Why Is Livestock Grazing Still Permitted in Federal Wilderness Areas?

Most Americans don’t know that livestock grazing is allowed in wilderness areas on public lands, and if they find out, they are usually upset and want to know why – because it doesn’t make any sense.

The National Wilderness Preservation System was promoted by Pres. John F. Kennedy and subsequently created when Congress passed the Wilderness Act of 1964, which defined wilderness as “an area where the earth and community of life are untrammeled by man, where man himself is a visitor who does not remain” and “an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions.” The legislation also prohibited certain activities in wilderness areas, including no permanent roads and “no commercial enterprise.”

Livestock grazing, however, was allowed to continue “where established prior to the effective date of the Act” and “subject to such reasonable regulations as are deemed necessary.” Obviously, ranching is a commercial enterprise that is inherently contrary to the definition of wilderness, but ranchers had the political clout back then to prevent the creation of wilderness areas unless grazing was allowed to continue in them.

Since then, Congress has created many more wilderness areas on the nation’s public lands, including those created by the Arizona Wilderness Act of 1984 and the Arizona Desert Wilderness Act of 1990. Ranchers succeeded in having the protection of preexisting livestock grazing included in the laws that created the new wilderness areas too.

Consequently, the appropriate management of livestock grazing in wilderness areas has been an issue. Proposals for new wilderness areas in 1979 prompted the U.S House of Representatives to issue Report No. 96-617 that became the Congressional Wilderness Grazing Guidelines. They were referenced in U.S. House Report No. 101-405, that was produced in response to the proposed Arizona Desert Wilderness Act of 1990.

The congressional guidelines made it clear that grazing “established prior to the effective date” meant grazing that was ongoing the year a wilderness area was created. They also explained that:

• “It is anticipated that the number of livestock permitted to graze in wilderness would remain at the approximate levels at the time an area enters the wilderness system.”
• “The construction of new improvements should be primarily for the purpose of resource protection and the more effective management of these resources rather than to accommodate increased numbers of livestock.”

But these guidelines haven’t stopped attempts to increase grazing in wilderness areas. In September 2022, for example, the Globe Ranger District of the Tonto National Forest issued a draft decision for the Hicks-Pikes Peak grazing allotment, which includes a portion of the Salt River Canyon Wilderness, created by the Arizona Wilderness Act of 1984. (This upper stretch of the Salt River, above Roosevelt Lake, has also been deemed eligible for designation as a Wild & Scenic River.)

Livestock were excluded along the upper Salt River on the Tonto in the late 1990s in order to comply with the Endangered Species Act by protecting the river’s important Sonoran Desert riparian habitat. On the Hicks-Pikes Peak allotment, that meant no grazing in the allotment’s Ortega and Lower Shute Springs pastures, which border the river in the wilderness.

The 2022 draft decision for the allotment would have implemented the Proposed Action Alternative described in the accompanying environmental assessment (EA), which would have facilitated the resumption of grazing in these pastures by constructing miles of new livestock fences along the river. The fence proposed for the Lower Shute Springs pastures, for example, would have been almost five miles long. The decision would have also authorized the construction of numerous other new ranching infrastructure projects in the pastures.

Moreover, it would have authorized a maximum of 650 to 800 adult cattle to graze the allotment yearlong, along with up to 700 to 1100 yearlings for seven months. That would have translated to up to about 14,220 animal unit months (AUMs) per year. The allotment’s 2022 EA didn’t identify the number cattle that were grazing the allotment in 1984, when the Salt River wilderness was created. However, there’s a 1992 allotment management plan (AMP) that’s technically still in effect because the Globe Ranger District has failed several times to approve a new one. It states that the authorized use of the allotment then was 1,000 adult cattle yearlong, or 12,000 AUMs – about 19% less than what was in the 2022 draft decision.

Fortunately, the Tonto National Forest withdrew the 2022 draft decision for the Hicks-Pikes Peak allotment on January 6, 2023, in response to objections filed by conservationists. The withdrawal notifications explained that a new and better EA should be drafted for the allotment. As of April 2024, however, the project still wasn’t listed on the Tonto’s schedule of proposed actions (SOPA).

Grazing Permit Retirements Are An Equitable Solution

Congress should finally end the tyranny of the minority they gave to ranchers in 1964 by passing legislation to eliminate livestock grazing in wilderness areas. There are a variety of ways to accomplish it. First of all, grazing should be permanently prohibited on any currently vacant grazing allotments located in wilderness areas. Allotments stay vacant for a reason – usually because they wouldn’t be profitable enough to graze. But vacant allotments are still legally vulnerable to the reauthorization of grazing, so a ban is required.

Also, grazing permits for active allotments in wilderness areas should not be renewed when they expire. (A standard grazing permit has a 10-year term.) This phase out strategy was used by Congress when they passed the Capitol Reef National Park Act of 1971, where in existing grazing permits were scheduled for eventual retirement. Congress used another retirement strategy when it passed the California Desert Protection Act of 1994. In that legislation, the Bureau of Land Management (BLM) was instructed to prioritize the purchase of ranch base properties within Death Valley National Park and the Mohave National Preserve so their associated grazing allotments could be closed.

Since then, Congress has passed several bills that authorized voluntary grazing permit retirements in specific local situations. It’s proven to be a good strategy, so in November 2023 U.S Representatives Jared Huffman (D-CA) and Adam Smith (D-WA) introduced the Voluntary Grazing Permit Retirement Act (HR 6314) to allow permit retirements on all Western public lands. It didn’t allocate any federal funding to encourage ranchers to surrender their permits, but relied upon private organizations to provide financial incentives. This is important because government payments for permit retirements could create the defacto conversion of grazing permits to private property rights. The bill is still awaiting a hearing in the House Committee on Natural Resources, despite being a common sense solution and having the support of numerous environmental organizations.

Updates

Congressmen Jared Huffman (D-CA) and Adam Smith (D-WA) both won reelection in November 2024.

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 National Forest’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 rescinded. 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 initially authorized for use after the 2021 Telegraph Fire as an emergency forage reserve for one of the forest’s permittees affected by the fire. (The Reavis-Tortilla allotment had burned just two years earlier in the 2019 Woodbury Fire.) Mundy claimed the permittees paid to have some of the allotment’s 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 AMP. (The NEPA Sufficiency Review file obtained in response to FOIA request #2025-FS-R3-06421-F wasn't dated.)

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.

Keep in mind that all of this was going on during the recent revision of the Tonto's LMP, and was never mentioned by the forest's staff during that process, even though the authorization of grazing on long-vacant allotments was an identified issue.

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 Reavis-Tortilla allotment as a forage reserve before the new grazing permit was issued.)

In January 2024 the first AOI under the new grazing permit was issued for the Reavis-Tortilla allotment. It 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.