Humboldt Toiyabe Considers Restocking Vacant Allotments

Mount Jefferson in Alta Toquima Wilderness, Humboldt Toiyabe NF, Nevada. Photo George Wuerthner 

The Humboldt Toiyabe National Forest (HTNF), primarily in Nevada, has 40 vacant allotments. Vacant allotments mean they once were grazed, but for various reasons currently do not have any livestock grazing.

Rather than permanently closing allotments that are currently ungrazed, the Forest Service in a recent call for scoping comments seems intent on creating more public conflict by restocking vacant grazing allotments. The proposed action description and other information are available for review at

As part of this effort, the Humboldt-Toiyabe National Forest (HTNF) is preparing an environmental assessment (EA) addressing livestock grazing on the McKinney, Meadow Canyon, Monitor Valley East, Monitor Valley West, Silver Creek, and Table Mountain allotments. These allotments are located south of Austin and north of Tonopah, Nevada.

Yellow highlighted areas are the general location of grazing allotments. 

Permits for the McKinney, Meadow Canyon, and Silver Creek allotments expired and were not reissued in 1994. The Table Mountain, Monitor Valley East, and Monitor Valley West allotments were canceled for non-compliance issues from the permittees. All six of these allotments have been ungrazed (except for trespass livestock) since the 1990s.

The Forest Service seems intent on restocking these allotments. The logic goes like this. The HTNF plan (done in 1986 or 27 years ago) suggests that livestock grazing is “permitted” on the forest. But just because something is permitted does not mean it must or should occur. Whether restocking these allotments is really in the public interest should be one of the significant discussions in any EA.

A complete evaluation of the multiple impacts of livestock grazing on other public values, as well as the economic costs associated with livestock impacts, should be done before any decision to restock allotments is considered.

From a public interest perspective, it behooves the FS to prove beyond a doubt that livestock grazing is a benefit to American citizens, not just the permittees who will be utilizing these lands.

The Toquima Range from Monitor Valley, Nevada. Photo George Wuerthner

Some of these allotments are very large. The Meadow Canyon allotment is 44,000 acres, the Silver Creek Allotment is 51,000 acres, and the Table Mountain Allotment is 35,000 acres. In total, all six allotments represent over 209,000 acres of public land.

To minimize public oversite of its lands, the Forest Service requires that one must establish eligibility to object to the draft decision that will be released following completion of this National Environmental Policy Act review. In other words, if you want to influence how your public lands are managed, you must submit scoping comments. Submit your comments online at


Several of these allotments are within the Alta Toquima Wilderness and Table Mountain Wilderness.

Aspen in Pine Creek Alta Toquima Wilderness, Nevada. Photo George Wuerthner

The Alta Toquima Wilderness was designated in 1989 and covers 35,860 acres. The glacier-carved Mount Jefferson, the highest summit, rises 11,941 feet.

The Table Mountain Wilderness in the Monitor Range is cloaked in aspen. Photo George Wuerthner

The Table Mountain Wilderness covers part of the Monitor Range, which rises to 10,430 feet. The wilderness was also established in 1989, and it now totals 92,627 acres. It consists of a large plateau covered with aspen.

While livestock grazing is permitted in wilderness under the 1964 Wilderness Act, it is only allowed if it does not substantially degrade wilderness values. It is difficult to see how exotic animals (cows), polluting water, consuming forage that would support native animals, degrading riparian areas, spreading weeds, and providing an excuse to kill native predators enhances wilderness values. Plus, “range developments” like fences, spring troughs, piping, and other construction designed to facilitate livestock use of these areas also detracts from the wilderness values. You might want to make this part of your scoping comments.


The restocking of these vacant allotments seems likely to invite a repetition of the Sagebrush Rebellion of the 1980s or an expansion of the ongoing Bundy rebellion.

