Public Land Grazing Was Increased During Ongoing Megadrought

Government agencies have quietly distributed large subsidies that increased livestock grazing on public land in the Desert Southwest during the ongoing long-term megadrought.

The recent history of livestock management on Arizona’s Tonto National Forest is an example. The Tonto includes about 2,964,308 acres of public land, and despite being called a forest, about 27% of  it, or 791,284 acres, is hot and rugged Sonoran Desert. From 2000 to 2002, toward the beginning of the ongoing drought, the Tonto ordered its grazing permittees to remove almost all of their cattle from the Forest. (By 2002 Arizona had experienced two of the driest winters on record, back-to-back, and six of the previous seven winters had brought below-normal precipitation.) The common sense decision to remove the cattle helped protect the Forest’s publicly owned natural resources, which include the watersheds of five large surface water reservoirs that help supply the City of Phoenix.

Most of the Tonto is in Gila County, so the removals affected most members of the Gila County Cattle Growers Association (GCCGA), although the drought would have forced them to drastically reduce their herds anyway. It also resulted in the cancellation of their annual county cattle auction. The removals, however, barely caused a blip in the county’s overall economy.

But the GCCGA took advantage of the disproportionate political influence of public land ranchers to help persuade Congress to add a provision to the 2002 Farm Bill that made it possible for public land ranchers to receive financial assistance from the USDA’s Environmental Quality Incentives Program (EQIP). This resulted in the Tonto National Forest EQIP Pilot Project, which issued the first EQIP contracts to public land ranchers in the country in 2004. The USDA’s Natural Resources Conservation Service (NRCS) awarded more than $1.5 million in EQIP assistance to Tonto ranchers that year. The ranchers used much of it to help build new livestock watering sites on the Forest. Since then, EQIP assistance for public land ranchers in Arizona, and across the West, has grown to many millions of dollars annually.

The State of Arizona also provided a new financial assistance program for public land ranchers during this time. In 2003 the Arizona Legislature created the Livestock & Crop Conservation Grant Program (LCCGP) which gave priority to grant requests submitted by public land ranchers. One of the program’s intended purposes, in fact, was to provide the ranchers with the matching funds they needed in order to qualify for EQIP assistance.

Subsequently, the Tonto National Forest signed a memorandum of understanding (MOU) in 2004 with the Arizona Cattle Growers’ Association and Gila County Cattle Growers Association that outlined an agreed upon “Restocking Process.” In other words, the removal of cattle would no longer be the Forest’s primary drought management strategy. Since then, millions of dollars in government financial assistance has been awarded to Tonto ranchers to help them build ranching infrastructure on public land, such as fences and livestock waters. (The MOU, by the way, may be evidence that the Forest Service violated the Federal Advisory Committee Act by making a private agreement with the rancher groups.)

The Salt River 6 Grazing Allotments

There are many grazing allotments on the Tonto where government assistance recently helped increase authorized livestock numbers. The stories of the six grazing grazing allotments located along the Salt River upstream from Theodore Roosevelt Lake are good examples. They are the Chrysotile, Dagger, Haystack Butte, Hicks-Pikes Peak, Poison Springs/Sierra Ancha, and Sedow allotments – the Salt River 6.

Roosevelt Lake
View of Theodore Roosevelt Lake from Tonto National Monument, Arizona (Jeff Burgess)

The tables below show the government assistance distributed since 2002 to the ranches which grazed these six allotments. This type of data is difficult to collect, even though it’s public information, and there was likely more, so these are at least the amounts that were awarded.

