Ranchers Want To Graze More Of Arid Tonto National Forest

The newly revised land management plan (LMP) for the Tonto National Forest 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.) Most of them include federal wilderness, including much of the Superstition Wilderness and Mazatzal Wilderness areas. And they all include some hot desert, since the Tonto National Forest includes about 791,284 acres of Sonoran Desert.

The draft decision for the revised LMP was released in March 2022, and generated several objections. 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 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.

When the Tonto finalized their revised LMP in December 2023, however, their final decision didn’t mention this specific issue. Instead, it included 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 39 years ago. Since then, there have been many changes which render them obsolete.

Other Vacant Grazing Allotments

The Bull Springs allotment located in the 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 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.

In 2020 the enormous Bush Fire burned much of the Mesa Ranger District’s Sunflower allotment. This mostly-desert allotment is located 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 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 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 Cave Creek Ranger District. 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 was necessary to “maintain a viable ranching operation.”

There were no public notifications that grazing was being initiated on these allotments and pastures. Keep in mind that the Forest authorized grazing on these allotments during an almost uninterrupted period of drought that has lasted more than 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.

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.) And, if a NEPA project for a vacant allotment gets listed, be sure to submit comments which point out that converting a vacant allotment into a “forage reserve” means the initiation of livestock grazing, and more public investments in ranching infrastructure.

Also, it could help to send emails to Tonto National Forest Supervisor Neil Bosworth and his Range Program Manager Chandler Mundy to let them know you are concerned about this issue.