Bridger Teton NF Capitulation to Ranchers on Upper Green River Allotment


The Elk Ridge Complex grazing allotments were closed to livestock grazing in 2015. Now the BTNF wants to open them to cattle grazing. Photo George Wuerthner 

The Bridger Teton National Forest (BTNF) has recently issued an Environmental Assessment to restock four vacant grazing allotments in the Upper Green River drainage north of Pinedale, Wyoming. If allowed to go forward, the Elk Ridge Complex Rangeland Supplementation proposal will have multiple negative consequences for wilderness, wildlife, the public enjoyment of these lands, and the future of grazing permit buyouts.

The big difference here from most livestock grazing issues is these allotments are currently vacant, so a “refugia” from the nearly omnipresent livestock degradation.

At best, this represents “bad faith” on the part of the BTNF. At the worse, it is a concerted effort to make permit retirement impractical.


Larger wildlife found on the Elk Ridge Complex includes bighorn sheep, moose, elk, grizzly bear, pronghorn, black bear, wolves, and cougar and could again support wild bison. Photo George Wuerthner 

The Elk Ridge Elk Ridge Complex is adjacent to the Upper Green River Grazing Allotment. The entire Upper Green drainage has better wildlife habitat than the famous Lamar Valley in Yellowstone National Park. Indeed, the Upper Green should be protected by a new national park or other designation like national wildlife refuge because of its high wildlife values.

The spectacular wildlife and scenic values of the Upper Green should be protected in a national park, wilderness or other designation that legally recognizes its outstanding public values. Photo George Wuerthner 

Even the BTNF recognizes this fact and has designated the entire Upper Green in its Forest Plan as Desired Future Condition 10 (DFC), which requires the Forest Service to manage the area primarily to protect wildlife values.

The Elk Ridge Complex consists of four grazing allotments, Tosi, Rock Creek, Lime Creek, and Elk Ridge, lying within, adjacent to, or near the eastern boundary of the Gros Ventre Wilderness. Indeed, 44% of the allotments are within the Gros Ventre Wilderness.

The Elk Ridge Complex adjacent to the Upper Green Grazing Allotment is designated a wildlife priority area by the BTNF forest plan, however, the BTNF  tends to make livestock the priority in all its management decisions. Photo George Wuerthner

The Forest Service wants to make these allotments available for cattle grazing by shifting livestock grazing from other parts of the Upper Green River allotment, the largest single grazing allotment in the country under the Forest Service administration.

The circles indicate over 500 livestock-grizzly conflicts in the Upper Green area between 2010 and 2018. 


It is important to note that all grazing on public lands is a privilege, not a right. Grazing “rights” only divvy up rangelands among different ranch operations but convey no private property entitlements. Nevertheless, in recognition of the political difficulty of removing livestock from public lands, even after repeated violations or documented harm to public resources, an alternative strategy is to pay ranchers to voluntarily relinquish grazing privileges in exchange for an agreed-upon payment by private parties.

Such a permit buyout was implemented on these allotments in 2015 when private individuals paid the permittee to retire their sheep grazing permit voluntarily.  Part of the justification for closing the allotments was conflicts with grizzly bears (meaning bears were killed due to livestock depredation). The BTNF Forest Service agreed to close the allotments to future sheep grazing as part of the agreement.

The Elk Ridge Complex allotments were grazed by domestic sheep until they were closed in 2015. Photo George Wuerthner 

But here’s the catch. The Forest Service only agreed to close these allotments to sheep grazing, and they are now planning to restock them with cattle.

Suppose the Forest Service is permitted to go ahead and restock grazing allotments that were retired by grazing permit retirement. In that case, it will jeopardize all future permit buyouts because few private individuals or foundations would be willing to invest money in permanent retirement if it is not permanently close to all livestock.

Nowhere in its EA does the Forest Service even acknowledge how its proposal would harm permit retirement, much less analyze the damage to this management option that will occur by the restocking of vacant allotments after private funds had paid ranchers to vacate the lands.


Cattle gravitate to and damage the moist green habitat along streams known as riparian areas. These riparian areas are critical habitat for the majority of all western wildlife. Photo George Wuerthner 

As discussed below, one of the most significant impacts of any livestock grazing is on riparian areas, which are critical to 70-80% of all western wildlife. There are numerous studies documenting that livestock removal and exclusion promote riparian function and wildlife recovery. [i]

Numerous studies have documented the harm of livestock grazing to both plants and animals; indeed, a meta-analysis found that.[ii]Livestock exclusion increased the abundance and diversity of all animals, but especially for wildlife dependent on plants, such as herbivores and pollinators.[iii]


Under the BTNF Forest Plan, the entire Elk Ridge Complex area is designated wilderness or DFC 10, where wildlife is to be given priority in any management decision.

