Ranchers Want To Graze More Of Arid Tonto National Forest

The The Tonto National Forest land management plan (LMP), revised in 2023, includes a provision pushed by local ranchers that could expand livestock grazing into federal wilderness areas. The livestock grazing section of the revised LMP includes the following objective:

At least one vacant allotment will be evaluated for one of the following options every two years, until there are no vacant allotments. If additional allotments become vacant (waived without preference) they will be evaluated for one or a combination of the following options within two years:

1. Convert to forage reserves to improve resource management flexibility;
2. Grant to current or new permitted livestock producer; or
3. Close to permitted grazing, in whole or in part.

According to the livestock grazing portion of the revised LMP’s environmental impact statement (EIS), there are 8 grazing allotments on the Tonto that have been vacant for many years. (Vacant allotments are those that haven’t been officially closed to livestock grazing, such as when the neighboring Coconino National Forest closed its Ike’s Backbone grazing allotment in 2017.) Most of the Tonto’s vacant allotments include federal wilderness, including much of the Superstition Wilderness and Mazatzal Wilderness areas. And they all include large amounts of hot desert, since the Tonto National Forest includes about 791,284 acres of Sonoran Desert.

When the Tonto released the LMP’s  draft decision in March, 2022, it generated several objections regarding livestock grazing management. The Southwestern Regional Forester, Michiko Martin, responded by hosting online objection resolution meetings on February 21 & 22, 2023. When the issue of the status of vacant grazing allotments was raised during the first meeting, the Meeting Notes show that Tonto National Forest Supervisor Neil Bosworth responded:

“There would be a public process for analyzing them through the NEPA process. However, some already have NEPA completed. He’ll need to get back to Jeff. Usually, NEPA is the public process. So, if NEPA is already done, we may need to come up with something different.”

The Southwestern Regional Forester subsequently produced an Objection Response report in May 2023, and on page 94 of the report it stated:

In response to Jeffrey Burgess’s request to initiate the NEPA public planning process before making administrative decisions to permit grazing on a vacant allotment, where NEPA is needed because NEPA has not been completed or there have been significant changes since the previous NEPA was completed, the forest will complete NEPA and ensure compliance with other applicable laws prior to issuing a grazing permit.

But the Tonto ignored these instructions in their subsequent final decision for the LMP revision, issued in December, 2023. Instead, page 15 of the decision provided a universal commitment that the National Environmental Policy Act (NEPA) public planning process would be “conducted in order for prohibitions or activities to be implemented.”

The Tonto’s eight long-vacant grazing allotments are listed in the table below, along with their most current livestock management documents. The most recent of their NEPA environmental assessments (EAs) were completed many years ago. There have been many changes since then that render them obsolete.

Forest Service Policies Promote More Grazing

In May 2004 The Tonto National Forest signed a memorandum of understanding (MOU) with the Arizona Cattle Growers’ Association that encouraged the forest to authorize grazing on vacant pastures and grazing allotments. The MOU replaced the forest’s 2001 rangeland drought policy, which focused on protecting natural resources from livestock damage.

Conservationists were hopeful when the Biden administration took office in January of 2021 that things might change, especially when he immediately issued Executive Order 14008, wherein he outlined a nationwide conservation initiative that instructed federal agencies to enact policies that would “achieve the goal of conserving at least 30 percent of our lands and waters by 2030.” It was labeled the “30 by 30” plan. But the plan lacked specifics about what constituted conservation under his program and mostly promised to increase agricultural subsidies. In regard to public land grazing, there was controversy about whether all federal grazing allotments should be considered “conserved” lands – even though many of them don’t meet land health standards or aren’t in compliance with the Endangered Species Act.

But when the Biden administration finally started releasing long-awaited amendments to the grazing management directives in Forest Service Handbook 2209.13, the new version of Chapter 30, Temporary Grazing Permits, issued in June of 2023, wasn’t substantially different from the previous version, and still promoted the authorization of grazing on vacant grazing allotments.

A good example of how the agency is biased towards the interests of grazing permittees is shown by the Tonto’s management of the Sunflower grazing allotment after most of it was burned in the enormous 2020 Bush Fire. The allotment, which is located in the Mesa Ranger District, is mostly Sonoran Desert on the western slopes of Four Peaks all the way down to State Route 87. An EA was completed for the allotment in 2015, which facilitated the resumption of grazing on it in 2018 after several years of nonuse. The allotment’s October 2015 decision notice stated that several of the allotment’s lower elevation desert pastures would be put into nonuse, “until such time as a new environmental analysis is conducted to show the need for these pastures and the effects of authorizing grazing within them.”