Government Assistance Program Key
AALB - Arizona Livestock Loss Board, Arizona Livestock Loss Board (federal/state)
AWPF - Arizona Water Protection Fund, AWPF Commission (state)
EQIP - Environmental Quality Incentives Program, USDA’s Natural Resources Conservation Service (federal)
The EQIP program absorbed the Wildlife Habitat Incentives Program (WHIP) after 2014.
HPC - Habitat Partnership Committee, Arizona Game & Fish Commission (state)
Arizona Heritage Fund, Arizona Game & Fish Commission (state)
LCCGP - Livestock & Crop Conservation Program, Arizona Department of Agriculture (state)
Note: Open Space Reserve Grants became LCCGP Grants after 2002.
LFP - Livestock Forage Disaster Program, USDA’s Farm Service Agency (federal)
LRP - Landowner Relations Program, Arizona Game & Fish Department (state)
PFWP - Partners for Fish & Wildlife Program, U.S. Fish & Wildlife Service (federal)
WQIG - Water Quality Improvement Grant, Arizona Department of Environmental Quality (federal/state)
Note: These grants were previously called Section 319 nonpoint source (NPS) water pollution prevention grants.
Griffin Cattle RanchM Bar K RanchO Bar O RanchRafter Cross RanchRafter P RanchRockin Four Ranch
Griffin Cattle Ranch (Griffin Cattle Ranch LLC) - Sedow Allotment
2002OSR #58*$33,729
2005LCCGP #05-44$100,000Livestock Water and Fencing
2007LCCGP #07-34$100,000Livestock Water and Fencing
2009LCCGP #09-45$75,000Restoration-Conservation-Resource Enhancement
2011LCCGP #11-26$77,332Fencing, Grassland Restoration, Livestock Water
$1,159,431TOTAL 2002 - 2021
* Open Space Reserve (OSR) grants became LCCGP grants in 2005.
The current allotment management plan was completed in 1979.
M Bar K Ranch (M Bar K Cattle Co., LLC) - Chrysotile Allotment
2002OSR #13*$77,350
2007LCCGP #07-71$125,000Livestock Water and Fencing
2009LCCGP #09-85$100,000Livestock Water and Fencing
2011LCCGP #11-54$125,000Livestock Water and Erosion Control
$823,029TOTAL 2002 - 2021
* This assistance was received by the ranch’s previous owner, Howard J. “Pinky” Norris. Open Space Reserve (OSR) grants became LCCGP grants in 2005.
The current allotment management plan (AMP) was completed in 1984.
O Bar O Ranch (Rugged Edge Cattle Co., LLC) - Dagger Allotment
2011LCCGP #11-69*$125,000Open Space Conservation Project
$471,349TOTAL 2011 - 2021
* This assistance was received by the ranch's previous owners, John & Sarah Sowers. The ranch was sold to Joshua J. Roundy in 2015 and he began managing it in 2016.
Grazing was reauthorized on the allotment in 2010 after many years of nonuse. The current allotment management plan (AMP) was completed in 1981.
Rafter Cross Ranch (J Bar B Cattle Co. LLP) - Campaign, Poison Springs and Wildcat Allotments
1992BOR$73,9801992 AMP for Campaign allotment
2006Heritage Fund$10,000Campaign Creek Riparian Fence
2006 - 2012EQIP$207,575Campaign allotment $133,096
Wildcat allotment $74,479
2011 - 2015LFP$198,402Campaign allotment $142,264
Wildcat allotment $56,138
$489,957TOTAL 1992-2015
The Campaign and Poison Springs allotments are in the Tonto National Forest, and the Wildcat allotment is in the Apache-Sitgreaves National Forest. The Poison Springs allotment was reauthorized for grazing in 2017 after many years of nonuse. The current allotment management plan (AMP) for the Poison Springs allotment was completed in 1987. The Campaign allotment’s current AMP was authorized in 2011. The previous 1992 AMP was funded by a grant from the U.S. Bureau of Reclamation as part of a mitigation plan for the local wildlife habitat flooded after the height of Theodore Roosevelt Dam was increased.
Rafter P Ranch (Rafter P Ranch LLC) - Haystack Butte Allotment
2011LCCGP #11-67*$100,000Allotment Improvements
2018LRP$12,000Rafter P Ranch Dirt Tank Improvements
2019HPC #18-605$50,000Livestock Water
$678,681TOTAL 2007 - 2021
* This assistance was received by the ranch's previous owner Joshua D. Smart.
The current allotment management plan was completed in 1982.
Rockin Four Ranch (Rockin Four Ranch LLC) - Hicks-Pikes Peak Allotment
2008 - 2019EQIP$231,089 
$353,194TOTAL 2008-2019
The current allotment management plan was completed in 1992.

