. in particular, caused the cost—of—living to increase more than It
contributed to increased incomes. There is insufficient historical data for
Taos to Identify the changes in local spending patterns due to tourism and to
determine with any degree of accuracy the impact TSV, Inc. has had on this
change. However, some insights can be gained by a general review of the
Information which is available.
Studies . Generally, in communities heavily influenced by tourism,
property and housing values and grocery prices tend to be higher than in
communities which do not have noticeable tourism impacts (Flance, 1980).
Further, most jobs generated by tourism are service jobs and low wages are
Data . If the conclusion reached by Flance is valid, then land, housing
and grocery prices should be higher in Taos County than in nearby counties
which are much less affected by tourism (e.g. Mora, Rio Arriba and San Miguel
Inflation is evident in land prices (see section D.L .), especially when the
highest price land in Taos County is coripared with the most expensive land In
(for example) Mora County. However, increased land prices are also evident in
Espanola and elsewhere Indicating that tourism alone is not responsible for
the difference. Housing costs are strongly influenced by land costs. With
land discounted, the costs of new housing are similar for Taos, Rio Arriba and
Mora Counties, about $45,000 for a ‘standard’ 1000 sq. feet home (Best Way
Realty, 1980; Trujlllo, 1980). Used homes are also similar in Taos and Rio
Arriba County, but may be a few thousand dollars lower in Mora County.
Based on newspaper ads for Safeway and Furr’s stores, there Is no major
difference In grocery prices between the communities of Taos, Espanola and Las

The median spending Income in Taos is about the same as In Rio Arriba
($9,095 vs. $9,169 in 1979) and is higher than in Mora ($5,191).
The data indicate that the relationship observed by Fiance be true in
Taos County, but if so the effects are small. This does not mean that
Taosenos have adequate buying power or even that their economic status has
Improved in recent years; however, whatever major factors account for
inflation in Taos are typical of the region as a whole, including areas not
heavily influenced by tourism. It may even be argued that without the
infusion of tourist dollars, the impact of inflation would have been much

Prices are n .:ollars, :r one acre of LrneIel:oed, nor—irrigated, resi ent1a1
Price Range
Ski Area
Rea River
Angel Fire
l0,C0 /lot
2 8—48,000
28 —48,OCO
Other Recreation
Valle EsconaicO
St. Hwy. 4, west of
Los Alamos
Valley Comnunities
Taos County
Arroyo KcfldO
Arroyo Seco
Ranchos de Taos
Los Corcovas
Santa Cruz
La Madara
Tierra Ainarilla
Tres Piedras
Source: Lee Wilson & Associates, Inc., May 1990. Sased on conversations with
Ar e1 Fire Corporation, Best Way Realty (Santa Fe and Esoar ola), Lota Realty,
Ben Maestas, Mares Realty, Martinez Development Company, Polson—Mercer Realty,
Taos Mountain Realty, Territorial Realty Inc., Ron Sebesta Realty, and others.
D- 11


I ble of Contents Page
Letters from Taos Pueblo Council B - 2
Letter from U.S. Fish and Wildlife E- 6
Letter from U.S. Army Corps of Engineers E- 7
Letter from State Historic Preservation Officer E— 8