Pine Creek within the Toquima Range was the focus of a legal battle over government authority to manage livestock on public lands waged by rancher Wayne Hage. Photo George Wuerthner

The area in and around the Alta Toquima Wilderness was a significant controversy in 1991 when the Forest Service seized 100 head cattle owned by of rancher Wayne Hage over multiple grazing violations. (This was back in the day when the federal government confronted violators, unlike today when hooligans like Cliven Bundy illegally grazes livestock in Nevada unmolested).

Hage had a long history of conflict with the federal government. He bought the Pine Creek Ranch in 1978. Pine Creek drains out of the Alta Toquima Wilderness. The ranch included 752,000 acres of public lands grazing allotments. Almost immediately Hage objected to the presence of elk grazing on these public lands suggesting they conflicted with his “right” to graze livestock. Between 1980 and 1990, the FS sent Hage 40 letters reprimanding him for overgrazing the public lands and ordered him to remove his cattle. The FS made 70 visits to the Pine Creek allotments.

After repeated warnings, the HTNF impounded some of his cattle and sold them. Hague reacted by billing the Forest Service $28 million. Later more of his grazing allotments permits were canceled.

Hage became the darling of the livestock industry which supported his efforts to challenge the federal government’s authority to manage private livestock using public resources.

Over time, and many lawsuits, Hage (who died in 2006) and then after his death, his son continued the conflict. They argued that they owned the water on public lands, and they had a “right” to graze their cattle without a permit.

At first, Hage prevailed in the court cases, but ultimately in 2016, the Ninth Circuit Court ruled that the government had the right to manage public lands and that Hage’s cattle were trespassing, and by 2019 all legal suits were settled. Of course, like Cliven Bundy, the Hage’s got to graze their cattle on public lands for decades without having to pay for the forage or privilege.

Now the HTNF is considering “restocking” the old Hage allotments and others.


There are numerous issues to consider and question. You can write the FS and ask them to consider these points.

First, strongly argue that restocking these allotments that are vacant will only result in more conflicts over public land management. It is impossible for livestock to graze these arid lands without damaging public values. The Forest Service should permanently retire these allotments.

Failing that, at the very minimal, the FS should maintain vacant status until it can demonstrate that it has the funds to do adequate monitoring, and recovery of all vegetation, riparian areas, and other considerations are met.

For instance, two-thirds of monitoring sites in the McKinney allotment and half of the monitoring sites in the Meadow Canyon allotment are not meeting desired conditions. Until these sites meet at a minimum “desired conditions,” no reauthorization should be permitted.

Another problem has to do with the standards the FS is using to evaluate livestock impacts. The FS suggests that it will allow livestock to consume 45% of the grass and other plants on most allotments. In other words, nearly half of all annual biomass will be allotted to private livestock.

This level of heavy use often harms grass plants and other vegetation, particularly in drought situations which cannot fully recover from the loss of photosynthetic material unless rested for years.

Grazing at this level can also harm native species in numerous ways, but frequently livestock use is much higher, particularly in wet meadows and riparian areas. Since the FS often “averages” use over the entire allotment considered suitable for livestock, uses in critical areas typically exceed these standards. The FS should do annual monitoring while cattle are on the allotment to determine when forage consumption has exceeded standards and immediately remove livestock.

The Forest Service claims that it will only reauthorize grazing if the allotments maintain LRMP desired conditions. That all sounds nice in theory, however, in most situations the FS does not have the funding to do proper monitoring and follow-up.

A frequent problem with all public land management is that the agencies aspire to maintain minimum conditions, but they often lack the personnel to do proper follow-up and monitoring. The FS should show how it will fund monitoring and cancel grazing if adequate funding is not available.

Elk are socially displaced by the presence of livestock, not to mention nearly half of the annual forage production is proposed to be allotted to livestock means that much less for wildlife like elk. Photo George Wuerthner 

Some of these allotments have growing elk herds. The proposed stocking rate would allot nearly 50% of the forage to private livestock. You cannot be putting that much forage in the belly of cattle without seriously impacting the ability of these public lands to support wildlife like elk, bighorn sheep, and deer.

