The Grazing toolbox is a ‘work in progress’ and represents information available to date on this subject. Contact us to suggest new materials for inclusion.



This toolbox is intended to facilitate the management of permitted grazing operations within designated wilderness areas. It is not intended as guidance in the application of grazing as a management technique (e.g., controlling non-native invasive plants), though some of the material presented here may be useful in such circumstances. Neither is it intended as guidance on the grazing of recreational stock or management of wild horses and burros, though a document on monitoring grazing impacts from recreational stock has been included as it may be of use in analyzing similar impacts from non-recreational livestock.

Materials in this toolbox originally created by either the Bureau of Land Management or Forest Service are largely interchangeable between agencies. Few wilderness areas managed by the Fish & Wildlife Service or the National Park Service have traditional permitted grazing operations, so some material in this toolbox may not be applicable to wilderness stewards in those agencies. In any case, be sure to check your agency's policies and the enabling legislation of you wilderness


Congressional Guidelines

Case Law

Forest Guardians v. APHIS, USFS, 2000 WL 34510092 Forest Guardians v. Animal & Plant Health Inspection Serv., 309 F.3d 1141, (9th Cir. 2002)

Topic: Killing predators to protect livestock (use)

Background: In 1984, Congress designated an area of the Coronado National Forest in Arizona as the Santa Teresa Wilderness. See Arizona Wilderness Act of 1984, Pub.L. No. 98-406, § 101(a)(23), 98 Stat. 1485. In May 1997, the Regional Forester delegated authority to APHIS to perform predator control in wilderness areas, including the Santa Teresa Wilderness, to "prevent serious losses of domestic livestock." The Regional Forester defined "serious loss" as "a determination made by APHIS or State Game and Fish after investigations, historical evidence and patterns of loss show the habitual nature of kills." APHIS killed six mountain lions between July 18, 1997, and March 22, 1999, at the request of a rancher who grazed cattle within the Santa Teresa Wilderness. A coalition of conservation organizations and one individual ("Forest Guardians") sought to enjoin this practice on the ground that it violates the Wilderness Act. Forest Guardians also claimed that APHIS and the Forest Service failed to conduct adequate environmental studies - as required by the National Environmental Policy Act ("NEPA") - before deciding to kill the mountain lions.

Holding: The Circuit Court affirmed the District Court's decision, which ruled that predator control is allowed in wilderness where necessary to support pre-existing grazing operations. The Forest Service did not need a NEPA document that solely addressed predator control in the Santa Teresa Wilderness, but could rely on a statewide analysis that specifically addressed predator control in multiple Wilderness areas.

Key Language: "The district court did not err in concluding that the Forest Service may authorize APHIS to perform lethal predator control of mountain lions in the Santa Teresa Wilderness in order to protect private livestock. Nor did it err by allowing predator control in areas where it had not been used in the past. The Wilderness Act of 1964 and the Arizona Wilderness Act of 1984 do not expressly prohibit predator control in wilderness areas. 16 U.S.C. §§ 1131-1136; Arizona Wilderness Act § 101(a)(23), (f)(1); H.R.Rep. No. 96-617, at 10-13 (1979). They do, however, allow pre-existing grazing operations to continue in areas later designated as wilderness. See Arizona Wilderness Act § 101(f)(1). We agree with the Forest Service that 'private livestock grazing implicitly includes operations to support that grazing, such as lethal control of predators.'" "We therefore defer to the Forest Service's conclusion that the Act authorizes predator control as one of the "flexible opportunities to manage grazing in a creative and realistic site specific fashion."