Are Cattle Grazing Leases Appropriate?

by Jeff Aardahl, Senior California Representative, Defenders of Wildlife

In September 2022, the Bureau of Land Management (BLM) published an Environmental Assessment (EA) for a proposal1 to issue new 10-year cattle grazing leases which include portions of the Bright Star and Kiavah Wilderness Areas. Managed respectively by the Ridgecrest and Bakersfield Field Offices, these Wilderness Areas are at the junction of the Mojave Desert, Sierra Nevada Mountains, San Joaquin Valley, and the Transverse Range eco-regions with elevations ranging from 3,000 to 5,000 feet resulting in a diverse assemblage of habitats and species. Both areas were severely burned in 2008 and 2016 and have been affected by recent drought conditions with native grasses and shrubs in the early stages of recovery.

Included within the boundaries of these Kern County grazing allotments are: 1) the 8,775 acre Bright Star Wilderness, located in the Piute Mountains of the Southern Sierra Nevada; and 2) a 8,831 acre portion of the Kiavah Wilderness2, located in the Scodie Mountains of the Southern Sierra Nevada. BLM’s portion of the Kiavah Wilderness is located northeast of the Bright Star Wilderness and west of the Scodie Mountains. These two wilderness areas were designated in 1994 under the California Desert Protection Act. The Bright Star Wilderness has an even longer conservation history. It was included in the California Desert Conservation Area under the Federal Land Policy and Management Act (FLPMA) in 1976 and was designated by BLM as part of the Jawbone-Butterbredt Area of Critical Environmental Concern (ACEC) in 1980.

c. map

Effects of the Piute and Erskine Fires on Wilderness

In 2008, the Piute Fire burned about 30% of the Bright Star Wilderness. Eight years later in 2016, the Erskine Fire burned and destroyed all the native vegetation in over 60% of Bright Star. According to the EA, the Kelso Peak grazing allotment, which includes the Bright Star Wilderness, was “ravaged by fires at an unusually high fire interval rate” and that the “Erskine Fire severely impact[ed the] natural quality of wilderness.”

The EA also states that “Grazing at the maximum allowable intensity could have a profound effect on the naturalness of the Bright Star Wilderness, given that the vegetation community is still in the early stages of recovering from two large fires in relatively quick succession. Livestock grazing would introduce additional trammeling impacts that could disproportionately influence the outcome of fire recovery in this wilderness for years to come.” The BLM’s Wilderness Character Report for the Bright Star Wilderness stated, “[T]he 2022 data show a marked increase in the extent and frequency of non-native plant species and a decrease in naturalness within the Bright Star Wilderness since the 2016 Erskine Fire. Key forage species are no longer sufficient within the burned area to support both livestock grazing and fire recovery.”

The fires also affected the Kiavah Wilderness, but the EA provided little information of the fire’s effects on soils, vegetation, and wildlife. Instead, the EA focused on range improvements (e.g., fences) that were burned and are now non-functional. The EA states, “The 2016 Erskine fire burned over 48,000 acres to the east and northeast of the project area. Over 5,500 acres of the Woolstalf Creek, High Enough, Cane Canyon, and Nicoll Spring pastures were affected by this fire. The Piute Fire of 2008 burned 37,000 acres of which 573 acres of the Upper Cortez Canyon pastures burned. The effects of these fires on the landscape have not yet been analyzed.” The EA is largely silent on the current condition of the wilderness area and merely states, without evidence, that “impacts to the Kiavah Wilderness are not expected to occur” as a result of cattle grazing. This statement is highly questionable given the effects of the Erskine Fire that resulted in the loss of native grasses and shrubs which have not fully recovered.

Kelso Peak Allotment before the Erskine Fire

c. Pic 2 - Kelso Peak Allotment before Erskine Fire

Kelso Peak Allotment after the Erskine Fire

c. Pic 3 - Kelso Peak Allotment after Erskine Fire

Alternatives Considered and Analyzed in the EA

Under the National Environmental Policy Act, the BLM is required to consider and analyze the effects on the environment that would occur from a reasonable range of alternatives that would accomplish the underlying purpose and need of the proposed action. The analysis of the effects of alternatives and their implementation must avoid alternatives depending upon speculation or which are unsupported by evidence. Furthermore, alternatives cannot be similar or substantially the same as another alternative. Generally, for an externally generated proposal the no action alternative would mean rejecting the grazing permit application and not issuing any new 10-year grazing leases.

BLM states in the EA that “The BLM’s purpose for the action is (1) to process term grazing authorizations on the affected grazing allotments; (2) to address changes needed to the livestock management units, practices, and resource improvement project authorizations resulting from the partial relinquishment of grazing privileges on the Rudnick Common allotment; and (3) to continue to meet, or make significant progress toward meeting, the Standards of Rangeland Health, objectives of the Resource Management Plans, and other pertinent multiple use objectives for the affected allotments.”

BLM has so narrowly construed the purpose that all alternatives (the no action, the proposed action, and the single alternative) must include cattle grazing. The only way BLM could satisfy the stated purpose and need is to issue the proposed grazing leases. It is notable that the proposed action and the single alternative analyzed in the EA would allow essentially the same level of grazing. Absent from the EA are alternatives that would suspend grazing until the burned areas recover and alternatives that adjust grazing seasons (e.g., fall and winter seasons) to avoid plant periods of native plant germination, growing and maturing.

