2e) Water Issues, (1) Stormwater drainage

Norman Gaume, P.E. (ret.)

44 Canoncito Dr NE • Albuquerque, New Mexico • 87122 • 505 690-7768 • normgaume@gmail.com
Consulting Engineer (ret.) Water Resources Management and Planning

Hand delivered for the record and emailed

December 4, 2018

ABCWUA Board Chair Jones and members

Albuquerque/Bernalillo County Water Utility Authority

Re: Santolina Serviceability Letter

Dear Madame Chair and board members,

The ABCWUA’s October 1, 2018 Water and Sewer Serviceability Letter #180108 for
Santolina and information reported in the Albuquerque Journal October 17 news article $600M
water plan proposed for Santolina that the article attributed to the ABCWUA but is not
contained in the serviceability letter raise important questions and matters of public policy
that should be of concern to you, the ABCWUA governing board.

1. The Bosque Water Reclamation Plant construction schedule has been accelerated.
It was to be built after 2050. Now it is proposed to be completed as a
prerequisite to providing water and sewer service to Santolina. $49 million of
Bosque WRP capital costs were included in the $659 million total of “Table 1
Estimated Cost of Infrastructure by Phase” that ABCWUA’s consultants set forth
in an October 11, 2018 Technical Memorandum entitled Santolina Water and
Sewer Serviceability Basis of Cost. The Bosque WRP costs do not appear in the
serviceability letter list of the master plan infrastructure set forth in Table 2.
What is the basis for the $49 million share of the Bosque estimated total capital
costs which exceed $100 million? Why are Bosque plant costs eliminated from
the serviceability letter infrastructure requirements?

2. The ABCWUA in its requests for state and federal capital funding that are on
your agenda today for approval includes funding for the Bosque Water
Reclamation Plant. What is the rationale for asking the state and federal funding
to contribute funds for the Bosque plant in light of item #1 above?

3. Ongoing O&M costs for Bosque WRP and other water supply and wastewater
treatment infrastructure that the serviceability letter identifies as being necessary
to provide service to Santolina will be disproportionately high. Mark Sanchez
told the Legislature’s Water and Natural Resources Committee on November 30
that growth will pay for growth, without subsidy from existing ratepayers. If that
is true, then will ABCWUA rates for service to Santolina recover these high
marginal annual costs?
ABCWUA Board Chair and Members
December 4, 2018
Page 2 of 3
4. Background technical documents prepared by ABCWUA consultants indicate that
Santolina’s water supply will involve reuse of treated wastewater because the
consultants evaluate concerns of objectionable total dissolved solids
concentrations build up in the Santolina water supply. This could only result from
reuse of treated wastewater. Does the Santolina water supply solution require
non-direct potable reuse as Mark Sanchez has previously indicated to the
Bernalillo County Board of County Commissioners? If so, why doesn’t the
serviceability letter so indicate? Is the “5 MGD Advanced WTP” included in the
serviceability letter Table 2 for indirect potable reuse? Aquifer storage and
recovery is the mechanism for indirect potable reuse. Why are the aquifer storage
and recovery costs missing from the serviceability letter?
5. The October 11, 2018 technical memorandum cited in #1 above concludes that 18
MGD of new groundwater capacity is required for service to Santolina but
illustrates no groundwater facilities (well locations and associated collector lines
to convey water from the new wells to storage tanks) and includes a low
groundwater costs subtotal. The Albuquerque Journal article cited in #1 above
says,
Water Utility Authority officials have told developers that groundwater is
available on the property, but no additional water capacity within the
Water Utility Authority’s current infrastructure is available for the area.
There is no locally available groundwater. The ABCWUA probably intends to
pump groundwater from the east side of the Rio Grande to the west side for
Santolina. Why are all aspects of the 18 MGD of additional groundwater capacity
listed as a requirement that Santolina must pay for without any public description
or detail?
6. The October 11, 2018 technical memorandum cited in #1 above indicates the cost
estimate is highly preliminary, uncertain, and could be as much as 100% higher
than the $659 million estimate it presents. The serviceability letter asserts the
developer must reassess and report feasibility of its development as a requirement
before proceeding. The ABCWUA web page also mentions developer assessment
of feasibility as a purpose of serviceability letters. For this developer
reassessment of feasibility to be valid, it should include all the ABCWUA costs to
be imposed on the developer in order to comply with the no-net expense to
existing customers policy. Instead, ABCWUA’s stated Santolina cost of $600
million, as provided to the Albuquerque Journal but not directly to the public, is
unrealistically low if the ABCWUA intends that its no net cost policy means what
it says.
The ABCWUA has failed to respond to my November 15, 2018 request to inspect public
records pertaining to its October 1, 2018 Water and Sewer Serviceability Letter #180108
and information that the ABCWUA provided to the Albuquerque Journal before the
October 17 news article $600M water plan proposed for Santolina. The ABCWUA is in
technical violation of the New Mexico Inspection of Public Records Act by indicating it
ABCWUA Board Chair and Members
December 4, 2018
Page 3 of 3
would respond by November 30, 2018, and then not doing so with notification of a
revised date to produce the responsive public records.
I will make additional public comment on this matter after the ABCWUA comes into
compliance with its lawful requirements to timely provide all pertinent public records
pursuant to my November 15 IPRA request for inspection.
Sincerely,
/s/
Norm Gaume