The following table shows how this government assistance, which totaled more than $3.5 million, helped to increase the number of authorized cattle on these allotments as they were restocked after 2002 during the drought. The overall increase from the initial restockings to the 2020 authorized stockings was about 529%.

Grazing Allotment Initial ReauthorizationsSubsequent Authorizations2020 Authorizations
Chrysotile2006: 65 cows410 cows
Dagger2010: 33 cows2016: 165 cows180 cows
Haystack Butte2003: 40 cows2016: 250 cows250 cows
Hicks-Pikes Peak2004: 130 cows2008: 310 cows110 cows
Poison Springs/Sierra Ancha2010: 4 cows2017: 125 cows115 cows
Sedow2004: 15 horses2016: 725 cows375 cows
Totals272 cows1,440 cows

The new livestock management plans facilitated by these funds were implemented with little use of the NEPA public planning process, even though the existing allotment management plans (AMPs) were obsolete. The one exception was when the Forest conducted a NEPA analysis and issued a decision in 2005 to implement a new AMP for the Hicks-Pikes Peak allotment. But that decision was reversed in response to an appeal filed by Forest Guardians. Then, in 2011 the Tonto announced the start of the Salt River Allotments Vegetative Management project.

2013 Salt River Allotments Vegetative Management Project Draft EIS

The ranchers holding the grazing permits for the Salt River 6 allotments were already upset before their cattle were ordered off the Forest due to the drought. That was because during the latter part of the 1990s the desert riparian habitat along the river, and its perennial tributaries, had been excluded from grazing in order to comply with the Endangered Species Act. The permittees for the Poison Springs/Sierra Ancha and Dagger allotments were so resistant to new grazing restrictions that the Tonto was forced to suspend their grazing privileges for noncompliance.

The Salt River Allotments Vegetative Management  project was the Tonto’s response to pressure from the permittees of these six allotments to get the Forest to complete the NEPA process so they could obtain authorizations to resume grazing along the river. However, when the Tonto released the project’s Draft Environmental Impact Statement (DEIS) in early 2013, the proposed preferred alternative only allowed grazing in the river pastures during the cool season, from November 15th to February 15th, in order to maintain compliance with the Endangered Species Act.

But that wasn’t what the ranchers wanted, so in February of 2015 the Tonto announced they were retracting the DEIS. Their notice explained, “through discussions with term-grazing permittees, it was determined that if livestock were allowed to graze along river that neither Forest Service nor term-grazing permittees had time or money to conduct monitoring necessary to determine appropriateness of this proposed action along river corridor.”

The retraction added that the Forest would continue with the implementation of new livestock management on the allotments and that, “project planning will continue through an EA process.”

But range “improvement” projects on the Salt River 6 allotments continued to be approved on a piecemeal basis, as they were before the 2013 DEIS. In effect, expensive new allotment management plans were implemented without NEPA reviews. The table below shows the administrative history of the allotments since 2002, and illustrates that almost all of the significant livestock management decisions were made using NEPA categorical exclusions, grazing permit modifications and “trial” cattle number increases, or through annual operating instructions. The only environmental assessments (EAs) which were issued were for the 2012 Miner’s Camp Pipeline & Storm Canyon Fence and the 2018 Sedow & Haystack Butte Allotments Range Improvements projects.

