Tonto National Forest Is Secretly Initiating Grazing On Long-Vacant Allotments

Arizona’s Tonto National Forest has been secretly initiating cattle grazing on long-vacant grazing allotments in wilderness areas, despite a megadrought and the ongoing aridification of the desert Southwest. These decisions were of questionable legality because they were based upon obsolete National Environmental Policy Act (NEPA) environmental assessments (EAs). The most egregious example is the recent authorization of grazing on the Reavis-Tortilla allotment.

Reavis-Tortilla Grazing Allotment

On January 9, 2024, the Tonto National Forest’s Mesa Ranger District secretly issued a new grazing permit for the long-vacant Reavis-Tortilla grazing allotment, located in the arid and rugged Superstition Wilderness. The allotment hadn’t been grazed since at least 1994, when the permit was cancelled due to permittee non-compliance.

The re-authorization of grazing on the allotment was revealed in early 2025 by a Forest Service response to a Freedom of Information Act (FOIA) request about a different topic. Many Arizona conservationists were concerned about it, especially those who remembered that the forest had completed an environmental assessment (EA) of the allotment in 1996, which was accompanied by a decision to issue a new grazing permit, and then the district ranger had withdrawn the decision due to an appeal.

According to subsequent communications with Chandler Mundy, the Tonto’s range program manager, the Reavis-Tortilla allotment had been initially authorized for cattle grazing in the winter of 2021/2022, as an emergency forage reserve for a grazing permittee in the Globe Ranger District that was adversely affected by the 2021 Telegraph Fire. (The Reavis-Tortilla allotment had burned just two years earlier in the 2019 Woodbury Fire.)

That permittee was the Page Land & Cattle Co., which held the grazing permit for the Globe Ranger District’s Jones allotment. It’s also one of the owners of Stud Camp Ranch LLC, the new permittee for the Reavis-Tortilla allotment. The Mesa Ranger District authorized the emergency grazing on the Reavis-Tortilla allotment by issuing a modified annual operating instructions (AOI) for the Jones allotment. This modified 2021 AOI  was issued in early November, 2021, and authorized 150 cattle to graze on the Reavis-Tortilla allotment from November through June 15, 2022. The Jones allotment’s original 2021 AOI, issued in January, before the fire, showed that the allotment had been authorized for 94 cattle and 17 bulls yearlong.

It was otherwise later discovered that after the emergency grazing had already started, the Mesa Ranger District completed an allotment inspection report at the beginning of 2022 which found the Reavis-Tortilla allotment had “major potential for grazing,” so the process of issuing of a new regular grazing permit for the allotment was already in motion.

Mundy also mentioned there had been a complication issuing the new grazing permit because of the requirement to identify a private base property for using the allotment. That’s because the base properties for the old Reavis and Tortilla ranches had been acquired by the Forest Service many years ago. Most of the ranching infrastructure had been removed or allowed to decay because it was presumed the allotment wouldn’t be grazed again. So, on November 29, 2023, the Page Cattle Co. quit claimed a parcel of land near its ranch base property in the Globe Ranger District to Stud Camp Ranch LLC, and this became the base property for the Reavis-Tortilla allotment, even though it’s about 45 miles away.

Mundy said that the Reavis-Tortilla allotment’s new permittees paid to have some of the fences rebuilt, and after a NEPA review, they were issued a regular grazing permit based upon the allotment’s 1985 EA/Decision Notice and 1990 allotment management plan (AMP). The new permit authorized up to 1800 yearlings for 7 months, as had the 1985 decision. However, due to the ongoing drought, the allotment’s initial AOI authorized only 435 yearlings for 5.5 months.

During an April 2025 visit to the allotment there were new boundary fences, but it’s unknown if they were rebuilt in their original locations. No interior pasture fences were seen. Furthermore, government assistance may have made it easier for the Reavis-Tortilla allotment’s permittees to pay for building the fences. One of the permittee’s owners, Page Land & Cattle Co., had benefited from two Arizona Post-Wildfire Infrastructure Assistance Program (APWIAP) grants to rebuild livestock fences burned on the Jones allotment in the 2021 Telegraph Fire. They were APWIAP grant #21-806 for $453,905 in 2022, and APWIAP grant #21-828 in 2023 for $98,600 – for a total of $583,523. The Jones  allotment was also one the Tonto allotments which benefited from $2.325 million in federal Burned Area Emergency Response (BAER) funds allocated to rebuild livestock fences burned by the Telegraph fire in the Globe Ranger District.