The mere presence of cattle socially displaces native species like elk, forcing them to utilize a habitat that may be less suitable. How is the FS going to prevent the social displacement of elk, deer, and other wildlife?

What is the impact of restocking vacant allotments on other economic values like wildlife, water quality, recreation, and ecosystem integrity.

Ask the FS why it is putting the interests of private businesses ahead of the welfare of public wildlife?

Ungrazed stream on the Humboldt Toyaibe NF has an intact stream channel, vegetative cover to the streambank. Cattle naturally gravitate to these “riparian areas” trampling banks, removing vegetation cover, polluting water, much to the detriment of riparian-dependent wildlife from amphibians to trout. Photo George Wuerthner

As in most of Nevada, permanent water and springs are in short supply. Often the bulk of all forage in Nevada allotments is located along the green strip of vegetation along streams and in wet meadows. Cattle naturally gravitate to water and degrade “riparian” areas by consuming the vegetation, compacting soil, polluting water, and breaking down channels and banks. The only way to preclude this is to fence these streams. But one can question why the public should have to pay tax dollars to fence streams to protect its property from private businesses.

Furthermore, the FS proposes developing springs and seeps critical to many other wildlife, from native snails to amphibians like frogs. Removing water from these natural water sources to give water to cattle harms these wildlife species.

Some of these allotments are in sage grouse habitat. Livestock grazing, particularly of springs, wet meadows, and other moist habitats, removes forbs (flowers) critical to young sage grouse chicks. Plus, livestock grazing removes the hiding cover that grouse need to protect themselves from predators.

Grazing, particularly in wilderness areas but throughout the region, will impact recreational use—nothing worse than trying to camp where cow pies are scattered about the ground.

The dense grass cover in the foreground is the highly flammable annual cheatgrass which is wiping out sagebrush ecosystems. Cheatgrass spread is facilitated by livestock grazing. Photo George Wuerthner

Livestock grazing causes disturbance that enhances the spread of cheatgrass. By trampling biocrusts that inhibit cheatgrass establishment, livestock further the spread of this exotic grass. Cheatgrass readily burns and increases the likelihood of wildfire which is a threat to sagebrush ecosystems. The Forest Service should explain how it will preclude the spread of cheatgrass.

Livestock is a major source of GHG emissions. The FS should justify how it can help meet the federal government’s goal of reducing GHG while allowing domestic livestock to graze on public lands.

While the Forest Service is under no obligation to make a profit, it doesn’t have to lose money. Given the low grazing fees that are charged for grazing public lands, the high costs of management, including the cost of monitoring, maintaining range infrastructure (like fences, etc.), and the “ecological” costs associated with grazing, such as the damage to watersheds, vegetation, wildlife, and recreation, the FS should provide a complete cost accounting of all fees and benefits. This economic analysis should include the administrative costs of doing an EA, the cost of office space, trucks, gasoline, hydrologists, biologists, botanists, soil scientists, archeologists, and any other specialists associated with the grazing allotments implementation and planning.

One should evaluate permanent allotment retirement in any EA or other environmental evaluation.

Please send in scoping comments and ask to be sent a copy of the EA when available. Again comments can be submitted 


  1. cynthia brown Avatar

    Leave the alloments vacant and to wildlife.

  2. Ralph Maughan Avatar
    Ralph Maughan

    I really hope people will comment on this because Nevada is a place where public land ranchers have been among the nastiest, and have often got their way by yelling, stalling, breaking the law, and they figure they are immune because the ranges of Nevada are not well known to their owners — you and me.

    If we can’t keep cows off of lands like these that are soaking up carbon, what chance do we have to fight climate change?

  3. Rich Avatar


    Thank you for providing background information, and a great summary of all the issues, economic and ecological costs and how to contact the FS. I will definitely express my concerns and opposition and ask for a copy of the EA when it is released.