Dagger AllotmentChrysotile AllotmentHaystack Butte AllotmentHicks-Pikes Peak AllotmentPoison Springs AllotmentSedow Allotment
History Of Dagger Allotment Since 2002
NEPA Analysis ConductedNEPA Categorical Exclusion or No Public Notice
2009 Grazing Permit Modification
Grazing authorized to resume in 2010 with a new permittee after several years of nonuse
2009 Grazing Permit Modification
Three pastures from the adjacent Poison Springs allotment were transferred to the Dagger allotment
2010 Annual Operating Insructions (AOI)
2011 Devore Pipeline Extension
2013 Draft EIS - no decision
2015 Grazing Permit Modification
2016 Annual Operating Instructions (AOI)
2017 Annual Operating Instructions (AOI)
2020 Annual Operating Instructions (AOI)
History Of Poison Springs Allotment Since 2002
NEPA Analysis ConductedNEPA Categorical Exclusion or No Public Notice
2009 Grazing Permit Modification
  • Grazing authorized to resume in 2010 with a new permittee after several years of nonuse
  • Three of the allotment's pastures were transferred to the adjacent Dagger allotment
  • Pastures south of Salt River placed in nonuse until completion of NEPA
2010 Annual Operating Instructions (AOI)
2013 Draft EIS - no decision
2016 Memorandum of Understanding
2017 Grazing Permit Modification
Pastures north of Salt River removed to create new Black Mesa Allotment.
2017 Annual Operating Instructions (AOI)
2017 Klondyke Water System
2020 Annual Operating Instructions
2020 Poison Springs Structural Range Improvements

Thus the enormous public investments that were made in these ranches occurred with minimal public notice. In fact, it appears the Forest was trying minimize the general public’s involvement because a 2019 Habitat Partnership Committee grant application for a controversial livestock water project on the Tonto’s Cartwright grazing allotment revealed that the Forest held a private “emergency drought CE (categorical exclusion) meeting for water projects” with its grazing permittees.

History Of The Poison Springs Allotment

There’s no better example of how the Tonto has been making important livestock management decisions behind the scenes than the recent history of the Poison Springs allotment. As previously mentioned, the current AMP for the Poison Springs allotment was completed in 1987. At that time it was a stand alone allotment of about 31,275 acres. But in the 1990s it was combined with the adjacent Sierra Ancha allotment to the north and became part of a larger new allotment called the Poison Springs/Sierra Ancha allotment.

According to a 2007 biological assessment that the Tonto National Forest submitted to the U.S. Fish & Wildlife Service, the combined Poison Springs/Sierra Ancha allotment contained 63,655 acres and was permitted for up to 1,224 animal unit months (AUMs), which equated to 102 cows yearlong.

However, when grazing was authorized to resume on the allotment in 2010, the permit had been increased to a maximum of 112 cows, or 1,344 AUMs. And this was after three of the allotment’s pastures had been transferred to the adjacent Dagger allotment to the east. Furthermore, the allotment’s seven pastures located south of the Salt River were placed in nonuse status “until completion of an Environmental Assessment.” Henceforth, the allotment was simply called the Poison Springs allotment.

Poison Springs Allotment pasturemap, 2013
Poison Springs Grazing Allotment pasture map (2013 Tonto National Forest DEIS for Salt River Allotments)

The preferred alternative in the subsequent 2013 DEIS proposed to dramatically increase livestock numbers on the Poison Springs allotment. It would have authorized up to 225 cows yearlong in the pastures south of the Salt River, and up to 250 steers yearlong in the pastures north of the river. This equated to 5,700 AUMs, about a 424% increase! As mentioned earlier, however, the DEIS was retracted.

A permit modification in 2016 confirmed that the allotment was still only permitted for 112 cows, but only 14 head were authorized, while the other 98 head were in nonuse status for resource protection because of the lack of water availability and poor maintenance of existing range improvements.

Then on January 6, 2017, the allotment was split between its pastures north of the Salt River and those south of the river. The pastures north of the river became the new Black Mesa allotment. The pastures south of the river, comprised mostly of Sonoran Desert, became the revised version of the Poison Springs allotment. The new Black Mesa allotment was permitted for 108 head, while the revised Poison Springs allotment was permitted for 4 head. That maintained the previous total combined permitted number of 112 head. (The newly created Black Mesa allotment, however, was only authorized for 8 head in 2017.)

