Taos, New Mexico
Rachel Conn is the deputy director for Amigos Bravos, a conservation organization dedicated to protecting and restoring the waters of New Mexico. Rachel works to provide hands-on support to New Mexico communities and watershed groups, review and comment on state and federal water quality policy, and conduct Clean Water Act trainings. Rachel leads ongoing campaigns to hold Los Alamos National Lab accountable for pollution, protect New Mexico’s waters from degradation through Outstanding Waters designations, restore and protect Wetland Jewels, protect New Mexico’s waters from degradation caused by mining, and advocate for strong water quality standards throughout the state. Prior to joining Amigos Bravos in 2001, Rachel worked in San Luis Colorado on mining and water contamination issues and in Boston for the Massachusetts Department of Environmental Protection.
Amigos Bravos is a statewide water conservation organization guided by social justice principles and dedicated to preserving and restoring the ecological and cultural integrity of New Mexico’s water and the communities that depend on it. While rooted in science and the law, their work is inspired by the values and traditional knowledge of New Mexico’s diverse Hispanic and Native American land-based populations, with whom they collaborate.
You recently wrapped up the 3rd edition of the Clean Water Act Owner’s Manual. Why is this resource so important for folks working in water advocacy?
The Clean Water Act Owner’s Manual, I think, is a really great tool for people working in clean water at all different levels. It’s a helpful tool for people who are just getting their feet wet and beginning to understand the broader components of the Clean Water Act and how it can work for all people working to protect their watersheds. It is also great for people who are already immersed in this work professionally or on a more regular basis.
The Manual references specific sections of the Act that are critically important to my own work. It is great to be able to flip through the manual and find specific regulations and associated regulations to cite when I’m making a case for greater protections in my own watershed.
You have been involved in a few iterations of the Manual. How was development of the 3rd edition or the components different from previous editions?
This new edition incorporates a number of new, broad themes, such as climate change and environmental justice, and includes a more intentional focus on storytelling. The stories and case studies provide a focal point that allows advocates to conceptualize different components of the Clean Water Act.
As far as the development of the updated Manual, I really enjoyed having the advisory group come together as a group as opposed to everyone working on their pieces individually. I got to understand other people’s experiences and perspectives around the Act instead of everyone working on their sections in a vacuum. This new process created an atmosphere of collaboration and excitement around the sharing of ideas.
What will be the most useful section of the new Manual for you and your work?
I have always found that, for folks who are new to the Clean Water Act, learning about the foundations is really important. Amigos Bravos works to advocate for strong water quality standards in New Mexico and runs a water quality monitoring program, so the Water Quality Standards section has been the most useful for me. I have historically relied on that information in the first, second, and now third editions for both my own understanding and figuring out how to teach other people about water quality standards. It is really great to incorporate some of these bigger themes like climate change and environmental justice into this edition of the Manual.
Amigos Bravos engages heavily in the triennial review of water quality standards. Our organization is typically the only NGO or conservation voice in that process in the state of New Mexico. That has changed a bit in recent years with some of our work to bring in new partner voices, but a big part of our work is advocating for strong water quality standards for our rivers. I use the Clean Water Act Owner’s Manual for much of this work. I didn’t know anything about the Clean Water Act before getting involved with River Network back in 2002. The first edition of the manual was my initiation into clean water advocacy!
It sounds like this publication really empowered you to advocate for clean water.
The Clean Water Act itself is very empowering. It is drafted with tools for citizen engagement like the citizen suit provision and the triennial review of water quality standards. There are opportunities for public engagement in establishing the goals for our waterways, and permitting processes set up under the Clean Water Act also have strong public engagement opportunities and appeal processes. So, the Act itself is a good tool for empowering advocacy, and the Manual does an amazing job of communicating those steps to make the Act work for the public and clean water.
What victories has Amigos Bravos experienced recently that are related to the Clean Water Act?
I was just summarizing our Fiscal Year ‘22. This year was really a culmination of multi-year projects and a whole bunch of victories came to fruition this year. And most of them are Clean Water Act related!
One of these victories was the designation of 179 miles and 42 acres of wetlands in the Upper Pecos Watershed as outstanding national resource waters, which are tier 3 waters under the antidegradation provisions of the Clean Water Act. In addition to that we saw 125 miles of designation in the Upper Rio Grande, the Rio Hondo, and the Jemez headwaters, also as outstanding national resource waters. These receive the highest form of water quality protection under the Clean Water Act.
We also participated in a triennial review. The hearing happened in 2021, but the decisions and deliberations by our decision-making body at the State level, which is the water quality control commission here in New Mexico happened this spring. And we had a number of amazing victories, including getting the State to adopt a definition of contaminants of emerging concern and authorization for the State to require monitoring of contaminants of emerging concern in Federal permits. In addition, we defeated an industry proposal to limit testing methods for compliance purposes, and we defeated another industry proposal to weaken the definition of toxic pollutants in our water quality standards. There were many other victories, but those are some of the highlights of the most recent triennial review.
What’s next for Amigos Bravos after all these victories?
New Mexico is one of only three States that doesn’t have delegation or primacy over our surface water permitting program. In other words, we do not have a State National Pollutant Discharge Elimination System (NPDES) program. Unfortunately, because of the number of smaller waterways in our State, (over ninety percent of our waterways are either intermittent or ephemeral), many of New Mexico’s waterways are not considered “Waters of the US” and therefore EPA cannot (or will not) control discharges into them. New Mexico must develop its own state run permitting program to ensure that all waters in New Mexico are adequately protected from discharges of pollutants. The next step for us is getting our state to develop and implement a State surface water quality permitting program.