Among the impacts that even the Environment Assessment admits will occur are conflicts with grizzly bears. In the past ten years, dozens of grizzly bears have been killed or removed from the Upper Green River allotments (which the Elk Ridge Complex is part of). The FWS, in an opinion about continued livestock grazing of the Upper Green Grazing Allotment, predicted dozens of more bears would be killed in future years.

Dozens of grizzly bears have been killed due to conflicts with livestock in the Upper Green River Grazing allotment during the past ten years. Photo George Wuerthner

The Forest Service claims that since they will not increase cattle numbers, only shift the use around; it will not increase grizzly bear mortality. What an absurd statement. In truth, spreading cattle over more terrain will only increase the probability of bears and cattle coming into contact.

One of the negatives of having any livestock on any of these allotments and the Upper Green River allotments, in general, is that dead cattle often attract grizzlies if not immediately removed. Frequently bears, once they feed on a dead cow, become accustomed to attacking cattle.

However, other wildlife will suffer from livestock grazing.

Elk are socially displaced by active cattle grazing. Photo George Wuerthner

The mere presence of livestock socially displaces elk. They are more likely to leave suitable habitat if there is active livestock use of the area.

The main grass found on these allotments is Idaho fescue, which seldom grows taller than five or six inches in this area. According to the document, cattle will be permitted to graze off 50% of the grasses meaning that on average, there will be at most 3 inches of grass left for native herbivores from ground squirrels to bighorn sheep and elk. A couple of inches of stubble is also insufficient height to hide ground-nesting birds and small rodents.

Grazing by cattle photographed here on the Upper Green Allotment in the summer of 2021 has reduced residual grass to 1-inch stubble, eliminating hiding cover for ground-nesting birds and putting forage in the belly of private livestock that would otherwise support native herbivores from ground squirrels to elk. Photo George Wuerthner 

The other problem with these standards and the requirement to leave 4-6 inches of stubble in riparian areas is that even these requirements are seldom met. I have repeatedly seen grasslands and riparian areas grazed to a “golf ball putting green” height of less than an inch. And a rancher who violates the management guidelines doesn’t get fined or have their permit pulled. At best, they get a slap on the wrist and are told not to do it again next year—which, of course, they do.

The BTNF requires 4-6 inches of stubble to remain after grazing in riparian areas. These standards are seldom met as seen here in the Upper Green River allotment, and even if a rancher’s cows graze a riparian area to the dirt, no consequences result. Photo George Wuerthner

The 50% grazing standard also harms sage grouse. But they get around this by suggesting the area is not a “good” sage grouse habitat and that there are no “known” leks in the area. That conveniently ignores the fact that the BTNF has never done a concerted survey either.

Sage grouse are impacted by cattle grazing in numerous ways. For instance, cropping grasses and other plants by 50% leaving 2-3 inch stubble reduces the hiding cover for grouse, making them and their nests more vulnerable to predation.

Cattle also consume the forbs (flowers) that young sage grouse consume. Although sage grouse, as the name implies, relies on sage bush for much of their habitat needs, young chicks spend the first couple of months of their lives in wet meadows and the riparian areas along streams. Cattle spend excessive time in riparian areas because they contain water and green vegetation, thus trampling and degrading riparian habitat. The EA admits no fences or other means of precluding cattle from contaminating riparian areas are available in the Elk Ridge Complex.

Amphibians such as the Columbia spotted frog pictured here are harmed by livestock grazing in riparian areas. Removal of vegetation, compaction of soil, trampling of banks, all degrade amphibian habitat. Photo George Wuerthner 

Other wildlife harmed by livestock includes amphibians.  Grazing can trample wetlands and riparian areas critical to amphibians, among other impacts. Indeed, one of the BTNF biologists wrote a 600 page plus document on how livestock grazing harmed frogs and toads, but the document was not cited or referenced.

Another rare bird species, the great gray owl, which hunts voles in meadows, is also harmed by cattle grazing by reducing the hiding cover for voles and compacting vole tunnels, which diminishes their abundance.

