On 27 February, I received a Gila National Forest proposal to drill a new water well near Bullard Peak because "current water sources within the Bullard Peak [cattle-grazing] Allotment are not sufficient to provide water year-round for wildlife and seasonally for livestock." I was told that my "involvement in this analysis is encouraged" and given four business days to comment. I emailed my comments to the proposal's author, (new) District Ranger Elizabeth Toney, published them here as an op-ed piece two days later, and awaited Ranger Toney's reply. I consider it fair to match a four-day comment period with a four-week reply expectation and yet, having received no word from Ranger Toney in four weeks — not even a "thanks for your input, we're taking it under advisement" — I am left to apply decades of personal experience with Forest Service management in six states to answering my own questions.

First, a disclaimer. I am neither a tree-hugger nor a plunder-the-land advocate. I understand the quandary of historical/traditional livestock-grazing rights versus public-land management and the legal/moral challenges that result. I hold ranchers and farmers in high esteem — unless their endeavors rely upon taxpayer-funded agricultural-welfare programs. I have met, and in two states fought wildfires alongside, dozens of hard-working, admirable boots-on-the-ground Forest employees, but it has been 29 years since I've known a district supervisor or ranger worthy of similar regard. That does not mean I'm prejudiced; it means I'm still waiting.

And since it is not enough to flatly disparage taxpayer-subsidized agriculture — whether in the form of grazing permission, crop-loss relief, fishery incentives, or by paying dairy farmers to dump milk on the ground — in fairness I must state an alternative. What, therefore, would constitute a reasonable arrangement where private grazing on public land is concerned?

After legitimate environmental and competing public-use considerations have been duly addressed, the infrastructure required to support and manage livestock grazing should be, down to the last dollar, the fiscal responsibility of grazing leaseholders. Range-improvement costs, including the erection of miles of barbed-wire fencing, the burying of (in this proposal) miles of underground plumbing, water-well siting and drilling, stock-tank installation, corral construction, gate and cattle-guard placement, and the ongoing maintenance of said improvements, must be accurately and consistently factored into individual leaseholder contracts — as with any independent business venture. If demand for the final packaged product fails to cover the expense of bringing that product to market, such would simply be market reality, neither fair nor unfair to industry, community, or lifestyle choice. The overarching principle is that there is nothing fair about taxing people to support an industry they do not, uncoerced, adequately support as consumers by paying the unsubsidized market price.

1) Is "water for wildlife" fundamentally what this proposal serves?

No. Forested swaths of the Bear Pasture portion of the Bullard Peak Grazing Allotment have been clear-cut and burned by the Gila National Forest, not for wildfire control in an area nicknamed by firefighters "the asbestos forest" for its flame resistance, but to increase grazing acreage for cattle. These costly deforestation projects stripped the landscape of healthy vegetation that provided shade, forage, and shelter for wildlife while slowing evaporation from the soil and decreasing monsoon-rain runoff and erosion. It is no surprise that those responsible for decreasing wildlife resources now see themselves as saviors of wildlife by artificially bringing groundwater to the surface for — wildlife? Well, no, for cattle. But wildlife can drink it, too.

2) Will well-furnished water increase the livestock-carrying capacity of the Bullard Peak Allotment?

That depends on whether or not the agency aligns its standard of carrying capacity to accommodate a desired carrying capacity.

3) Has the Gila National Forest estimated how much of this project's cost primarily benefits the grazing leaseholder?

Probably not.

4) 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?

Federal agencies rarely conduct real-world cost-benefit analyses unless pressured, because what works in real-world terms is irrelevant compared to how much funding can be obtained next year, and because it is easier to bend regulations and redefine terminology than adhere to burdensome mission statements. In the case of this proposed new infrastructure north and west of Bullard Peak, taxpayers will be subsidizing beef production.

5) Will this proposed well's licensed driller be selected through an open public-bid process?

Probably, since the question has been publicly asked.

6) Will these proposed water-trough installations be designed and maintained to minimize water loss?

Probably not. The Silver City Ranger District has in the past demonstrated little respect for water conservation and, on at least one documented occasion, no respect for private water rights or State of New Mexico water law.

7) Why [for this proposed project] 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?

The "categorical exclusion" caveat is written into USFS regulations for at least one obvious reason: So that "the rules" don't have to apply when policy makers decide they don't want them to. Maybe there are budget considerations in spite of overt overspending elsewhere (such as six-figure annual salaries for supervisors and rangers), or maybe an environmental assessment would not favor this particular well-drilling, pipe-burying, trough-installation proposal. Ranger Toney is welcome to chime in with a correction — about this or any other answer wherein I may be mistaken.

8) How does playing musical-chairs with forest familiarity, knowledge, and understanding benefit Americans' public lands?

This question may seem immaterial to a grazing-allotment-improvement proposal, but it is at the center of all Forest-management policy in recent years. It is not an accident that regional upper-level staff are being shifted from one short-term post to another, learning after a few months or years just enough about their new domain to be authoritatively ignorant. Which begs a rewording:

8) If knowledge acquired by district supervisors and rangers through long-term experience with America's unique regional forests is not valued by bureaucrats at the top of the Forest Service hierarchy for the purpose of intelligently stewarding America's forests, what is?

Answer: Control of America's forests.

In an attachment to his 20 February Letter to the Editor protesting the aerial slaughter of "invasive non-native species," aka unpermitted cattle, Ralph Pope, a retired Forest Service rangeland manager, asked (new) Silver City District Supervisor Camille Howes: "Whatever happened to 'Caring for the Land and Serving People'?" Mr. Pope's question fundamentally targets the aforementioned upper-echelon bureaucrats and their paymasters, but its implications inevitably trickle down to local forest-management practices. Somewhere along the way — probably prior to that public-relations slogan's unveiling — "Caring for the Land and Serving People" became "Caring for the Policy and Serving Washington," the reversal of which, even on a local level, will require more than an occasional Coffee with Camille. Especially if her Silver City posting is short-term.

Ranger Toney's well-drilling proposal is about taxpayer-subsidized cattle grazing. That wildlife can sip at the trough is merely a consequence on the periphery and a public-relations appeasement.

 Michael Russell

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