Mr. William P liux-.t
Pap. Two
Jua 24, 1974
June 24, 1974
Mr. William P. Hurst
Regional Forester
U. S. Forest Servic.
517 GoldAvenue, S. W.
Albuquerque, Now ISexico 87102
Dear Mr. Uunt*
The Draft Environmental Statomont oh the “aos Ski Vallcy. -
Expansion Pro?osal confirms that the projoot will have nothing
but adverse environmental •ffoct upon the Rio Ho. - ,clo ‘atorshcd
and adjacent areas. Destructive elements predicted by the
Stateu ,ent include erosion, loss of vegetative cover, water—,
air—, and noise-pollution, litter and disruption of water supply.
rn No realistic and offoctjvo safeguards are proposed to prevent— —-
destruotlon of th. Wheeler Peak and Blue Lake Wildetne g Z ,zeas
by the great number, of people, their vehicles, and thch facilities
to serve them that will. be introduced into this fragile area.
Nor is there any showing that sucn remedial, measures as are pro—
po ,ed to counter the ac5mitted damage would be economically
feasible for private developers or for the Forest Service.
Th. adverse impact upon the adjacent Wheeler Peak Wilderness
Area, the Blue Lake Area, and the regional water supply, incluc ]—
1mg the Rio Lucero, are paramount concerns of Taos Pueblo. None
of those major problems is given complete and accurate attention
by the Statement. The rapid deterioration of the Nildernes Arca
from overuse has been deecribed in tho Forest Service’s recently
published Draft Managemont Plan for that area. Yot the Statement
actually cites as a benefit the improved access that the project -
will afford to tho Si1dernesg,r—-Thou a , of peopt ‘a a1l be brought
to the area’. periphery for winter and au.’r er recreation. Short
of posting guards along the borders, patrols and full—time cleanup
crews within the area, nothing can stop the destruction of the
fragile watersheds within the Wildernes, from such an onslaught.
Tho Statement merely calls for reliance on a proposed Wilderness
porisit systom,failing entirely to consid.r the monumental problem
of enforcement.
The destruction could not and would not be confined to the
Wheeler Pe&k Area, but will spread inevitably into Taos Pueblo’s
own Sacred Blue Lake Area. The proposed now village would be
located at the back door of thc area,. It would menace the
peace and eocurityof our religious shrine . which our people
have for so long struggled to pr sorve at groat sacrifice. It
would open our lands to littoring, noise, traffic, trespassing,
forest fires, erosion and other damsge.
By facilitating tho use of public lands in connection with
the project am thus endangering both the Wheeler Peak and Blue
Lake Areas, tho Forest Service will corr.e into direct conflict
with two Ct3 of.Congro s, which_require., preservation of these
lands as wilderness forever.
Any disruption of the water oupply.inti e area threatens -
all of u.s who live thOre. According to tho Environmental Stato—
moat, lncreasod stream flow msy result from clearing of ski trail,,
parking lots, and bu.ildings. No explanation for this prediction
is given: the Statement merely suggests t1 st an existing gaging
at tion will deter,njna how sub tantja1 the incroaso ii aft r
the project is constructed.
A similar situ tio was experienced on the Rio Grande de1
Rancho, and the effect aa disactrou, for the farmers downstraaje
In that case clcaring in the watershed for lojging roads- and
skid trails caused rapid iral.ting of the snowpack in April and i -lay,
leaving little runoff for irrigation during the critical later
months of the growing season,, and ab a reducing replenishment of
the undorground basin.
The Rio ilondo project not only will -create a similar problem
as the result of substantial-clearings, but-mcy produce a-rise
in tomporature causod by habitations,. burning fireplaces, anticipated
traffic congestion, sewage treatment plants, and all the other
aocoutrementi of a permanent community. A great deal is said
in’ the Stat m nt about- pollutjon’from—thoae- sources- but nothing
about their offact on temperatures and melting of tho sno%.-pac , .
Cortainly, thore must be date available concerning these factors
from similar projects elsewhere. Furthermore, projections cos—
puted from known factors, sucn as amount of land to be cleared,
should b. made in order to estimate tho effect en runoff.

Nr. William D. Uuret
.Pag Throo
Juno 24, l 74
Docaujo of its failure to prc. .o inforeation and data on
any of thc3e mattera, the Draft Environrontal Stotoniont a. it
stands does not mcet the otandards for evaluating the iepaot of a
nnjor fcdcral action.. The actual iinp ct of the projoot upon the
W oe1er P ak and liie Lake Areai will cl.oarly be unnanagoeblej
tho e f fact upon the wator aupply, d aetrow. irrigator, and under—
çrc’und bn.i will very po3aibly be disaatrou.. taos Pueblo .. -
thcrcforo o7posco any actLon by tho Forcot Service, including the
grant of -a right-of-way over public land3 for a roal, that woul&
f cilitato co iitruction of the propoeo village or the -cxpanoion
of aos Si Valley facilities.
Yours- vozy- truly,
I ll
Bit______ ____
‘ereoino Jixon,- GOVEIWOR:

