Elizabeth Toney, the Gila National Forest's Silver City District Ranger, has proposed drilling a water well west of Bullard Peak on the Continental Divide. This well is intended to provide water via underground pipe to new troughs one mile north, three miles north (T Bar T Corral), one mile south (Peak Corral), and one mile northwest. I was sent notice of this proposal on 27 February with a request to comment within four business days. Since this proposal concerns all users of the Gila National Forest and, more broadly, all citizen taxpayers, I offer it publicly with several questions and observations. The Service's answers to these questions will also be published.
Ranger Toney's original letter and corresponding map are available from the Silver City District office, but it reads:
"This letter describes a proposal to drill a new well in the Burro Mountains, on the Silver City Ranger District of the Gila National Forest. The well will be drilled within the Bear Pasture of the Bullard Peak allotment. The purpose and need for the new well is current water sources within the Bullard Peak Allotment are not sufficient to provide water year-round for wildlife and seasonally for livestock.
"We would like your input for further planning of this proposed action. Instructions for submitting comments are below. It would be most helpful to receive your comments by March 6, 2023.
"The Silver City Ranger District is proposing to drill a new well 11 miles south of the Saddle Rock Road turnoff, within Tl 8S, RI 7W, Sec25 of the Burro Mountains within the Bullard Peak Allotment (see attached map). The new water will eventually provide water for a total of 8,944 acres of land and will be permanent resource for wildlife to use year-round.
"The well will be drilled and set up by a licensed contractor and a storage tank and solar panel will be installed by Forest personnel. Trough(s) will be set-up and include wildlife escape ramps. As funds become available water will then be pipelined underground along the existing road to an additional drinker 1 mile north of the existing well and then another 2 miles north to the T-T corral, a mile south to Peak Corral and another mile northwest to the ridge of FR 4088X. The pipelines will be buried along the existing road to minimize any extra impact to the area.
"The Forest Service intends to accomplish this work over the next two years with the help of cooperating organizations and the current permittee.
"The scoping process will help to determine if there are any issues involved in the implementation of this proposal. In the absence of such, it is the intent of the Forest Service to categorically exclude the project from documentation in an environmental assessment or any environmental impact statement as allowed by regulation FSH 1909 .15 Chapter 31.2, Category (1).
"Elizabeth Toney, District Ranger, Silver City Ranger District, is the official responsible for deciding whether this project shall be implemented. The Forest Service expects to conclude its analysis and issue a decision in March of 2023. Implementation is estimated to start in April, 2023.
"Your involvement in this analysis is encouraged. Please email your comments to naomi.gomez@usda.gov or mail them to Silver City Ranger District, Gila National Forest, 3005 E. Camino del Bosque, Silver City, NM 88061, Attention: Naomi Gomez. You may contact Naomi Gomez at 575-388-8379 for more information on the project."
Ranger Toney states that current water sources "are not sufficient to provide water year-round for wildlife and seasonally for livestock." Since, in the backcountry, wildlife populations and the resources that support them ebb and flow in a natural balance, has the Gila National Forest identified a cause — nature- or human-induced — responsible for a wildlife-to-water imbalance? A hydrological shift, perhaps? Diminished annual precipitation? Erosion caused by past Gila National Forest clear-cutting for grazing development?
Is "water for wildlife" fundamentally what this proposal serves?
The diverse beneficial utilization of public land, when fairly applied, is a sensible concept; the perpetuation of a taxpayer-funded welfare scheme for beef producers — or any business enterprise — is not. Will well-furnished water increase the livestock-carrying capacity of the Bullard Peak Allotment? Has the Gila National Forest estimated how much of this project's cost primarily benefits the grazing leaseholder? If grazing-leaseholder profits are increased by the capital expenditure of taxpayer money, will this expenditure be recovered via grazing fees? Or are taxpayers subsidizing beef production?
Grazing on public land should be financially self-sustaining, not a taxpayer burden.
Will this proposed well's licensed driller be selected through an open public-bid process?
If surface-water scarcity (whether for wildlife or beef) warrants costly new infrastructure, it must be treated as such from source to end-user. The current proliferation of unsheltered troughs throughout the Bullard Allotment results not only in water loss due to evaporation, but in algae growth that eventually chokes troughs and impairs fill-valve function. Whether the responsibility of conserving scarce water lies with the Forest Service, the grazing leaseholder, John Q Public, or the New Mexico State Engineer, groundwater brought to the surface on public land must be conserved.
Will these proposed water-trough installations be designed and maintained to minimize water loss?
Why is the categorical exclusion of an environmental assessment — presumably a standard to which all such projects are held and often a cost-prohibitive hindrance to private endeavors — a desirable or prudent outcome?
It has become apparent, both locally and nationally, that the U.S. Forest Service is making ranger and supervisor employment a short-term, rapid-turnover program. Forest policies and regulations may be nationally applicable, but forested public-land regions — their use, history, geographic characteristics, flora-fauna composition, role in local identity, and stewardship challenges — vary immeasurably. Years ago, upper-level Forest staff intimately knew and personally understood the forests they were hired to caretake. Today, administrative transience has become the norm.
How does playing musical-chairs with forest familiarity, knowledge, and understanding benefit Americans' public lands?
Michael Russell