Wolves and other predators are regularly killed to make the land “safe” for private livestock on public lands. Photo George Wuerthner 

Livestock presence often leads to the killing of native predators like wolves and coyotes.

WILDERNESS IMPACTS. About 44% of the Elk Ridge Complex is within the Gros Ventre Wilderness, and nearly all the rest is protected under the Roadless Rule. In other words, these roadless lands could potentially be added to the Gros Ventre Wilderness at some point. In addition, the lack of grazing means there is one less industry (livestock/ranching interests) that might oppose wilderness designation.

Grazing in wilderness areas such as the Gros Ventre Wilderness pictured here degrades the wilderness experience and values, but the BTNF dismissed these concerns by merely asserting that the Wilderness Act allows livestock grazing, so no further analysis of livestock impact on wilderness quality is necessary. Photo George Wuerthner 

The BTNF argues that since the 1964 Wilderness Act permits grazing in the wilderness, it can allow livestock grazing. But just because some commercial use is allowed does not mean the agency must permit it.

Cattle are an exotic animal that are not native to the continent. The presence of livestock is, in fact, domestication of the land, the exact opposite of the values that federal agencies are supposed to promote in wilderness areas.

Furthermore, given the negative impacts to the wildlife mentioned above, livestock directly harms the native wildlife that are supposed to be given priority in wilderness areas. The entire Upper Green is designated DSC 10, where wildlife protection is prioritized.

Finally, if you have ever camped or hiked in an area with heavy livestock use, one is aware that the water is polluted, manure covers the ground with a stench, and makes the experience less appealing.


Nearly every stream used by livestock becomes polluted with manure and high levels of E Coli. Photo George Wuerthner 

One of the big problems with domestic cattle is that they evolved in moist woodlands in Eurasia. Because of this evolutionary history, they tend to forage in the arid West areas that most resemble their evolutionary home-namely riparian areas. Cattle spend an excessive amount of time in riparian areas harming the vegetation and soils and polluting the waters. Almost every stream with active grazing by livestock does not meet state clean water regulations, particularly for E Coli.


As with other essential topics like economics, the Elk Ridge Complex Environmental Analysis fails to consider the impact of livestock on carbon and climate warming. Much research shows that “grass-fed” beef emits more Greenhouse Gas emissions than even factory-farmed animals.[iv] Plus, all livestock, both grass-fed, and factory-farmed animals, contribute to significant climate warming.[v]

Despite rhetoric by Allan Savory and other livestock proponents, long-term intensive livestock use generally depletes soil carbon.


The Forest Service claims it will manage the area for “Best Management Practices” but doesn’t specify what that is and what will happen when there are violations. For instance, what exactly will happen if riparian 4-6 stubble height is violated. How will the FS or the public keep ranchers accountable? There is nothing in the document explaining, likely done on purpose; the public can’t hold the BTNF responsible either.


The 10,000-foot elevation of Elk Ridge roadless area is adjacent to the Gros Ventre Wilderness and should be added to the existing wilderness. Photo George Wuerthner 

An economic analysis is missing from Forest Service documents, for good reason. Any reasonable assessment would show that the negative costs to society (including below-market grazing fees) and environmental impacts like water pollution, loss of endangered species like grizzly bears, methane from cattle digestion contribution to climate warming, and the damage to riparian areas strongly outweighs any positive gain to society from having a few more cows.

Typically, if an economic review is done, the entire focus is on the benefit to ranchers without incorporating the negatives mentioned above. Even when you focus on the “economics” of public lands forage contributing to ranching, you find it’s insignificant to even the local economy.

For instance, in Sublette County, where the allotments lie, ALL agriculture contributes to 7.1% of the county’s employment, while non-farm is 92%. But even the 7.1% is missing since that is all Ag, not just cattle ranching. It would include other agriculture like growing hay. But the critical factor is that not all ranching in Sublette County uses public lands forage.

So to do a fair economic analysis, you would have to determine what percentage of total forage consumed by cattle in the county comes from public lands. Given what I have seen in other studies, I can almost assure you that this is likely less than 1% of all forage. Thus the actual contribution of public lands grazing to Sublette County is practically insignificant.

Any honest economic analysis would demonstrate that protecting the wildlife values, water quality, scenic attributes and ecological function of the Upper Green Allotment seen here (Peaks of Wind River beyond) easily outweighs the economic value of any livestock grazing of the area. Photo George Wuerthner 

By contrast, the service sector accounts for 51.1% of employment. And due to the typically low wages paid to ranch hands, all agriculture continues to 4.8 percent of income in Sublette County. So again, the percentage that can be attributed to the access to public lands forage will be some subset less of the total.