Ci:izan’s Advisory Cannittee
l\ ir ing Sanitatiou District
Public eting, ) rth 31, 1981
Mardi 26, 198].
Statenn it of Ccricerns of the Taos Pueblo Couicil and Cawns,jty
1 have here a letter that was written by forner Governor Teresino Juno
aid the Tribal Cc,u,cil of Taos Puablo in 1974 to the Regicmal Forester e cpress-
ing their cencerns abc*at the vqaisino of Kathlna Village at Taos i Valley.
Governor Jirno’ s and the Tribal Couicil’s icerns as pressed in this
letter reflect the pernanent valves of an ancient relatinoship the Pveblo
has with its sin-raz dings. The truthe e q ressed herein have not changed
since the begiming of tise.
rn In the past sixty five years, lace Puablo has gained a reputatim for
its tenacity in appealing to the Coveirnent for the rightful deed to its
sacred lands. In an iz recedented case, President Nixno signed a bill 4 ith
retutned those lands to their original st ds. Since that tIne • a n i
spirit of optiM has gr ei in the hearts of the people. Yoiz g people
eidifbit a ra wel of cultural pride as they take part in the intensive
The changes outlined in the letter of 1974 cnocerning the
Kadilna Village eiqaisicsi are not rilike those sutgested by today s Taos
d. Valley expaisicm plan. There is no reasno i iy the 1an w uld be any
enre acceptable to the Pueblo Indians today then it was in 1974.
We have a history of preserving aid defending w land. We love the
noe that stands there. That v rtajn is sacred. We love the pure water
Citizen’s Advisory Ccsxnittee
c i the I SV - A/EIS
(xsnfz)g fran the highest nouritath plateau through the Pueblo. Those waters
care fran the source, the head, and that source is not u2de by a uwai being -
it is node by Cod. He is the father. Re creates no and he creates you.
That’s the Indian way of life. That’s the Indian bible. The Indian feels
that uster is very sacred. Without clean water, we caru0t survive. bther
nat ne s these trees and these big nø.s,tains. God has strutgled to
give no this life. Water is i iiat rekes us the way we look, I at we are today.
%1 en Governor Jirczi and the Tribal Coizcil wrote of their caicein for
the “peace and sec n ity of am religious shrines”, there was no legal
recamse Lor the Pt. blo. In 1979, iever, a lrei was passed to guarantee
am sacred shrines. The Airerican Indian Ee1igi s Freedan Act guarantees
access, preservatino, and protectino for all. religious properties held by
Mative Anorican tribes.. To the Taos Pueblo people all water samces, the
springs, rivers, and lakes are sacred. Any drage or alteratias of these
sacred entities is a violatiai of the rican Indian Religious Pree Act.
Taos Pueblo is prepared to participate in the taft process of the
P iviruiiantal Protectino Agency •s Fnvirainsital Inpact Statenent. The
Pueblo •s caicerns incinde other factors than the protect.icn of religious
shrines. Taos Pueblo has a past history of trespass violatiais no border
laWs adjacent to Taos Ski Valley. There a amrently a tu±er of laid
disputes between the neighbors of Pueblo lands. Increased cpensioo of
Taos Sd Valley would urther ag avate this problen. The past ten years has
seen a draretic increase In s’. as well as winter use in the Taos Ski

t s Advisory Cannittee 3
I., the1 V-EPAJElS
eady have a full bi dan patrolling the
1 rders. There i ist not be at lnc se in trespass VOI C. or desecra-
Of o sed la ds
The following factors nust be ccnsidered by the Fnvimiiantal lupact
1. Increased violaticns of Sacred Laid or oirt ilsait of access to
those lands.
2. Water quantity atd quality alteraticx%s such as to the Rio I jcero.
3. Develqxnent of nore residantial growth bordering I ndian lands aid
the possibility of f zther laid disputes being prodeced by
caitirsied expansic i.
The Taos Puablo uaintained the positism stated in iti letter of 1974 to
Forest Service. )breover,. the quaries that arise fras that letter and
this staterant sheuld be aiswered by the EPA Ewim t tal Isçact Stateiait.
me Puth]o will assist EPA in any wy possibla to provide up-to-date data
1 di% to a fair and rrect asses t of the situatim.
Sincerely y s,
‘ T) ?
f J
Tribal C z 1 t&y

