SRM Comments on Proposed Revisions of Regulations for Grazing Administration

Docket No. BLM-2026-0001

Submitted via Federal eRulemaking Portal

RE: SRM Comment on Proposed Revisions of Regulations for Grazing Administration, Exclusive of Alaska

July 13, 2026

The Society for Range Management (SRM) appreciates the opportunity to submit formal comments on the Bureau of Land Management’s (BLM) proposed revisions to the regulations governing grazing administration on public lands. As the leading professional society and scientific body dedicated to the conservation and sustainable management of rangelands, SRM’s comments are grounded in evidence-based rangeland ecology, professional field experience, and the core believe that land health must remain the driving objective of land management.

SRM supports the BLM’s intent to modernize grazing administration by introducing regulatory mechanisms that allow for more flexible, real-time decision-making. However, successful implementation of adaptive management requires a realistic appraisal of agency capacity and a steadfast commitment to site-specific rangeland science. We offer the following specific comments and structural recommendations to ensure the final rule achieves its intended outcomes without compromising localized ecological integrity.  

SRM strongly supports the proposed changes designed to expand flexibility regarding permitted seasons of use, livestock numbers, and temporary nonuse. Rigid, calendar-driven permitting structures fail to accommodate modern climate volatility and acute landscape disturbances.

·       Climate and Ecological Volatility: In years marked by severe, immediate environmental stressors—such as the acute drought conditions impacting states like Wyoming this season—rigid turnout dates harm both resource conditions and livestock operations. Range managers must possess the authority to allow early turnout or extend use based on vegetative readiness and localized moisture, rather than arbitrary administrative dates.

·       Targeted Ecological Outcomes: Increased operational flexibility is a vital tool for achieving specific rangeland health goals. This includes utilizing highly responsive targeted grazing strategies to control invasive species, achieve post-fire ecological recovery, and execute strategic fuels reduction to mitigate catastrophic wildfire risk. 

·       Adoption of SRM's AUM Definition: To ensure that adjustments to livestock numbers and timing are scientifically standardized, SRM strongly recommends that the BLM explicitly adopt the SRM’s standardized definition of an Animal-Unit-Month (AUM) within Section 4100.0-5. Standardizing this definition across all federal land agencies prevents administrative confusion and aligns regulatory accounting with peer-reviewed rangeland science. 

o   Animal-Unit-Month: The amount of oven-dry forage (forage demand) required by one animal unit for a standardized period of 30 animal-unit-days. Not synonymous with animal month. Abbr. AUM. The term AUM is commonly used in three ways:

§  (a) stocking rate, as in "X acres per AUM";

§  (b) forage allocations, as in "X AUMs in Allotment A";

§  (c) utilization, as in "X AUMs taken from Unit B."

·       Operational Mechanism: SRM recommends that the final rule direct field offices to authorize broad permitted seasonal windows within grazing permits, leaving the precise operational parameters to be dialed in annually via Annual Operating Plans (AOPs). This structure provides the necessary latitude to implement rest-rotation systems across multiple allotments, which are frequently bottlenecked by inflexible permit dates under current management paradigms. 

II. Addressing the Critical Agency Staffing Crisis and Assessment Frameworks (Part 1700)

While SRM supports efforts to modernize the land health assessment process, the Bureau must confront the critical staffing deficits plaguing field offices. On-the-ground range management specialists are routinely pushed to capacity, often managing upwards of 60 allotments per person while balancing heavy monitoring workloads.

·       Rapid Landscape-Scale Condition Assessments (Section 1700.3): SRM is concerned that mandating extensive 10-year rapid landscape-scale assessments on rigid timelines will function as an additional bureaucratic hurdle, further removing understaffed field personnel from active, on-the-ground management.

·       Recommendation: The final rule must explicitly define Rapid Landscape-Scale Condition Assessments as macro-level, high-level screening tools to help understaffed offices prioritize where to deploy field resources. These rapid macro-assessments must not substitute for localized, ground-truthed Land Health Evaluations (LHEs) and must not be used as legally binding baselines to dictate localized stocking rates or causal factor determinations without field verification. 

·       Causal Factor Analysis (Section 1700.4): Tight turnaround windows for causal factor determinations must be backed by a clear requirement for rigorous, multi-faceted scientific monitoring. It is imperative that determinations remain science-based to ensure livestock operations are not penalized for land health degradation driven by forces outside the permittee's control, such as surging recreational traffic, wild horse and burro populations, or localized drought. 

·       A Collaborative Solution - Partnering for Active Monitoring: SRM emphasizes that achieving the land health goals outlined in this proposed rule requires a fully staffed, technically proficient agency workforce. We strongly encourage the Bureau to prioritize funding and recruitment for local, field-level rangeland management specialists. However, recognizing immediate budget and capacity constraints, the Society for Range Management stands ready to formalize a collaborative monitoring partnership with the BLM. Building upon the spirit of recent interagency modernization initiatives, SRM offers the unmatched capacity of our vast professional network of Certified Range Management Consultants (CRMCs) and rangeland specialists. Through a cooperative framework, our members can assist understaffed local field offices with ground-truthed data collection, trend analysis, and active compliance monitoring. This partnership will ensure that adaptive management decisions remain strictly science-based without adding to the administrative backlog of overextended field staff. 