But the allotment’s 2021 annual operating instructions (AOI), the first AOI issued after the Bush Fire, authorized grazing on one of these pastures, the Otero pasture, and also on the East Bartlett pasture, which is located on the adjacent, and long-vacant, Bartlett allotment in the neighboring Cave Creek Ranger District. (The Bartlett allotment’s EA was completed in 1982.) The Forest’s justification for allowing grazing in these pastures was that it was a temporary “emergency” measure due to the fire and drought, and it was necessary to “maintain a viable ranching operation.” In other words, protecting the financial interests of the grazing permittee was their primary concern, as per the 2004 MOU. Furthermore, the allotment’s subsequent 2022 AOI showed that grazing was allowed to resume on its burned portions – less than two years after the fire.

Other Vacant Grazing Allotments

The Bull Springs allotment located in the forest’s Payson Ranger District is also vacant, after a 2018 allotment inspection report found the grazing permittee to be out of compliance. The allotment is located entirely within the Mazatzal Wilderness, and its most recent EA was completed in 1989.

Obviously, it would be a NEPA violation if the Forest authorized grazing to begin on any of these allotments without first conducting a new environmental analysis. As described above, Forest Service officials have given assurances that the NEPA public planning process would be engaged before grazing might be authorized on them, but the Tonto National Forest has a history of authorizing grazing on allotments that have been vacant for years without first completing a NEPA analysis.

For example, in 2007 the Pleasant Valley Ranger District authorized grazing to begin on the Bar X allotment, located below the Mogollon Rim. It includes the old Bar X, Haigler Creek, Young & Colcord allotments, and hadn’t been grazed since 1979, which was also the year of the most recent EA. (The Forest was subsequently sued for failing to completed a NEPA analysis before authorizing the grazing, and forced to complete an EA in 2019. The resultant 2019 decision is still under litigation.)

In 2010 the Tonto Basin Ranger District authorized grazing on the Dagger allotment, located along lower Cherry Creek. It hadn’t been grazed since 1999, and the EIS was completed in 1997. Then in 2015 several pastures were transferred to it from neighboring allotments without any NEPA analysis.

In 2010 the Tonto Basin Ranger District authorized grazing on the mostly-desert Poison Springs allotment, located along the lower Salt River just above Roosevelt Lake. It hadn’t been grazed since 2000, and the EIS was completed in 1997. The current, and much different, boundaries of the Poison Springs allotment were set in 2017. These changes also created a new allotment, called the Black Mesa allotment, and grazing was also authorized on it without any NEPA analysis.

In January 2017 the Cave Creek Ranger District authorized grazing to resume on the New River allotment. The allotment hadn’t been grazing since 2005 because its fences had burned in the 2005 Cave Creek Complex Fire. The permittee was required to rebuild the fences before grazing would be reauthorized, but they still hadn’t been rebuilt by 2010. Grazing was authorized to resume on the allotment in 2017, despite the fact the fences still hadn’t been rebuilt. The allotment’s EA was completed in 1985.

In November 2017 the Cave Creek Ranger District authorized grazing on the Cartwright allotment, which surrounds the Seven Springs area. It hadn’t been grazed since 2008, and the most recent EA was completed in 2008.

There were no public notifications that grazing was being initiated on these allotments and pastures – nor is the Forest Service required to announce these types of decisions. Keep in mind that the Tonto authorized grazing on these areas during an almost uninterrupted period of drought that has lasted more than 20 years. The ongoing megadrought is the driest multi-decade period the Southwest has seen since at least 800 CE.

Furthermore, the initiation of grazing on these allotments required the construction and repair of expensive ranching infrastructure, such as fences and livestock waters. Taxpayers had to help pay for them through government assistance programs, such as the USDA Environmental Quality Incentives Program (EQIP). And they paid again when the permittees received USDA Livestock Forage Disaster Program (LFP) assistance due to the continuing drought. The tables below show the government assistance received by some of the ranches that hold grazing permits for the formerly-vacant allotments mentioned above:

Government Assistance For Ranchers Program Key

Note: Financial information acquired through Freedom of Information Act requests and Public Records Requests.

Converting Vacant Allotments to Forage Reserves

One of the options for vacant grazing allotments listed in the Tonto’s new LMP is to, “convert them to forage reserves to improve resource management flexibility.” This might sound good, but what it really means is that grazing would be authorized in new areas in order to allow grazing permittees to avoid having to reduce their herds due to drought or fires. And, as pointed out above, initiating grazing in new areas usually means taxpayers are stuck with the bill for the new fences and livestock waters that are typically required.

Moreover, designating a vacant allotment as a temporary forage reserve could sneakily create a situation where it would be much easier for the forest to issue a regular 10-year grazing permit for the allotment.

