March 16, 2001
Mr. Donald Hobbs
BECC General Counsel
PO BOX 221648
El Paso, Texas 79913
Dear Mr. Hobbs,
The Texas Center for Policy Studies appreciates the opportunity to provide ideas for pilot projects being considered as part of the mandate expansion. We view this opportunity as a first step in this process. We have three types of projects we believe would make sense as "water management" pilot projects: irrigation delivery and on-site water conservation projects, sustainable agriculture projects, and sustainable forestry management projects.
One of the major ongoing challenges in the border has been water management in the Conchos River Basin, principally located in the State of Chihuahua. (Recently TCPS published a report The Rio Conchos: A Preliminary Overview which highlights the state of the river and current challenges.) The current and ongoing drought has exacerbated this challenge. Currently, TCPS is working with partner organizations in Mexico to identify the opportunities to better manage the quantity of riverflow and improve its quality. We believe there are a number of potential pilot projects along the Rio Conchos, as well as the need for a basin-wide management plan. While our specific examples concern the Rio Conchos, other river basins -such as the Rio San Juan - would also provide excellent opportunities for water conservation projects.
First of all, there are several large irrigation districts within the basin which rely upon riverflow, allocated reservoir water and, in some cases, groundwater to grow a variety of crops. In fact, agricultural irrigation accounts for 90% of water use in the basin, with the irrigation districts themselves using most of this water. Nonetheless, the Comisión Nacional de Agua estimates that water use efficiency in the three major irrigation districts in the Conchos basin is only about 40%. Because of these inefficiencies, CNA estimates that more than $90 million is required to make the necessary conservation investments. With loans to improve delivery of water through irrigation canals, to more accurately measure water use and to implement on-site agricultural conservation projects once the water is delivered to individual farms, substantial water savings could be enjoyed, reducing drawdown from the reservoirs and aquifers and allowing for more instream flow to the Rio Grande.
While one of the major districts is located within 100 kilometers of the border - the Distrito de Riego Bajo Rio Conchos - others, such as the Delicias irrigation district -- are located outside of the 100 kilometer border area. Still, because the charter allows for certification of projects outside the 100 kilometer border area if the EPA and SEMARNAP find that a project would "remedy a transboundary environmental or health problem" , we believe that water conservation projects outside the border area could be justified as they would improve the health and environment of residents downstream on both sides of the border, according to the Agreement Between the Government of the United Mexican States and the Government of the United States of America Establishing the Border Environment Cooperation Commission and the North American Development Bank, Chapter 1, Article II, Section 2.
Similarly, these same irrigation districts, as well as individual farms could be candidates for sustainable agricultural pilot projects. Instituting integrated pest management practices as well as non-chemical alternatives on farms could lessen the possibility of insecticides and herbicides affecting both groundwater and river water resources. While water quality data in Mexico is limited, evidence from some monitors along the Rio Conchos as well as on the Rio Grande itself suggest that contamination from pesticides is a serious problem. These include contamination from pesticides which have been banned from use in the U.S. because of their inherent dangers. A sustainable agriculture pilot project could reduce dependence upon expensive chemicals, improve water quality and possibly open up new niche export markets in the U.S.
Finally, there is growing evidence that improper forestry practices, including illegal logging, in the Sierra Tarahumara in southern Chihuahua is leading to rapid sedimentation of the upper Rio Conchos . The BECC and NADBANK could work on a pilot project with forest ejidatarios to design and manage a sustainable forestry plan to preserve the quantity and quality of the river headwater flows.
The Texas Center for Policy Studies, working in partnership with Mexican authorities and organizations, looks forward to helping the BECC and NADBANK identify specific irrigation districts, municipal authorities and forest ejidatarios that would have a potential interest in such pilot projects.
Thank you again for the opportunity to comment,
Cyrus Reed
Project Director