Mundy also revealed that the Mesa Ranger District was considering an MRAF wilderness exemption to allow the permittees to bring in more ranching infrastructure materials by helicopter because the wilderness “cherry stem” Forest Road 213 into the northern portion of the Reavis-Tortilla allotment from State Route 88, the Apache Trail, is very rough. This information prompted a letter of concern in June 2025 from the Wilderness Watch conservation organization regarding the potential illegality of allowing helicopter flights into the Superstition Wilderness.

But there was still the big question of why the Mesa Ranger District had authorized grazing based upon their 1985 EA and 1990 AMP, instead of the more recent and thorough 1996 EA. So in May of 2025 a FOIA request was submitted to the Forest Service asking for a copy of the allotment’s 1996 EA and decision notice. The FOIA response received later that month from Southwestern Regional Forester Michiko Martin was a boilerplate statement which said, “Staff members searched in every place where a reasonably knowledgeable professional could expect to find records pertaining to your request.”

Her FOIA response letter also explained that the only requested record they could find was a copy of the October 4, 1996, decision withdrawal for the allotment issued by Mesa District Ranger Arthur Wirtz.

His decision withdrawal letter stated that further analysis was needed before any decisions were made for the allotment, and it promised 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.

The fact that the Forest Service said it couldn’t find a document as important as the 1996 EA was disturbing, but in March 2025 the Mesa Ranger District had rescinded the Reavis-Tortilla allotment’s 2024-2025 AOI due to severe drought and put the allotment in nonuse status for resource protection, so there was a possibility that grazing wouldn’t soon be reauthorized.

On November 21, 2025, Western Watersheds Project sent a follow up letter, cosigned by the Sierra Club Grand Canyon Chapter and Wilderness Watch, to the Tonto National Forest regarding their failure to respond to a June 17 letter of concern regarding the status of the Reavis-Tortilla grazing allotment. Acting Tonto National Forest Supervisor Ericka Luna issued a response letter on January 22, 2026, wherein she tried to justify the decision to graze the allotment. She also revealed that grazing had been authorized on the allotment again for the 2025-2026 grazing season for 600 yearlings for 6 months.

In early 2026, however, there was some good news, because paper copies of the Reavis-Tortilla allotment’s 1996 EA and accompanying July 30, 1996, decision notice were found in the archives of Arizona conservationist Don Steuter. The archived documents also included the project’s 1994 NEPA scoping letter, which stated that a new EA was being completed because the 1985 EA was, “was no longer adequate to address the current issues.” Furthermore, the Purpose and Need statement of the 1996 EA explained that:

“Examination of previous NEPA documentation, management plans, and analysis reports showed that these documents did not adequately address the current issues involved with issuing a new term grazing permit on these allotments.”

Alternative 6, was the preferred alternative in the 1996 EA, and it was the one selected in the decision. It would have allowed only 5oo adult cattle to graze the allotment from November through April each year. That would have amounted to about 3,000 animal unit months (AUMs), which is significantly less than the approximately 7,560 AUMs allowed in the Reavis-Tortilla allotment’s new permit. Also, the grazing season would have only been for 6 months, instead of the 8 allowed in the permit, and it wouldn’t have allowed grazing in the problematic growing season months of May and June. Furthermore, it required that grazed areas had to be rested at least one year of every two years of use, and the permittee was required to repair of lots of livestock fences and waters. The fact that the decision to implement Alternative 6 was withdrawn a couple of months later doesn’t invalidate the EA’s analysis and findings, especially when the previous grazing system, the one  the new grazing permit is based upon, had been deemed insufficient.

Moreover, the Mesa Ranger District wasn’t legally required to approve the application for the new grazing permit for the Reavis-Tortilla allotment. In 1992, for example, an application to issue a grazing permit for the adjacent and vacant Superstition grazing allotment was denied. The denial letter from Forest Supervisor James Kimball explained that a large portion of the allotment was unsuited for grazing, and it was also a popular recreation area, so there would be “unacceptable conflicts between livestock and recreationists.” These same issues apply to the Reavis-Tortilla allotment.

The Reavis-Tortilla allotment isn’t the only recent example of the Tonto National Forest secretly authorizing grazing on a long-vacant grazing allotment.