One has to wonder why the BTNF continues to put the economic interests of the livestock industry ahead of its mandate to manage these lands for the national public interest. Given the high likelihood of ecological damage and harm to wildlife, soils, water, plant communities, climate change, and even the taxpayer’s financial interests, it behooves the BTNF to permanently close these vacant allotments rather than try restock them with any livestock.

If you care to voice your opinion on the restocking of the vacant allotments of the Elk Ridge Complex, please send comments here:

Comments are due by December 27, 2021

[i] Earnest, S.L., Ballard, J.A., Dobkin, D.S., 2005, Riparian songbird abundance a decade after cattle

removal on Hart Mountain and Sheldon National Wildlife Refuges In: Ralph, C.J., Rich, T. [eds.],

Proceedings of the Third International Partners in Flight Conference; Albany, CA, USA. US Department

of Agriculture. Forest Service, General Technical Report PSW-GTR-191. p. 550-558.

[iii]   Filazzola,A., Brwn, C., Dettlaff, M.A., Batbaatar, A., Grenke,J.,Bao, T., Heida, I.P., and Cahill, J.F. 2020.

The effects of livestock grazing on biodiversity are multi-trophic: a meta-analysis. Ecology Letters 23:1298

– 1309. DOI: 10.1111/ele.13527


[iv] Wuerthner, George.


[v] Carter, John, Allison Jones, Mary O’Brien, Jonathan Ratner, and George Wuerthner, 2014. Holistic Management: Misinformation on the Science of Grazed Ecosystems.  International Journal of Biodiversity Volume 2014, Article ID 163431, 10 pages


  1. Ida Lupine Avatar
    Ida Lupine

    I really can’t believe this is happening under a Democratic administration.

    1. Ralph Maughan Avatar
      Ralph Maughan

      I think this should be mentioned in your comments, and copied to the Secretary of Agriculture.

    2. skyler thomas Avatar

      Deb Haaland is a rancher. Enough said.

  2. Ralph Maughan Avatar
    Ralph Maughan

    In the past, I guess there were sheep somewhere on this allotment then, but I saw no sign of them on Elk Ridge. Anyway, while up there in the sub-alpine and alpine splendor,I had three separate close encounters with black bears, all several miles from the road.

  3. k Avatar

    We can grow cows in the back yard. We can not re-create this landscape scale ecosystem anywhere/ever. You csn guess what matter and why it is worth fighting for.

  4. skyler thomas Avatar

    In an increasingly robotic society divorced from nature and seemingly incapable of independent thinking cattle are now the same as wildlife in the eyes of the public. In reality livestock ranching is responsible for the disappearance of both native plants and native wildlife. Opening wild areas to cattle grazing is further confirmation that the people in charge have no idea what they are doing or are carrying out the wishes of the animal agriculture industry that lobbies them.
    Do not open these areas to livestock.

  5. Ress Sandy Avatar
    Ress Sandy

    The Elk Ridge Complex should remain closed to prioritize wildlife. Thanks.

  6. Linda Avatar

    Good article snd comments. This is just one example of the lack of principles in protecting nature that exists in the present state. People are too detached from wild areas and are too glued to their electronic devices. It doesn’t bode well for our planet.

  7. Jon Marvel Avatar

    Thanks George! You have done a great job explaining all the reasons why the Pinedale Ranger District and the Bridger-Teton National Forest’s cursory EA for restocking the four Elk Ridge allotments is wrong. As a board member of the Sagebrush Habitat Conservation Fund that provided a majority of the funding in 2015 to buy out Mary Thoman’s domestic sheep permits on these four allotment, I can say that the Fund completely agrees with you. The Fund intends to comment on the EA and, if needed, legally challenge any final decision by the B-T to implement the shift to cattle.

    1. Chris Zinda Avatar
      Chris Zinda

      You bought Thoman out w/o any guarantee of permanent retirement. What a waste.

      What did you expect with Ruby bloodmoney?

      Maybe next you’ll buy out a rancher and create an HMA to placate the horse crowd you and WWP covet


George Wuerthner is an ecologist and writer who has published 38 books on various topics related to environmental and natural history. He has visited over 400 designated wilderness areas and over 200 national park units.

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George Wuerthner