h1 _ i 1(, . w B71
October 12, 1 9
Mr. Clinton B. Spotts
Regional EIS Coordinator
J.S. Environmental Protection Agency
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
1Z ’97G ’
\Z._ a_,. ;i

This is in reply to your September 17, 1979 letter which requested
information about species which are listed or proposed to be listed as
threatened or endangered as provided by the Endangered Species Act.
Your area of interest is the Twining Water and Sanitation District,
Taos County, New Mexico.
As provided by Section 7(c) of the Endangered Species Act Amendments of
1978, the Fish and Wildlife Service is required to furnish a list of
those species, both proposed and listed_that may be or are present in
the area involving Federal construction activities.
L’pon receipt of the Fish and Wildlife Service’s species iist, the
Federal agency authorizing, funding, or carrying Out the construction
action is required to conduct a biological assessment for the purpose of
identifying listed species which are likely to be affected by such
action. Proposed species are included on the list even though they do
not have legal protection under the Act. Their inclusion recognizes
that they may be listed anytime and have the portent to cause delays or
modifications to the proposed action. In light of this, we recoend
that those species be included in the biological assessment.
The biological assessment shall be completed within 180 days after
receipt of the species list, unless it is motually agreed to extend this
period. The biological assessment should include: 1) the results of a
comprehensive survey; 2) results of any studies undertaken to determine
the nature and extent of any impacts on identified species; 3) considera-
tion of the cumolative effects upon the species or its critical habitat;
4) study methode used; 5) difficulties encountered in obtaining data and
completing the proposed study; 6) conclusions including recomaend.ations
as to further studies, and 7) any other relevant information.
S aw. agrv, and You Se-vs Aawr ca/
For purposes of providing interim guidance, the Fish and Wildlife
Service considers construction projects to be any action conducted or
contracted by the Federal agency designed primarily to result in the
building or erection of man—made structures, such as dam.s, buildings,
roads, pipelines, and the like. This includes consideration of major
Federal actions such as permits, grants, licenses, or other forms of
Federal authorization or approval which may result in construction and
which significantly affect the quality of the hunan environment. In
addition, other actions that have the potential of becoming or are
controversial, may be considered as construction.
If the biological assessment reveals that the proposed project nay
affect listed species, the formal consultation process shall be ini-
tiated by writing to the Regional Director, Region 2, U.S. Fish and
Wildlife Service, P. 0. Box 1306, Albuquerque, New Mexico 37103. If no
affect is evident, there is no need for further consultation. We would,
however, appreciate the opportunity to review your biological assessment.
The attached sheet provides information on species which may occur in
the proposed project area. If we may be of further assistance, do not
hesitate to call upon us (505—766—3972; P ’ES 474—3972).
Sincerely yours,
Regional Director
Twining Wastewater Treatment Plant
Taos County, New Mexico
Bald eagle ( Raliaeetus leucocephalus )
May be found as a winter resident and or nigrant along the Rio
Grande and tributaries. Also recorded in the Sangre is Cristo
Mountain area in s er. This water oriented eagle feeds largely
on fish though also takes waterbirds and menmals.
Peregrine falcon (Falco peregrinus )
This species, a su er resident of the area, typically hunts
watervavs for food. Nest sites are associated with cliffs and
bluffs of gentle terrain.
I , ,

C. 1 P 0 BOX 1550
S AC0—OR 13 September 1979
Ms. Adlene Harrison
U.S. Environmental Protection Agency
1201 Elm Street
Dallas. TX 75270
Dear Ms. Harrison:
Reference is made to your notice of intent regarding Section 201 Grant
C—35—1064—01 for the Twining Water and Sanitation District, Twining,
New Mexico.
Review of your notice indicated a Section 404 Permit will be required
if dredged or fill material is deposited into the Rio Hondo below the
ordinary highvater mark or into an adjacent wetland.
The Environmental Impact Statement for this project should include a
discussion of the need for a Section 404 Permit and for compliance
with Section 404(b) guidelines.
Should you have any questions regarding these matters, please do not
hesitate to write or call Mr. Wayne Lea or Mr. Andrew Rosenau at (505)
766—2776 or FTS 474—2776.
Chief ,‘Construction—
Operations Division - --
\ ;.•• ?