  4. Ida Lupine Avatar
    Ida Lupine

    Truly, I about fell out of my chair when I read that cattle ranching’s contributions to conservation are being praised in the new 30 x 30 wilderness program!

    Do wilderness easements really compensate for cheatgrass, overgrazing, the killing and brutalizing wildlife? I don’t think so.

  5. Ida Lupine Avatar
    Ida Lupine

    ^^sorry, ‘conservation easements’, that should read.

  6. Beeline Avatar

    What rancher and their bankers in this insane capitalistic society would not want such a huge discount? The grazing fee for 2021 is once again $1.35/AUM. $1.35 was the minimum rate set back in 1934. If the rate is adjusted for inflation it should be $26.64/AUM. The whole dam system is a tax payer super rip off.

    I think the Biden administration, like the others, is blind to the situation. But who knows, maybe the space aliens will develop a taste for beef and beam those suckers up to Orien for a barbecue.

  7. Chris Harbin Avatar
    Chris Harbin

    I commented on allotment renewals in the Gila and Apache-Sitgreaves NFs in New Mexico and Arizona. I thought it might help the Mexican Wolf Reintroduction.It can be exhausting in that there are so many allotments and each have their own characteristics.
    However, I will gladly re-enter the fray on these. If my comments help maintain the current status of these Nevada allotments it will increase my impact by at least 1.

  8. Green Hunter Avatar
    Green Hunter

    I’m confused, am I misinterpreting what the document is proposing? I saw lots of cows on these allotments all last summer. On the Table and in the Toquimas. At Georges Camp, in Pine Creek, Buck Canyon, North Table Spring, all over Mosquito Creek. July, August, September 2020. How is it being said that these allotments have been vacant or are rested? The contact number listed for Rixey Jenkins goes to a dead line.

  9. Maggie Frazier Avatar
    Maggie Frazier

    I just sent yet another email to my “representatives” in DC regarding the amendment that was proposed for the Appropriations for the budget, pushing to get PZP used for fertility for Wild Horses rather than experimental surgery! I really dont believe fertility treatments are necessary because I dont believe the BLM’s made up numbers. BUT preventing these yahoos from SPAYING wild mares & whatever other experiments they have in mind is important.
    Sorry – I know this is about grazing allotments & as Beeline says – this $1.35/AUM rate is absolutely NUTS. Set in 1934? NUTS. But just sent my very blunt assessment of what I think about the lack of my politician’s action regarding our Wild Horses & this time I didnt hold back – wont make any difference, I’m sure I will receive the stock email in response – that is if there is any response!

    1. Ida Lupine Avatar
      Ida Lupine

      Yes. It’s gruesome. It’s really difficult to believe anything we are told, especially with the latest news about the horses being secretly sent to slaughterhouses.

    2. Ida Lupine Avatar
      Ida Lupine

      And ‘spaying’? I’ve read all kinds of stories about surgery being performed in unsterile field, (hopefully anesthesia was involved somehow), prisoners being trained to perform spays and neuters, mistakes such as the surgery performed on the wrong sex.

      Very cheap and uncheerful.

      1. Maggie Frazier Avatar
        Maggie Frazier

        I remember reading quite a while ago that when stallions are castrated – they dont receive painkillers, more like a paralytic drug. So they are unable to move, but could feel the pain. I would hope that that still isnt the case – but honestly? I dont have much faith in that.

  10. Joan wager Avatar
    Joan wager

    These allotments must be retired. They can not support cattle without risk of complete degradation and must be left for wildlife support only.

  11. Susan Saul Avatar
    Susan Saul

    Native plants — and not just grasses and forbs –are an issue that also must be addressed in the EA. The Forest Service itself says that aspen are in decline across the West. Browsing has a direct impact on recruitment. Through the early sapling stage, browsing reduces aspen growth, vigor, and numbers. I will be urging botanist input into this EA. Also, those alpine environments like Mount Jefferson in Alta Toquima undoubtedly host rare plants.


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George Wuerthner