Initiation of Procedures to Designate an Irrigation Non-Expansion Area for the San Simon Valley Sub-basin

Update:  Effective October 9, 2015, the Director’s decision of August 12, 2015 (“Decision”) that the San Simon Valley Sub-basin of the Safford Groundwater Basin should not be designated as a subsequent Irrigation Non-Expansion Area (“INA”) is final, and the temporary prohibition on the irrigation of new acres within the sub-basin pursuant to A.R.S. § 45-434 is lifted. 
On September 25, 2015, the Department received a motion for rehearing or review of the Director’s Decision. The Director denied the motion for rehearing and review on October 9, 2015. View the Director's decision and order denying the motion for rehearing and review.
As provided in A.R.S. § 45-114(C)(1), the Director’s Decision is now final for purposes of judicial review.  As provided in A.R.S. § 12-904(A), “an action to review a final administrative decision shall be commenced by filing a notice of appeal within thirty-five days from the date when a copy of the decision sought to be reviewed is served upon the party affected.”

Director's Decision

On August 12, 2015, the Director issued findings and a decision that the San Simon Valley Sub-basin of the Safford Basin shall not be designated as an irrigation non-expansion area. A notice of the Director’s findings and decision was published in both the Arizona Range News and Eastern Arizona Courier on August 19, 2015, and August 26, 2015.

The Department will provide written notice of the date that the Director’s decision becomes final to all persons who attended the May 16, 2015 public hearing, to all persons who submitted written comments on the proposed INA in the San Simon Valley Sub-basin, and to all landowners within the San Simon Valley Sub-basin of county record. In addition, the Department will post notice of the date that the Director’s decision becomes final on the Department’s website for at least sixty days after the decision becomes final. 

Copies of the Directors Findings, Decision and Order will be made available upon request to the following:

Shauna Evans, Public Information Officer 
Email: [email protected]
Phone: 602-771-8079

Sharon Scantlebury, Docket Supervisor
 Email: [email protected]
Phone:  602-771-8472

The Arizona Department of Water Resources received a petition for the Initiation of Procedures to Designate an Irrigation Non-Expansion Area (INA) for the San Simon Valley Sub-basin.  Pursuant to A.R.S. § 45-432, the Director can designate a Subsequent INA if specific criteria have been met. Frequently asked questions and answers regarding INAs are available.

The Department evaluated the petition to designate an INA in the San Simon Valley Sub-Basin and determined that the petition is signed by at least one-fourth of the irrigation users of groundwater within the groundwater sub-basin.  A description of the Department’s process for making this determination is available here.  Because the petition meets the signature requirements of Arizona Revised Statutes (A.R.S.) § 45-433(A)(1), the Department published a Notice of Initiation of Designation Procedures and Notice of Public Hearing in both the Willcox Range News and Eastern Arizona Courier newspapers on March 18, 2015 and March 25, 2015.

On the date of the first publication of the Department’s notice, March 18, 2015, a temporary prohibition on the irrigation of new acres within the proposed INA became effective.  Pursuant to A.R.S. § 45-434, effective March 18, 2015, only those lands irrigated in the five years preceding that date may be irrigated.  “Irrigate” means to apply water to two or more acres of land to produce plants or parts of plants for sale or human consumption, or for use as feed for livestock, range livestock, or poultry.  A.R.S. § 45-402.  (Note that the new application of water to gardens, orchards or vineyards less than two acres in size is not prohibited, provided that groups of such fields are not managed as a single farming unit.) This temporary prohibition remains in effect until the Director of the Department makes a final determination on the proposed INA.

A public hearing concerning whether to designate an INA within the San Simon Valley Sub-basin was held at the Bowie High School in Bowie, Arizona, on Saturday, May 16, 2015.  A transcript from that hearing is available.