SOPA

The Tonto National Forest’s schedule of proposed actions (SOPA), where they publicly list their planned and active NEPA projects, has no mention of the vacant allotments. Forest Service SOPAs are updated quarterly, so conservationists obviously need to watch the Tonto’s to see if any NEPA projects for vacant allotments are announced. (Unfortunately, the Tonto doesn’t provide an email subscription for its SOPA.)

Updates

On July 15, 2024, the Biden administration released another amendment to Forest Service Handbook 2209.13. Their new version of Chapter 90, Rangeland Management Decisionmaking continued to give favorable treatment to grazing permittees.

On August 6, 2024, Arizona conservationists sent a letter to the Tonto National Forest Supervisor demanding that the NEPA public planning process would be engaged before any grazing was authorized on the Forest’s closed or vacant grazing allotments.

On September 18, 2024, Tonto National Forest Supervisor Neil Bosworth issued a letter in response to the letter he received from conservationists in August about engaging the NEPA process for vacant grazing allotments. In it, he claimed that “most” of the Forest’s grazing allotments have undergone a NEPA analysis through a “public” process. But many, if not most, of those environmental assessments are 30 and 40 years old, and back then government employees and grazing permittees were usually the only “public” participants in their completions. Furthermore, older assessments are obsolete because they did’t consider current issues, such as endangered species, or the ongoing megadrought in the Southwest, and the proliferation of massive wildfires, due to ongoing climate change. 

Reavis-Tortilla Allotment – On March 4, 2025, the Forest Service’s response to Freedom of Information Act (FOIA) request #2025-FS-WO-03917-F revealed that a grazing permit had been secretly issued for the Tonto’s long-vacant Reavis-Tortilla grazing allotment, located in the arid Superstition Wilderness. The allotment hadn’t been grazed since at least 1994, when the permit was cancelled for permittee non-compliance. An EA was subsequently completed for the allotment and a decision notice to resume grazing was issued on July 31, 1996. Several appeals were filed, so on October 4, 1996, the decision was withdrawn. In his withdrawal letter, Mesa District Ranger Arthur Wirtz explained that further analysis was needed before any decisions were made for the allotment. His letter also stated that, “When any future decisions are made regarding livestock management on the Reavis and Tortilla Study Area, they will be available for public review and appeal.” That promise wasn’t kept.

During a phone call on April 21, the Tonto’s range program manager Chandler Mundy said that the Reavis-Tortilla allotment had been used as a forage reserve by one of the forest’s permittees affected by the 2021 Telegraph Fire. (The Reavis-Tortilla allotment had burned just two years earlier in the 2019 Woodbury Fire.) Mundy claimed the permittee had paid to have some of the allotment’s fences rebuilt, and was then issued a regular grazing permit for the allotment based upon a 1990 allotment management plan (AMP). In a May 8 email Mundy added that the Mesa Ranger District was considering an MRAF wilderness exemption to allow the permittee to bring more ranching infrastructure materials in by helicopter because the “cherry stem” Forest Road 213 into the allotment from State Route 88, the Apache Trail, is very rough.  

The new permittee for the Reavis-Tortilla allotment is the Stud Camp Ranch LLC. One of this LLC’s owners is Page Land & Cattle Co., which is the permittee for the Jones grazing allotment, located in the forest’s Globe Ranger District. It’s one of the allotments that burned in the Telegraph Fire. The Jones allotment’s 2021 AOI, which was issued before the fire, authorized 94 cattle yearlong, or about 1,128 animal unit months (AUMS). The allotment’s 2022 AOI, the first one issued after the fire, authorized 138 cattle for 4 months, or about 552 animal unit months (AUMS). The AOI didn’t mention the need for use of the Reavis-Tortilla allotment for relief purposes. (A FOIA request has been submitted to find out how many cattle were authorized to use the allotment as a forage reserve before the new permit was issued.) The 2024 AOI for the Reavis-Tortilla allotment authorized 435 yearlings for 5.5 months, or about 1,794 AUMS.

The table below shows that amounts of government assistance that have benefited the Jone’s allotment’s permittee:

Bull Springs Allotment – On March 26, 2025, Tonto National Forest officials revealed that a new grazing permit had been issued for the Bull Springs allotment, located in the Mazatzal Wilderness, and that grazing had been authorized to resume, despite the fact its livestock management infrastructure was in disrepair, and the allotment’s most recent EA was completed in 1989.

On April 21, 2025, it was learned that Tonto National Forest Supervisor Neil Bosworth planned to retire on April 25, 2025, and his replacement would be Rachel Smith, Research Supervisor of the Forest Service’s Pacific Southwest Research Station. Bosworth replaced Gene Blankenbaker as the Tonto’s supervisor in 2012.