August 22, 2016
The following are reasons for writing a protest letter to the State Engineer:

1. The Augustin Plains Ranch, LLC. (APR) has filled another application with the OSE (Office of the State Engineer) to extract 54,000 acre feet of water from the Plains of San Augustin.

2. The plains aquifer is already in decline as of a recent report from the Water Resources Research Institute, which states that the plains groundwater has declined by 0.22 MAF (million acre feet) or 220,000 AF or 65,170,290,000 gallons between 1970 and the 1990s, and this does not take into account the losses in this century. This decline is with the drought and the current withdrawals for stock grazing and subdivisions. Currently there are about 7,000 AF of water under permit for diversion in the watershed.

3. The APR's application would achieve the current amount of decline that was scientifically calculated to have occurred between 1970 and 1990s; again not taking into account the losses in this century'within a 4-year-period. This is not a sustainable rate of withdrawal of the groundwater; because of the lack of adequate recharge to the watershed.

4. The Plains of San Augustin has a flow gradient to the southwest, toward the Continental Divide; this is only possible if the basin is leaking through fault/fracture structures that cross the divide. The leaking water supports the flows in the Gila and San Francisco Rivers. The water from the San Augustin Plains was never considered under the Arizona Water Settlements Act, which was a major oversight.

5. Other things at risk from this amount of additional pumping are:

Depletion of the whole groundwater aquifer,

Collapse of the perched aquifers in the northern part of the plains

Deferential settlement of the soils within the basin,

Probable damage to roads, homes and utilities,

Devaluation of adjacent properties,

Economic loss to Datil and the surrounding area; this also includes much of Catron and Socorro Counties. This could also adversely affect reaches of the Gila and San Francisco Rivers. Catron and Grant Counties would sustain economic loss of recreational income from hiking, bird watching, fishing, and hunting as well as the flora and fauna of these areas along the rivers. There will be diminished flows within the river systems to the point that there would not be enough water to support acequias ditches. This will also adversely affect two National Forests and the Gila Wilderness.

6. The current average wellhead elevation in the plains is about 6,940 feet in elevation and the average water elevation is about 6,744 feet; but water depths are all over the place because of perched nature of these water tables within the basin. This is based on evaluating 100 wells associated with lower part of the plains. The APR's 30 plus wells will be pumping water from about 4,000 feet in elevation. This difference in elevation is beyond what the current adjacent land owners could ever afford. To deepen their wells to this depth is well beyond their economic means. Also water quality often from such depths has higher concentration of harmful minerals and much higher levels of salt. The southwestern part of the plains has a salt playa with high salt content in the wells in that area.

These are just some of the reasons to file a protest letter with the State Engineer over this application. I hope you will take part in fighting this water grab for profit. It will NOT benefit the local counties.

Dennis Inman
Geologist