But on January 23, 2017, a permit modification was issued for the new Poison Springs allotment that increased the permitted numbers to 125 cows yearlong, despite the fact that it had become much smaller and only two of its remaining pastures were authorized for grazing. In September the Tonto issued a NEPA categorical exclusion decision memo that approved the construction of a new livestock water to add the allotment’s Klondike pasture to the grazing rotation.

At this same time the Tonto was in the process of updating its forest plan, and in  November, 2017, it released a Preliminary Proposed Land & Resource Management Plan (LRMP) for public comment. It included a grazing management proposal on page 89 which would have applied to the Poison Springs allotment, which stated:

“Allotments comprised of large percentages of Desert Ecological Response Units (Sonora-Mojave 25 Mixed Salt Desert Scrub, Sonoran Paloverde-Mixed Cactus Desert Scrub, and Sonoran Mid-26 Elevation Desert Scrub) should be closed, in whole or in part, as they become vacant.”

This proposal, however, had been deleted when the Tonto released its Draft LRMP in December 2019. Instead, the draft plan said that vacant allotments would be evaluated to determine the appropriate option. This change was likely in response to political pressure from ranchers, including the Gila County Cattle Growers Association.

In 2020 the annual operating instructions for the Poison Springs allotment showed that another one of the unused pastures had been added to the rotation, and in May another CE memo was issued to approve four range improvement projects on the allotment.

All of these changes were made administratively, without any NEPA analysis, during a long-term drought, for an allotment that’s mostly Sonoran Desert and had an AMP that was completed over 30 years ago, with several pastures transferred to another allotment since then.

The Government Money Just Keeps Flowing

In 2008 Congress responded to growing requests from Western ranchers for drought assistance by creating the Livestock Forage Disaster Program (LFP). The LFP is administered by the USDA’s Farm Service Agency (FSA) and provides financial assistance to ranchers when the U.S. Drought Monitor declares that a region is drought stricken, even if the area is desert. Ranchers who cannot graze their public land allotments as the result of wildfires are also eligible for LFP payments.

The continuing drought has resulted in millions of dollars in LFP payments to Arizona ranchers, and many other ranchers across the West. Sometimes these ranchers have received LFP assistance during the same years they received EQIP. For example, the tables above that list the government assistance which benefited the Salt River 6 ranches show that four of them received EQIP and LFP during the same years.

And there’s little doubt that the Tonto’s strategy for managing livestock grazing during the ongoing drought will continue to emphasize the use of government subsidies. On May 3, 2018, Forest Supervisor Neil Bosworth sent a letter to permittees about the Forest’s drought strategy and promised that, “my staff will focus efforts to approve critical range infrastructure needed to utilize available forage.” And a subsequent email to a permittee from the Tonto’s Globe Ranger District on May 14 showed that he meant it.

Moreover, in September 2020 the Arizona Silver Belt newspaper in Globe reported on a meeting of the Gila County Cattle Growers Association wherein the ranchers discussed the problems they were dealing with because of the wildfires that had burned about 288,000 acres of land in county during 2020 – most of it on the Tonto. (Bigger and more frequent wildfires in the Southwest are another product of drought and climate change.) It was reported that the Forest’s Range Program Manager Chandler Mundy told them that the Tonto had requested  $543,000 in Burned Area Emergency Response (BAER) funds to acquire ranching infrastructure materials like fencing and pipeline, to help replace those that had burned. A representative from the NRCS was also in attendance and encouraged the ranchers to apply for more EQIP assistance. And a representative from the FSA encouraged them to apply for more LFP, along with the Emergency Conservation Program, and the Livestock Indemnity Program.

How Much Will Taxpayers Have To Pay?

The under-the-radar livestock management decisions that facilitated the investment of millions in government assistance for the Salt River 6 ranches wasn’t a unique occurence – it was the norm. Many other ranches on the Tonto also received large amounts of government assistance during the ongoing drought with little public notice. During this time the Forest even authorized grazing to resume on some areas that hadn’t been grazed in many years, including the Bar X Ranch , Cartwright Ranch , and Circle Bar Ranch .