In response to the grazing applications, the BLM should have stated the correct purpose and need and acknowledged all of its legal obligations. These include managing the public lands for multiple uses, which includes grazing in a sustained yield manner, maintaining environmental quality, managing and protecting ACECs, and managing wilderness under provisions of the Wilderness Act. BLM should have also stated that its legal obligations include FLPMA’s multiple use and sustained yield requirement. Beyond this, the Wilderness Act mandates that BLM manage wilderness for the public use and enjoyment in a manner that will leave it unimpaired for future use and enjoyment by protecting and preserving its wilderness character.

Rangeland Health Assessments

The EA includes a summary of the Rangeland Health assessments based on BLM’s regulations for Fundamentals of Rangeland Health and Standards for Livestock Grazing. One assessment covered the proposed allotment pastures, and the other focused on wilderness character in the Bright Star Wilderness. Cattle have not grazed within the Bright Star Wilderness or the Kelso Peak Allotment as a whole since 1998.

A multidisciplinary team of BLM staff members performed assessments in the proposed allotment pastures in 2021 and reported that all components of the rangeland ecosystem met the recognized health standards. The fires that affected the proposed pastures were noted as “natural disturbances” even though both were human-caused.

The 2022 Wilderness Character Report covering the Bright Star Wilderness rated it as non-functional within areas burned by two fires within the middle elevations, where 95% of Joshua trees and California buckwheat and nearly 100% of pinyon pine and big sagebrush was eliminated. Perennial bunch grasses were found in several isolated, small patches, and current ground cover is dominated by annual forbs and grasses, including non-native cheatgrass, splitgrass, and filaree. The report concluded the burned area is in the early stages of recovery from the fires. The report stated, “This area is in danger of transitioning to a less diverse, more degraded (exotic) vegetation type community under additional stressors posed by drought and the possible resumption of livestock grazing. It could transition from an open Joshua tree-California Juniper woodland with a mixed Mojave scrub understory to a California Juniper annual forb and grassland dominated almost exclusively by serial and invasive species (such as cheat grass and red brome).”

For the Bright Star Wilderness, the Wilderness Character Report recommended that “Grazing should be suspended in areas severely burned and impacted by the 2016 Erskine Fire for another 5-10 years. These areas have not recovered sufficiently to support the resumption of livestock grazing without adverse and potentially irreversible impacts to the native vegetation communities.” It recommended that “Cortez Creek should not be used for livestock watering purposes whatsoever. It is the only source of water and shade in the area. Currently, it supports the most prominent expanse of green (wet, verdant) vegetation found within the area, along with a few relatively large monotypic stands of bunch grasses. These green areas are embedded within large expanses of mostly brown, dried-up stubble (spent annual grasses and forbs) in this period of extended drought. It anticipated that the creek bottom and isolated bunchgrass stands will be especially hard hit, selectively (over-) grazed by cattle (should they be reintroduced) in the absence of much of anything else. We should not allow cattle to have unfettered access to the spring and riparian areas and to monopolize these areas during the critical spring growing season or later in the year, when dwindling water resources become especially critical for native wildlife species.” The concluding recommendation was to allocate perennial forage only from the unburned portion of the area, or with very limited AUMs for both the burned and unburned areas only during years of higher precipitation and increased forage production.


The BLM’s EA for issuing new 10-year grazing leases and forage allocation for cattle fails to account for the severe impacts of two human-caused fires that eliminated nearly all perennial vegetation over significant portions of the Bright Star and Kiavah Wilderness Areas. The EA fails to include a reasonable range of alternatives, as the proposed action and the single alternative propose essentially the same level of grazing. Absent are alternatives that would suspend grazing until the burned areas recover from the effects of the two fires and another that would reduce the forage allocation and limit grazing to the fall and winter seasons.

On December 29, 2022, the Ridgecrest Field Office Manager issued a proposed decision to issue new 10-year grazing leases, including allowing grazing within the Bright Star Wilderness. The proposed decision called for suspending a portion of the livestock forage allocation due to the impacts of the Piute and Erskine fires. Mandatory monitoring by BLM every three years will assess the effectiveness of this action to protect rare plants and to restore and maintain wilderness characteristics. The Bakersfield Field Office Manager issued a proposed decision to issue new 10-year grazing leases for allotments under his jurisdiction on January 6, 2023, with no suspension of forage allocation. There was a 15 day protest period of the proposed decisions, and it is likely that protests will be submitted.

Working as a wildlife biologist and supervisory natural resources specialist with the Bureau of Land Management and the National Park Service, Jeff Aardahl has spent the greater part of his professional life engaged with outdoor conservation issues. Now retired, his work with Defenders of Wildlife is focused on wildlife and habitat conservation, endangered species recovery, land use planning, and similar conservation matters.


1) Kelso Valley Livestock Grazing EA (

2) Kiavah Wilderness is 88,290 acres of which BLM manages 20,435 acres and the U.S. Forest Service manages 50,728 acres.