ST-tIE (fl ‘\ MEXICO
July 22, 1981
Ft NEW MEXICO ‘5O3 o ’Rwr
535i2 -?C3
Dear Mr. Anderson:
This letter is in response to your request for information on the
archaeological, historical and cultural sites within the Twining
Wastewater Facility Improvement Project area. You state in your
letter that the preferred alternate will involve the replacement
of the existing treatment plant, the replacement of existing sewer
lines, with Only one new hook—up planned.
No properties entered in or eligible for nomination to the National
Register of Historic Places are presently known to exist in the
inssedi.ate vicinity of the project location. In addition, since
construction of the new treatment facility is to be confined to
the existing treatment plant site, it is highly unlikely that any
archaeological resources will occur at the project location.
Provided that construction activities are restricted to the existing
treatment facility site and that rk on sewer lines will also involve
replacement, with the exception of the single new hook—up, it is
our opinion that this undertaking will have no effect on any
significant cultural resources.
You should be advised that alterations to plans for the described
project will require further review by this office. We also wish
to inform you that buried archeological manifestations may be
uncovered by construction activities. If such manifestations are
Uncovered, artifacts and features should be protected in place and
this office notified i ediately of the find.
MrS tevan Anderson
July ‘, 1981
Page 2.
Shou1- .vou have any questions regarding our comments, do not hesitate
to contact this office.
Thomas W. Merlan
State Historic Preservation Officer
Historic Preservation Bureau
Mr. Stevan #nderson
Lee Wilson and Associates
P. 0. Box 931
Santa Fe, New Mexico 87501


Air quality .3—6, 6—34
Algae . . . . . . . . . . . . . . . . . . 6—13, 6—20 , 6—29, 6—38, 6—39
Alternatives 1—1, 5—1, 5—3, 8—2, 8—9
No—action alternative 1—1, 5—1, 6—5, 6—26, 6-35, 6—41, 6—46, 6—75, 6—93
No—funding alternative 57
No—growth alternatives (see: Capacity alternatives)
Treatment alternatives 5—2, 5—3, 5-6, 5-8, 6-5, 6—26, 6—35, 6—41, 6—46, 6-75
6—93, B—2, B—9, 8—10
Capacity alternatives ...1—4, 1—5, 5—17 to 5-29, 6—7, 6—30, 6—35, 6—41, 6-47
6—76, 6—94
EPA alternatives and responsibilities 1—6, 3—1, 5—42, 5—47, 6—8, 6—33
6—37, 6—42, 6—48, 6—92, 6—95
Other agency alternatives and involvement 1—6, 3—4, 3—7, 5—44, 5—48
6—8, 6—33, 6—37, 6—42, 6—48, 6—92, 6—95
Aquaculture 1—4, 5—3, 5—8, 5—10
Agricultural lands, economy . 3—5, 6—46, 6—48, 6—49, 6—54, 6—60
Archaeologjc resources 3—5, 6—43, 6—47
Biology 6-37, C—6, C—23
Citizens Advisory Committee 3-4, 7-1, 7—7
Clean Water Act 3—1, 3—3, 5—43
Climate 6—3, 6—8
Chlorine 5—34, 6—42, 6—94
Collection system 533
tuction impacts 5—7, 5—9, 5—15, 6—6, 6—33, C—8
Cost_effectiveness analysis 4—6, 5—16
Cultural resources 6—59, 6-85
Development plans 6—60, 6—67
Disinfection 5—34, 6—29, 6—37, 6—42, 6—94
Earth resources ..6-2
Economic issues 6-81
•1 0—2, 0—9
Effluent discharge, impacts, limitations 4—1, 4—2, 6—14, A—4, A—8, A—12
EII alternatives (see Alternatives: other agency alternatives and involvement)
Employment ..... 6—51, 6—53, 6—54, 6—55, 6—57, 6—84, D—3
Endangered and threatened Species 3-6, 6—40, 6—42
Energy use and consumption 5—35, 6—93
Enforcement 5—20
EPA alternatives (see Alternatives: EPA alternatives and responsibilities)
Equalization basins 5—5, B—3, B .-12
Erosion 6—5, 6—7
Facilities plan . . . . . . . . . . . • • . . . • • 3—1 , B—3
Flow reduction . . . . . . . . . . . . . . • • . . . . . 5—35, 6—9
Funding alternatives (see Alternatives: EPA alternatives and responsibilities)
Geology 6—3

