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.

Congressional Grazing Guidelines

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 grazing guidelines haven’t stopped attempts to increase grazing in federal wilderness areas.

Hicks-Pikes Peak Example

In February 2021 the Tonto National Forest’s Globe Ranger District released an environmental assessment (EA) and draft decision notice for the Hicks-Pikes Peak grazing allotment, which includes a portion of the Salt River Canyon Wilderness upstream from the Roosevelt Lake reservoir. Livestock were excluded along this stretch of the river in the late 1990s to comply with the Endangered Species Act by protecting the river’s important Sonoran Desert riparian habitat from grazing damage. This meant no cattle were allowed in the allotment’s Ortega and Lower Shute Springs pastures, located along the southern bank of the river in the wilderness.

The primary purpose of the Hicks-Pikes Peak project was to satisfy the permittees’ desire to graze these two long-vacant pastures by approving the construction of many miles of expensive new fence along the river. The EA explained that a 2018 decision memo had already authorized the construction of a fence to split the Ortega pasture in two, and that grazing had already been authorized in the newly created East Ortega pasture because cattle couldn’t access the river from it.

It also stated that the new West Ortega pasture and the Lower Shute Springs pastures were still not being grazed. Furthermore, the EA was accompanied by a  responses to public comments report that was generated by the project’s 2019 preliminary EA, which stated that a “Final Decision notice” would determine if the West Ortega and Lower Shute Springs pastures would be grazed. But those official statements weren’t true. The allotment’s 2020 annual operating instructions (AOI) and its 2021 AOI both show that the West Ortega pasture had already been authorized for regular grazing.

The 2021 draft decision notice was withdrawn in May due to issues raised by the public.

In September 2022 the district issued a new draft decision notice for the allotment. It was deceptive because the description of the proposed action was located in the accompanying revised EA. Like the previous draft, it proposed to authorize grazing in the West Ortega and Lower Shutes Springs pastures, with the requirement that neither would be grazed until fences were built to prevent cattle from accessing the river. It also stated that the Lower Shute Springs pasture was “not part of the current” grazing system.

According to the 2022 revised EA, the decision would have authorized a maximum of 800 adult cattle yearlong, and up to 1,100 yearlings for any 7 months within a 12 month period. The EA didn’t identify the number of cattle that were authorized to graze the allotment in 1984, when the Salt River wilderness was created. However, according to the allotment’s 1992 allotment management plan (AMP), the allotment was only authorized for 850 adult cattle yearlong as just a cow-calf operation.

The revised EA also claimed that the West Ortega pasture had only been grazed for “emergency” use in 2020 due to the 2020 Griffin Fire. But that was also not true, because the allotment’s 2020 AOI was issued that January, before the fire in late August, and as mentioned above, it shows that the West Ortega pasture had already been authorized for regular grazing. And, as also previously mentioned, the subsequent 2021 AOI shows the pasture was authorized for grazing again, as does the 2022 AOI.

The Tonto National Forest withdrew their 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.

The allotment’s 2024 AOI shows that the West Ortega pasture was authorized for grazing again, while the Lower Shute Springs pasture still isn’t being grazed.

Grazing Permit Retirements Are An Equitable Solution

Congress should end the tyranny of the minority they gave ranchers in the Wilderness Act of 1964 by finally 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

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

On February 12, 2025, the Globe Ranger District issued the 2025 AOI for the Hicks-Pikes Peak allotment, and grazing was still being authorized in the West Ortega pasture. 

On February 27, 2025, the Tonto National Forest’s Payson Ranger District secretly issued a new grazing permit to the Hat Ranch for the Bull Springs grazing allotment, located in the Mazatzal Wilderness. The allotment had been vacant for several years because in 2017 the previous permittees were issued a suspension letter for failing to comply with the terms and conditions of the grazing permit, which included maintaining fences in need of repairs. A follow up allotment inspection report in 2018 confirmed they still hadn’t complied. The new permit allows up to 160 head of cattle yearlong, the same as the old permit. The allotment’s most recent EA was completed in 1989.

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 new grazing permit had been secretly issued by the Mesa Ranger District for the long-vacant Reavis-Tortilla grazing allotment, located in the rugged and arid Superstition Wilderness. It authorized up to 1800 yearlings for 7 months, from November 15 to June 15. It was accompanied by the allotment’s initial AOI that authorized grazing to begin in January 2024.

The allotment hadn’t been grazed since at least 1994, when the permit was cancelled for permittee non-compliance. In 1996 an EA was completed and a decision notice issued in July to re-authorize grazing on the allotment. That decision, however, was then rescinded due to an appeal on October 4, 1996. In his decision 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 temporarily 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 permittee 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 and decision, along with its 1990 AMP. That decision had called for the conversion of the existing yearling operation to a yearlong cow/calf system. But that didn’t happen, so the existing authorization for up to 1,000 yearlings up to 7 months, from November 1 to May 31, remained in place. (The NEPA Sufficiency Review, obtained in response to FOIA request #2025-FS-R3-06421-F, wasn’t dated.)

Keep in mind that all of this was going on during the recent revision of the Tonto’s Land Management Plan (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.

During 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. This was despite the fact that grazing had been suspended on the allotment in March 2025 due to drought.

On March 27, 2025, the Tonto National Forest’s Payson Ranger District secretly issued a 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 and its most recent AMP was completed in 1988. The allotment was authorized for up to 175 cattle for 7 months, the same as the old permit. 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 permitee to fix all the fences before the area could be stocked which is estimated to coast over one million dollars. The Deadman Mesa project has 100% benefit to wildlife.

On January 22, 2026, acting Tonto National Forest Supervisor Ericka Luna issued a response letter to the November 21, 2025, complaint from environmental groups about the forest’s secret initiation of livestock grazing in 2024 on the Reavis-Tortilla grazing allotment in the Superstition Wilderness. She tried to justify that decision, and revealed that grazing had been authorized on the allotment again for the 2025-2026 grazing season for 600 yearlings for 6 months.

On January 20, 2026, the Southwestern Regional Office of the Forest Service finally responded to FOIA Request #2025-FS-R3-07233-F, which had been submitted on June 3, 2025, and asked for more information about the Reavis-Tortilla grazing allotment. They provided the 2022 Allotment Inspection Report, completed when the allotment wasn’t being grazed.