The negative impact these increased cattle numbers inflicted upon local wildlife habitat during the drought can be partially understood by comparing cattle and wildlife AUMs, as an AUM estimates how much forage a grazing animal eats in a month. For example, a cow grazing for a month equals 1.0 AUM, while an elk is only 0.6 AUM, a mule deer only 0.20 AUM, and a white-tailed deer only 0.15 AUM. In other words, one cow has the same impact as five mule deer.

And this situation certainly wasn’t unique to the Tonto National Forest. It was the same on public land all across Arizona and much of the West. It’s exacerbated by the fact that there are no needs tests for these government assistance programs. Even wealthy ranchers are eligible for them. For example, the table below shows that Bar T Bar Ranch, Inc., which holds the permit for the Coconino National Forest’s Bar T Bar grazing allotment, benefited from a lot of government assistance while in 2012 it was able to purchase another ranch, the Black Rock Ranch, for $1,228,920. (It included the Bureau of Land Management (BLM) Flying Butte allotment and Arizona state grazing lease #05-000305.)

Bar T Bar Ranch (Bar T Bar Ranch, Inc.) - Bar T Bar (FS) and Flying Butte (BLM) Allotments, State Leases #05-001339, #05-000305
2005LRP*$285,000Juniper Removal
2005LCCGP #05-81$150,000Grassland Restoration & Livestock Water
2011HPC #10-203$24,000Prescribed Burns To Kill Juniper Trees
2014HPC #13-204$32,000Quayle Hill Grassland Restoration (Cut Down Juniper Trees.)
2015HPC #14-214$5,349Drinker Replacements
2017HPC #16-211$31,920Quayle Hill Grassland Restoration (Cut Down Juniper Trees.)
$3,268,688TOTAL 2005 - 2021

* This was shared with the Flying M Ranch , the other member of the Diablo Trust.
WHIP was absorbed by the EQIP program after 2013.

It’s obvious that, unless the situation changes, U.S. taxpayers will be on the hook for continually increasing amounts of government assistance to help public land ranchers as the megadrought in the Southwest likely continues and intensifies due to climate change. In fact, some scientists are no longer calling it a drought, but permanent aridification. This is especially egregious for a state like Arizona, which is mostly desert that’s inherently unsuited for livestock grazing. The U.S. Government Accountability Office (GAO) recognized this in 1991 when it issued a report (RCED-92-12) that analyzed the BLM’s permitting of livestock grazing on desert public land. The GAO concluded that, “the lands we visited provided enough evidence of the high environmental risk and low economic benefit associated with livestock grazing in America’s hot deserts for us to conclude that the program as currently conducted merits reconsideration.”

But that didn’t stop the Arizona BLM from issuing a decision in September, 2020, to allow livestock grazing on the northern portion of the Sonoran Desert National Monument. When Pres. Bill Clinton created the monument in 2001, his proclamation included a clause which stated that livestock grazing within the monument north of Interstate 8:

“Shall be allowed to continue only to the extent that the Bureau of Land Management determines that grazing is compatible with the paramount purpose of protecting the objects identified in this proclamation.”

Donald Trump’s BLM, of course, decided that it was.

The absurdity of the federal government’s current drought strategy for managing livestock grazing on public lands in the arid West is highlighted by the fact that public ranchers are simultaneously receiving EQIP to maintain grazing and LFP because it’s not sustainable. It’s time for Congress to stop throwing good money after bad by reducing subsidies for public land ranchers. They can start by raising the public land grazing fee to the market rate, as the federal fee was only $1.35 per cow per month in 2020. Furthermore, they should allocate money to a fund that would be used to fairly compensate ranchers who are willing to voluntarily relinquish their grazing permits so their allotments can be permanently retired. And in the meantime, federal land managers should stop initiating grazing on unused pastures and allotments.


On January 21, 2021, the Tonto National Forest Supervisor issued a letter to the Forest’s grazing permittees wherein he acknowledged the growing severity of the drought, but promised them, “I commit to not requiring removal of all cattle from the Tonto Forest as a forest-wide decision.”

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