Letter to editor

From Silver City Ranger District, Gila National Forest

SILVER CITY, NM, April 17, 2023 – Several weeks ago, Michael Russell posed questions related to the Rock Well project in the Burro Mountains southwest of Silver City, publishing his letter in the Grant County Beat. The Silver City Ranger District has completed its compliance with the National Environmental Policy Act by documenting the effects of the proposed action in a Categorical Exclusion. Silver City District Ranger Elizabeth Toney issued the Decision Memo supporting development of the Rock Well on 04/14/2023. The project is expected to be implemented in May 2023. Project documents, including response to comments, can be found at Forest Service (usda.gov). This letter responds directly to Mr. Russell's questions from his published letter that are relevant to this project.

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

Yes. The installation of the well will improve wildlife habitat by providing yearlong water availability. Fenced off springs within the Burro Mountains have been drying up during the summer months with persistent drought conditions. While wildlife can find natural water sources, these improvements provide water during dry periods when springs recede underground, making water scarce. There are numerous ungulates, mammals, birds, reptiles, butterflies, and bats that are located within and around the project area. Water troughs would be designed to be bat friendly, as to invite nectar feeding bats to occupy the project area. All wildlife waters are intended to be functional year-round. Wildlife monitoring cameras have been placed at watering points within the Burro Mountains, and images collected from these cameras show that many different wildlife species have been detected using the water improvements. Water from the well is primarily for the benefit of wildlife, but permitted livestock will be able to drink the water, too.

2) Will well-furnished water increase the livestock-carrying capacity of the Bullard Peak Allotment? 3) Has the Gila National Forest estimated how much of this project's cost primarily benefits the grazing leaseholder? and 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?

The permitted number of grazing livestock will not be increased through this action, and the grazing permittee is not responsible for costs associated with this project.

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

This contract would only be awarded to licensed individuals qualified to provide the service. The New Mexico Office of the State Engineer requires that the driller be licensed in the State of New Mexico, with the exception of driven wells with a casing less than two and three-eighths inches outside diameter.

The Contract Opportunities website at sam.gov/content/opportunities is the website where the United States Forest Service and other organizations within the federal government publish notices on proposed contract actions valued at more than $25,000. These notices, or contract opportunities, cover announcements through official solicitations in the pre-award process. Anyone interested in doing business with the government can use this system to research active opportunities. The Federal Acquisition Regulation (subpart 4.11) requires that contractors be registered in the SAM database prior to being awarded a contract. Detailed information about SAM is available online at sam.gov/content/home.

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

To limit the amount of water lost, troughs are installed with a float to minimize overflow and regulate water to avoid running over. However, in the event that a small amount of overflow does occur, it can benefit butterflies, reptiles, and small mammals that would not otherwise be able to utilize the trough. If overflow is observed due to failure of the float or other infrastructure, repairs will be completed to correct the issue.

The relatively small volume of water being pumped to fill three troughs is highly unlikely to affect the aquifer below and providing additional water sources to cattle could deter their usage around springs, allowing for the natural recovery of these sensitive areas. A drawdown analysis was conducted to estimate how much the water level will go down over time and distance. When a well is pumped the water forms a cone of depression around the bottom of the casing. When the pump goes off, either because the float indicates the trough is full, or because it is nighttime and there is no power, the cone of depression will fill back in to a static (flat) water level. The drawdown analysis uses information about the geology, transmission rates, and permeability of the area of the well and adds a pump rate to it in gallons per minute. An equation is used that gives an estimate of how this cone of depression reacts over a period of time (e.g., does it fill in, is it widening, etc.). The results of this analysis show very little cone of depression forms over a decade (only 3/100ths of a foot over a 3-mile range).

7) Why [for this proposed project] is the categorical exclusion of an environmental assessment a desirable or prudent outcome?

In compliance with the CEQ regulations, a CE is defined as "a category of actions that the agency has determined, in its NEPA procedures, normally do not have a significant effect on the human environment" (40 CFR 1508.1(d)). A proposed action may be categorically excluded from analysis and documentation in an EA or EIS when there are no extraordinary circumstances related to the proposed action and when the proposed action is within one or more of the categories listed at 7 CFR part 1b.3 or 36 CFR 220.6(d) or (e) (36 CFR 220.6(a)). No extraordinary circumstances have been identified related to the proposed action. The application of a categorical exclusion for this project eliminated the need to analyze actions that will not have any significant environmental impacts, increasing project efficiency by reducing the cost, staff resources, and time needed to implement the project.

Questions about staffing on the Gila National Forest are not relevant to this issue and will not be addressed here. If anyone would like to discuss questions about staff tenure, they can feel free to reach out to us directly at 575-388-8201 for discussion.

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