Historic and archaeologlc resources . —5, 6—43
Infrastructure • 6-58,6—88
Land use and values 5—7. 5—9, 6-50, 6—51, 6—61, 0—7, D—ll
National Environmental Policy Act 3—3
Nitrogen 6—11, 6—12, 6—13, B—2, c—b
Noise 6—34
Non—point source pollution 4—4, 5—36, 6-20, 6-30, 6—33
C—5, C—6, C-il, C-20, C-21
On—site systems 5—9, 5—33, 6—42, 6—77, A—4, A—9, A—li, 8—8
B—li, C—9
Ozone 5—35, 6-37, 6—42, 6—94
Phosphorus .4-4, 5_9, 6—12, 6—13, 6-21, 6—27, 6—29, 6—30, B—4, C-li, C-20, C—2l
Physical environment 5—20, 6—61
Pollution, Water 4-i
Population 6—49, 6—67, 6-78, 6—81
Preparers, list of 8—1
Public participation process 3—4, 5-12, 5—45, 6-8, 7—1
Purpose and need being addressed by EIS 4-1, 4—6
Quality assurance 5—37
Rate design 5-36, 6—89
Recycling of wastewater 5-3b, 5-10, 6—28
Regulations and permits, wastewater management A—2, A—6, A—is
Rehabilitation of existing plant (see Alternatives: treatment alternatives)
Road salting C-b
Runoff 6—7, 6—8, 6—9, 6—10, 6—21, C—2, C—6, C—iO
Sacred lands 6—45
Sensitive resources 6—43, 6—44
Ski Solar Homes 5—40
Sludge management 5—34
Snowmaking 5—3b, 5—10, 5—12, 5—15, 6-9, 6—23, 6—24, 6-25, 6—26, 6—27
6-95, C—l4
Socio-economic conditions (see also Economic issues) 6—49
Soils 6—3, 6—4, C—6
Stream standards and violations 4—i, 4—2, 6—11, 6—14, 6—17, A—13, B—2
•. .. C—4, C—17
Taos Indian Pueblo . . . . . . . . . . . . .3—7, 6—45, 6—47
Terrain .. . . . . .. ........ ..6—2
Tourism . 6—49, 6—56, 6—64, 6—86
Traffic 6—30, 6—36, 6—58, 6—85
‘r5idity .. 6—5, 6—24
V getation 6—37, 6—41, 6—42, C—3
Visual resources . 6—45,6—47
Wasteioad allocation 5—22, 5—23, 6—12, 6—29, 6—30, B—4
Water conservation 5—35, 6-30, 6-75, 6—90
Water quality 4-5, 5—5, 5—6, 5—13, 6—11, 6—14, 6—15, 6—18, 6—22, 6—23
6—28, 6-30, 6-85, C-4, C—5
Water quantity/supply .. .4—5, 5—6, 5—9, 5—13, 6—9, 6-85, 6—21, 6-22, 6-27, 6—30
6—87, 6—90
Water rights 6—22, 6—24, 6—26, C—12
W t€r use 6—23, C—3, C—14, C—22
life 3—5, 6—37, C—8