Deadman Mesa Allotment

On March 27, 2025, the Tonto National Forest’s Payson Ranger District secretly issued modified 2025 annual operating instructions (AOI) to the H4 Ranch to authorize grazing on the long-vacant Deadman Mesa grazing allotment, which includes portions of the Mazatzal Wilderness. The allotment received a questionable NEPA categorical exclusion in 1987, followed by the completion of a 1988 AMP that allowed up to 175 cattle annually from October 21 through May 31, which equated to about 1,281 AUMs. The district’s modified AOI, however, arbitrarily increased the number of cattle to 215, plus 19 bulls. It slightly shortened grazing period, but still equated to about 1,685 AUMs, a more than a 30% increase during an ongoing drought. The AOI claimed that this increase, “lies within the permitted use and within the scope of the Allotment Management Plan.” But the permitted number is just 175 head, and the allotment’s 1988 AMP shows that 50 of those were in a “range protection nonuse agreement.”

In early 2020, the Arizona Game & Fish Department approved a couple of Habitat Partnership Committee (HPC) grants for projects on Deadman Mesa. They were HPC grant #19-610 for $500,000 for five years of juniper tree thinning, and grant #19-611 for $50,000 for dirt tank clean outs. The application for grant #19-610 stated:

It should be noted that Deadman Mesa has not been grazed in over 40 years and is currently not grazed or planned to be grazed. The allotment infrastructure is in such a state of disrepair that if the Forest were to open the allotment they would require a potential permittee to fix all the fences before the area could be stocked which is estimated to cost over one million dollars. The Deadman Mesa project has 100% benefit to wildlife.

During that same year, however, the Tonto had already started the process of authorizing grazing on the vacant Deadman Mesa allotment, according to the Forest’s 2024 biological assessment (BA) of the area.

Tonto Revised Land Management Plan

The authorizations to graze the long-vacant Reavis-Tortilla and Deadman Mesa grazing allotments were issued after the December 8, 2023, final decision for the Tonto National Forest’s Revised Land Management Plan (LMP). The future of the forest’s vacant grazing allotments was an issue throughout the entire LMP revision process, and 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.

When the Tonto released the revised 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 evaluating the future of vacant grazing allotments was raised during the first meeting, the Meeting Notes show that Tonto National Forest Supervisor Neil Bosworth admitted that NEPA analysis might be required.

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.

And page 15 of the subsequent final decision for the revised LMP prescribed that:

Site-specific analysis in compliance with the National Environmental Policy Act (NEPA), and other Federal laws and regulations, will need to be conducted in order for prohibitions or activities to be implemented, in compliance with the broader direction of the land management plan.

Another Forest Service Promise Broken

The Tonto National Forest’s failure to engage the NEPA public planning process wherein the public would be given an opportunity to submit comments on proposed alternatives before the initiation of grazing on vacant allotments is another broken promise. Furthermore, their use of obsolete EAs to justify new grazing is contradictory, because the primary reason they revised the forest’s LMP was their determination that the previous amended 1985 Forest Plan was obsolete. In fact, the revised LMP decision explained that:

Over 30 years have passed since the regional forester approved the original land management plan in 1985. These years have yielded new scientific information and understanding, and changes in economic, social, and ecological conditions, resulting in a shift in management emphasis from outputs to outcomes.

All of these things also apply to the forest’s vacant grazing allotments.

Status Of Tonto National Forest Long-Vacant Grazing Allotments In 2023

Ranger District	Allotment	Wilderness	Decision Notice	Environmental Assessment (EA)	Allotment Management Plan (AMP)	Other
Cave Creek	Bartlett		1982	1982	1982	2010 Non-Use Approval
Cave Creek	Bronco		1981	1981	1982	2010 Non-Use Approval
Globe	Brushiest	Superstition	1983	1983	1983	Grazing Permit Relinquished In 1999
Payson	Deadman Mesa	Mazatzal	Record Missing	1987 CE Memo	1988
Mesa	Reavis-Tortilla	Superstition	1985 1996	1985 1996	1990	Permit Cancelled in 1994 Withdrawal of 1996 Decision to Reauthorize Grazing
Cave Creek	St. Clair		Nothing since 1980	Nothing since 1980	Nothing since 1980	2010 Non-Use Approval
Cave Creek	Sears Club-Chalk Mtn.	Mazatzal	1985	1985	1985	2010 Non-Use Approval
Mesa	Superstition	Superstition	1985	1984	1985	Grazing Permit Relinquished in 1985 Grazing Permit Application Denied in 1992

Updates

On March 31, 2026, the Trump administration’s U.S. Bureau of Land Management (BLM) and Forest Service signed a memorandum of understanding (MOU) to promote more livestock grazing on federal public lands. It included a provision to try and initiate grazing on all vacant grazing allotments.