To build long-term landscape and industry resilience against catastrophic wildfire and severe drought, the BLM must maximize the utility of existing public land resources. SRM strongly recommends incorporating formal mechanisms to streamline the deployment of vacant allotments.

·       Disaster Displacement Forage: The final rule should include an expedited, rapid-approval framework allowing field managers to temporarily transfer displaced permittees to vacant allotments during acute emergencies, such as immediate post-fire recovery periods or localized forage failures.

·       Permanent Allocation Resiliency: When a vacant allotment is determined to be ecologically viable, the administrative process to transition that allotment back to permanent production agriculture must be streamlined. Leaving viable allotments vacant for extended periods without managed grazing frequently results in the accumulation of excessive fine fuels, severely compounding wildfire hazards.

IV. Prioritizing Land Health Standards Across All Public Land Uses (Part 1700 & Part 4100)

SRM strongly believes that the primary focus of federal rangeland policy must be the preservation and promotion of rangeland resources, rather than prioritizing or penalizing any specific user group.

·       Broadening the Permit Scope: SRM asks you to revisit the definition of “production-oriented livestock,” especially when considering the proposal to narrow the scope of grazing permits exclusively or requiring applicants to solely prove they are engaged in a traditional production business. If a non-traditional entity, conservation-oriented organization, or public-private partnership can utilize managed livestock grazing to successfully achieve Healthy Land Criteria, the regulations should facilitate that opportunity. This narrow focus may eliminate innovative management options, such as integrating targeted grazing with renewable energy infrastructure or utilizing non-traditional graziers for specific riparian restorations. 

·       Definition of Livestock: Should the Bureau retain production-focused language, the definition of livestock must be explicitly expanded to include non-traditional, non-meat-producing working stock—including outfitter, guide, dude ranch, and bucking stock—to protect legitimate public land operators from unintended permit loss. 

·       Allotment Closures via Resource Management Plans (RMPs): The final rule should prohibit the permanent designation of allotments as "closed" within 20-to-40-year RMPs. Hardcoding closures into long-term planning documents creates an inflexible barrier that cannot adjust to shifting ecological realities. Attempting to reopen an allotment to manage dangerous fine fuel loads via an RMP amendment is an incredibly slow process that invites protracted litigation. Allotment status must remain a flexible management tool handled at the local Allotment Management Plan (AMP) level based strictly on localized ecological data. 

·       Support for Part 1700: SRM highly commends and supports the creation of a distinct Part 1700 to establish unified Fundamentals of Land Health across all public land programs. Rangeland health is a product of cumulative impacts, including soaring public recreation and energy developments. It is both scientifically sound and equitable to ensure that all public land users are held to the same foundational standards, ensuring livestock operators are not held solely accountable for degradation caused by unmanaged external uses. 

·       Explicitly Protect and Authorize Research Permitting: SRM is concerned that narrowing the scope of grazing permits exclusively to traditional "production-oriented livestock" will inadvertently dismantle critical, long-term public land research programs. Rangeland research operations often utilize livestock to produce peer-reviewed data, advanced management tools, and genetic baselines rather than food or commercial income. The loss of a research allotment does not merely displace livestock; as documented in peer-reviewed analyses (e.g., Agriculture and Human Values), it systematically restructures entire research programs, creating a cascading loss of localized knowledge, unique genetic resources, and foundational range management science. Historically, federal research entities (such as USDA-ARS units) have successfully held BLM grazing permits for decades to conduct vital, allotment-scale research without competing with private industry. The final rule should explicitly state that applied rangeland research constitutes a valid, recognized use of a grazing permit. Failing to protect these permits will permanently set back public land science and force research herds off the range and into feedlots, eliminating the ability to study ranch-scale ecological responses in real time.

·       Beginning Rancher Provisions (Subpart 4110): While SRM supports incentivizing the entry of young and beginning managers into rangeland agriculture, the current proposed tracking requirements place an unrealistic administrative burden on field specialists to audit an applicant's asset and cattle-ownership history across state lines. We recommend utilizing simplified, self-certification protocols to prevent range conservationists from being diverted into forensic financial auditing.

·       Unauthorized Use Discretion (Subpart 4150): SRM strongly supports the inclusion of an "incidental, nonwillful" category to handle minor, quickly corrected infractions informally. This discretion protects the collaborative, good-faith working relationships, especially between range cons and land managers.

·       Appeals and Automatic Stays (Subpart 4160): The proposed language in Section 4160.3(c) allows the BLM to bypass an automatic stay and place a decision into immediate effect under the broad standard of "protecting range resource values". Because this standard is highly subjective, it risks rendering the automatic stay meaningless. SRM recommends clarifying that range-improving infrastructure investments (such as water distribution or exclosure fencing) must be allowed to proceed during an ongoing appeal if an LHE confirms the project directly prevents further resource degradation. 

The Society for Range Management stands ready to assist the Bureau of Land Management in refining these regulations to ensure they are scientifically defensible, operationally practical, and focused squarely on the long-term health of our nation's public rangelands. True adaptive management is an ecological necessity, but it can only be achieved by empowering qualified field professionals, honoring localized data, and maintaining flexibility in the face of a changing environment. 

\Sincerely,

John Walker, Ph.D.

President, Society for Range Management