Stop overgrazing damage across six Nevada public land areas
Basalt, Belleville, Little Huntoon, McBride Flat Allotments, and McBride Unallotted Area
Bureau of Land Management· Basalt Allotment, Belleville AllotmentBLM NEPA Register DOI-BLM-NV-C010-2025-0013-EA ↗
BLM ePlanningWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
4 groups work Nevada
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Center for Biological Diversity
Works Nevada: sued the Bureau of Land Management in March 2024 over its failure to complete the overdue management plan for Basin and Range National Monument..
- Friends of Nevada Wilderness
Works Nevada: campaigned for the 2015 designation and petitioned Nevada's governor and senators to remove Basin and Range from the federal monument review..
- Friends of Red Rock Canyon
Works Nevada: they work only in Nevada.
- Tahoe Rim Trail Association
Works Nevada: nevada is one of the 2 states they work in.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
New grazing rules for six areas near Stillwater, Nevada will determine how hard livestock hit these public lands.
What’s at risk
Rangeland health, wildlife habitat, and recreational access across the Basalt, Belleville, Little Huntoon, and McBride Flat allotments are at stake. Stocking rates and permit terms set here will shape how much grazing pressure these lands absorb.
If this goes through
If approved without strong limits, the grazing plan locks in livestock use levels that can degrade soil, water, and wildlife habitat on these Nevada public lands for years.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
10 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The document claims wild horse and burro use was the sole causal factor for rangeland health standard failures, yet simultaneously proposes livestock grazing as the solution. Section 1.2 states the LHA found wild horse and burro use as the causal factor, but the proposed action adds 5,675 total AUMs of cattle grazing to lands already degraded by wild horses and burros. The agency provides no quantitative analysis showing how adding livestock grazing to degraded land currently dominated by wild horse/burro pressure will improve rather than compound the problem. The agency should conduct a comparative analysis of forage consumption: quantify wild horse/burro AUMs currently using the allotments versus the new cattle AUMs, and explain the mechanism by which adding grazing pressure will reverse degradation caused by existing grazing pressure.
- The document bases the proposed 2-year rotation on Indian Ricegrass utilization thresholds (60% in dormant season, 40% in growing season) without establishing these thresholds are appropriate for the allotments' specific ecological sites. Section 3.2.3.1 references a single Utah State University extension paper for the utilization percentages but does not present site-specific vegetation monitoring data, soil type analysis, or precipitation regime analysis supporting why these particular thresholds apply to Nevada's Mineral County conditions. The agency should provide allotment-specific justification for the utilization thresholds or conduct additional monitoring to establish appropriate thresholds before permit issuance.
- The document acknowledges monitoring triggers will require cattle removal when key species utilization reaches thresholds, creating financial burden on the permittee, yet claims this will not cause livestock reduction. Section 3.3.3.1 states early removal triggers could require supplemental private land forage, creating financial strain, but then asserts this would not burden the permittee. The document offers no analysis of whether a ranching operation can remain economically viable under a permit requiring unpredictable early livestock removal each season, nor does it analyze what happens to the permit if repeated early removals make the operation unfeasible. The agency should analyze the economic sustainability of the adaptive management triggers or modify triggers to ensure permit viability.
- The document proposes spring exclosures and riparian protection but provides no baseline data on current riparian health or quantitative riparian health goals beyond vague references to Proper Functioning Condition. Section 3.6.2 lists riparian and wetland areas on the Belleville allotment but Section 3.6.3.1's long-term objectives state springs should achieve PFC for 75% of key springs, without specifying current PFC ratings, the specific springs, or timelines for achieving this goal. The agency should provide: baseline PFC assessments for each identified spring, map of springs targeted for exclosure, and specific measurable objectives with timelines for each spring.
Show all 12 points from the document
- The document proposes conifer removal on 22,508 acres but acknowledges only Phase I and II encroachment areas would be treated, yet provides no map, acreage breakdown, or analysis of actual treatment areas. Section 2.1 and Table 2 reference a 5km springs-buffered map in Appendix D but state only sites with Phase I or II encroachment would be treated without quantifying what portion of the 22,508 acres actually qualifies. Section 3.7.2 and 3.7.3.1 analyze fuels impacts but do not disclose how many acres will actually receive treatment or the location and timing of treatments. The agency should disclose the actual planned acreage for conifer removal, provide specific treatment locations and phases, and analyze fuels and wildlife impacts based on the actual (not potential) treatment area.
- The document states the LHA found standards not being met as early as 2006 on two allotments but remained vacant for nearly 20 years, yet provides no explanation for this gap or analysis of what degradation occurred during this period. Section 3.3.2 mentions LHAs for Little Huntoon and Belleville showed standards being met in 2006, but the allotments became vacant after the Forest Enhancement Act. The document does not explain why the BLM allowed lands it knew were not meeting standards (per the recent 2017-2023 LHA) to remain unmanaged for two decades, or how land that met standards in 2006 transitioned to failing standards by 2023. The agency should explain the timeline of standard attainment/failure and justify why rangeland health monitoring was discontinued for 17 years.
- The document proposes a forage bank reserve alternative (Alternative Four) that is nearly identical to the preferred alternative but with lower confidence in maintenance, yet fails to analyze why a 10-year permit is superior to temporary 2-year permits for range improvement completion and maintenance. Section 2.4 and 3.2.3.4 acknowledge that without long-term permittee engagement, range improvements would be less likely to be completed and maintained, yet the document does not quantify this difference or explain how the agency will ensure improvements are maintained under the preferred alternative given previous allotment vacancy. The agency should analyze whether requiring range improvement completion as a prerequisite for annual turnout authorization would ensure improvement functionality regardless of permit length.
- The document identifies nine BLM sensitive plant species with potential to occur on the allotments, including two riparian-dependent species (Sodaville Milkvetch and Mojave Thistle), but provides no site-specific surveys confirming presence or absence of these species prior to permit issuance. Section 3.2.2 lists sensitive species habitat requirements and known distributions but states surveys were not conducted to determine whether these species actually occur on the allotments. The document relies on general habitat descriptions rather than field verification, creating risk of unanalyzed impacts to sensitive species. The agency should require presence/absence surveys for sensitive plant species before range improvement construction and provide species-specific management prescriptions in the permit.
- The document proposes interim management allowing 10 percent livestock drift into closed pastures for the first two years, but provides no analysis of whether this tolerance is appropriate or how it will be monitored. Section 2.1 states interim management would allow 10% drift onto closed pastures to account for expected drift before drift fences are identified, but does not explain how the 10% figure was determined, how drift will be monitored, or what triggers adjustment. This creates uncertainty about actual livestock distribution and grazing intensity during the critical establishment period. The agency should justify the 10% drift allowance with reference to peer-reviewed research or baseline monitoring data, and specify monitoring methods and trigger points for adjusting or eliminating the interim provision.
- The document's analysis of Bi-State Sage-Grouse impacts relies on a single 2025 study (Conway et al.) showing grazing does not negatively impact sage-grouse, but does not address the documented negative impacts of conifer encroachment on sage-grouse while proposing only Phase I and II conifer removal. Section 3.4.3.1 cites Conway et al. 2025 to support the conclusion that well-managed grazing is compatible with sage-grouse, yet earlier in the document (Section 3.7.1) cites Coates 2017 confirming conifer encroachment negatively impacts sage-grouse. The document acknowledges Miller Mountain is historic sage-grouse habitat but confirms no conifer treatments were planned there despite conifer encroachment being identified as a threat. The agency should analyze why Miller Mountain historic habitat is excluded from treatment and provide a timeline for conifer removal in all identified…
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
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