To obtain a copy of the certificed transcript please contact:

Court Reporting Service
P.O. Box 17507 Tucson, Arizona 85731
(520) 792-2600 or (800) 759-9075
[email protected]

Access an uncertified copy of the transcript

At the hearing of May 16, 2015, the Department announced that it will keep the hearing period open until June 5, 2015 at 5:00 p.m. for the submission of written comments and evidence.  The Department further extended the comment period until July 17, 2015, so that the Department may present and the public may provide comment on: (1) finalized water level data for the San Simon Valley sub-basin, and (2) a numerical groundwater model for the San Simon Valley sub-basin. View comments received during the open comment period (as of July 23, 2015).

Within 30 days after the close of the public hearing period, the Director of the Department will issue findings regarding the matters considered during the hearing.  If the Director decides to designate an INA, he will issue an order of designation. If the Director designates an INA, the prohibition on irrigation of new acres within the San Simon Valley Sub-basin (with certain limited exceptions) would remain in effect permanently. If the Director decides not to designate an INA, the prohibition on the irrigation of new acres within the sub-basin will be lifted.

Petition and Supporting Documentation


A&P Ranch Parcel Information

Driscoll Parcel Information

FICO San Simon Farm Parcel Information

Ft. Bowie Ranches, Allred, Chapman Farms and Bowie Pecans Parcel Information

Massey Enterprises LLC

San Simon Valley Sub-basin Groundwater Flow Model

ADWR has completed a regional-scale numerical groundwater flow model of the San Simon Valley Sub-basin using the widely accepted U.S. Geological survey (USGS) MODFLOW computer program.  A technical memorandum describing the model objectives, design, inputs, calibration, and projection results is available.

Modeling input files and model grid GIS shapefiles are available.

The model was used to project groundwater conditions that would exist after 100 years of pumping at current rates of withdrawal calculated using USGS crop survey and water use data.  The results of this projection are summarized in the table below for agricultural areas with deep wells that mainly produce water from the lower aquifer.   Because portions of the upper aquifer are projected to de-water by 2115, only lower aquifer projections are provided.   Model projections using current rates of withdrawal indicate that a minimum of approximately 400 feet, and as much as several thousand feet, of saturated thickness would remain in the lower aquifer in 2115 for agricultural areas of the sub-basin.

Projected Depth to Water for Deep Agricultural Wells in the San Simon Valley Sub-basin in 2115


Bowie Area

San Simon Area

NE of Portal

Near Rodeo

Deep Agricultural Well Count





Minimum  Depth to Water (Feet BLS*)





Maximum Depth to Water (Feet BLS)





Mean Depth to Water (Feet BLS)





Median Depth to Water (Feet BLS)





* BLS = Below Land Surface

  • Statistics Are For Deep Agricultural Wells That Were Measured in 2015.  (Well Depth greater than or equal to 400 feet BLS)

  • Projected Depth-to-Water in 2115 = (2015 Measured Depth-to-Water) + 2015-2115 Projected  Lower Aquifer Drawdown

Information Presented During the May 16, 2015 Public Hearing

Presentation made by ADWR:
Hydrology and Water Use Data of the San Simon Valley Sub-Basin - Presentation

Presentations provided by the public during the public comment period:
Mason Bolitho - Presentation
Sy Ray - Presentation
Larry Romney - Presentation

Additional Information

Preliminary Water Level Data Collected in the San Simon Valley Sub-basin - PDF file or Excel file

INA Frequently Asked Questions

The Department has received requests for a list of previous hydrologic studies completed in the San Simon Valley Sub-basin.  The ADWR Open-File Report 12 entitled “Evaluation of Available Scientific Data Related to the Possible Delineation of a Bowie Sub-Basin of the Safford Groundwater Basin”, has an extensive list of references.

Information on Substantial Capital Investment

Provided below are examples of documentation previously used by ADWR to make determinations on applications for the consideration of substantial capital investment in granting a Notice of Groundwater Authority ("60") in an INA or Certificate of Grandfathered Groundwater Right ("78") in an AMA.  These examples are being provided for informational purposes only.

Attachment A 60-200083 60-203030
Attachment B 60-201080 60-203129
  60-201104 78-109097
  60-201111 78-116092