UNAUTHORIZED 

GRAZING

Actions Needed to 

Improve Tracking and 

Deterrence Efforts

Report to the Committee on Natural 

Resources, House of Representatives

July 2016

GAO-16-559

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-559, a report to the 

Committee on Natural Resources, House of 

Representatives

July 2016

UNAUTHORIZED GRAZING

Actions Needed to Improve Tracking and 

Deterrence Efforts

What GAO Found

The frequency and extent of unauthorized grazing on Bureau of Land 

Management (BLM) and U.S. Forest Service lands are largely unknown because 

according to agency officials, the agencies prefer to handle most incidents 

informally (e.g., with a telephone call) and do not record them. The agencies’ 

databases contained information on nearly 1,500 incidents of unauthorized 

grazing where formal action was taken by the agencies’ range program or law 

enforcement staff for grazing years 2010 through 2014 (March 1 to February 28). 

Unauthorized grazing incidents were recorded in the agencies’ databases when 

the agencies billed a penalty for unauthorized grazing or prepared a law 

enforcement report. However, agency staff told GAO that they handle most

incidents informally—their preferred practice—and do not record them in 

databases or consistently in paper files, because, in part, they do not consider it 

a priority. As a result, the agencies have incomplete information on the extent of 

unauthorized grazing. Federal internal control standards call for clear 

documentation of all transactions and other significant events. Until the agencies 

require that all incidents of unauthorized grazing be recorded, including those 

incidents resolved informally, BLM and the Forest Service will not have a 

complete record of unauthorized grazing incidents with which to identify any 

potential pattern of violations.

GAO found that the agencies’ preferred practice of informally resolving 

unauthorized grazing is not provided for under agency regulations. Specifically, 

the regulations do not provide the flexibility to resolve incidents informally without 

a written notice of violation (in the case of BLM) and without charging 

unauthorized grazing penalties (in the case of the Forest Service). Most agency 

staff told GAO that informal resolution is the most effective way to resolve nonwillful unauthorized grazing (e.g., when livestock stray outside of their permitted 

area and graze in an unauthorized area). As discussed in federal internal control

standards, program operations are effective and efficient in achieving agency 

objectives when they produce the intended results and minimize the waste of 

resources. By amending regulations to establish a procedure for the informal 

resolution of minor infractions, the agencies could achieve the objective of 

efficiently resolving such incidents with minimal conflict within its regulatory 

authority. Alternatively, rather than amending their existing regulations to match 

their practices, the agencies’ could change their practices to comply with their 

existing regulations. In addition, BLM and the Forest Service undertake similar 

efforts to detect and deter unauthorized grazing, such as conducting compliance 

inspections and assessing penalties for unauthorized grazing, but agency staff 

said that such efforts have limited effectiveness. For example, most of the Forest 

Service staff GAO interviewed said that unauthorized grazing penalties are too 

low to act as an effective deterrent. Under current policy, the Forest Services’ 

unauthorized grazing penalty formula calculated a negative number or a number 

less than the permitted grazing fee for grazing years 2009 through 2012. By 

adopting an unauthorized grazing penalty structure that is, like BLM’s, based on 

the current price of private forage, the Forest Service’s unauthorized grazing 

penalty can better serve as a deterrent to such grazing. View GAO-16-559. For more information, 

contact Anne-Marie Fennell at (202) 512-3841 

or fennella@gao.gov.

Why GAO Did This Study

BLM, within the Department of the 

Interior, and the U.S. Forest Service, 

within the Department of Agriculture, 

are responsible for managing most of 

the nation's public rangelands. 

Ranchers must obtain permits or 

leases from the agencies to graze 

livestock on federal lands. 

Unauthorized grazing may take various

forms, such as grazing more livestock 

than permitted or grazing without a 

permit.

GAO was asked to examine 

unauthorized grazing. This report 

(1) describes what is known about the 

frequency and extent of unauthorized 

grazing, and its effects, and 

(2) examines the agencies’ efforts to 

detect, deter, and resolve unauthorized 

grazing. GAO analyzed 5 years of the 

most recent data available on incidents 

where the agencies had taken formal 

action on unauthorized grazing 

(grazing years 2010 through 2014); 

examined federal laws and agency 

regulations, policies, and practices; 

and interviewed by telephone or site 

visit officials in a nongeneralizable 

sample of 22 agency field offices in 

eight western states where most 

unauthorized grazing had occurred.

What GAO Recommends

GAO is making six recommendations, 

including that the agencies take 

actions to record all incidents of 

unauthorized grazing, that they amend 

regulations to reflect their practices for 

resolving such incidents or comply with 

their regulations, and that the Forest 

Service revise its unauthorized grazing 

penalty structure. The agencies

generally agreed with GAO’s findings 

and recommendations.
Page i GAO-16-559 Unauthorized Grazing

Letter 1

Background 4

The Frequency and Extent of Unauthorized Grazing on Agency 

Lands Are Largely Unknown, and Its Effects May Include 

Rangeland Degradation 12

Agencies’ Efforts to Detect, Deter, and Resolve Unauthorized 

Grazing Have Shortcomings That Limit Their Effectiveness 22

Conclusions 30

Recommendations for Executive Action 31

Agency Comments 32

Appendix I Objectives, Scope, and Methodology 33

Appendix II Grazing Information for the Bureau of Land Management and 

U.S. Forest Service 37

Appendix III Detailed Information on the Extent and Frequency of Unauthorized 

Grazing 52

Appendix IV Comments from the Department of Agriculture 60

Appendix V Comments from the Department of the Interior 61

Appendix VI GAO Contact and Staff Acknowledgments 63

Tables

Table 1: Number of Unauthorized Grazing Incidents Where 

Formal Action Was Taken by the Bureau of Land 

Management and U.S. Forest Service, Grazing Years 

2010–2014 12

Contents
Page ii GAO-16-559 Unauthorized Grazing

Table 2: Bureau of Land Management’s and U.S. Forest Service’s 

Permitted Grazing Fee and Unauthorized Grazing 

Penalties, Grazing Years 2001–2016 24

Table 3: Bureau of Land Management Field Offices Where GAO 

Conducted Interviews from August 2015 through January 

2016 35

Table 4: U.S. Forest Service Field Offices Where GAO Conducted 

Interviews from August 2015 through January 2016 35

Table 5: Bureau of Land Management (BLM) Data on Acres and 

Animal Unit Months (AUM) by Field Office as of January 

2016 and AUMs Billed for Fiscal Year 2014 38

Table 6: U.S. Forest Service Data on Acres and Animal Unit 

Months (AUM), by Forest and Grassland, Grazing Year 

2015 43

Table 7: Number of Bureau of Land Management Grazing Permits 

and Leases by Size, as of December 2015 47

Table 8: Number of U.S. Forest Service Cattle Permits by Size, 

Grazing Year 2015 48

Table 9: Number of U.S. Forest Service Sheep Permits by Size, 

Grazing Year 2015 48

Table 10: U.S. Forest Service’s Formula Results for Permitted 

Grazing Fees and Unauthorized Grazing Penalties, 

Grazing Years 2001–2016 51

Table 11: Bureau of Land Management Range Program 

Unauthorized Grazing Incidents by State Office, Grazing 

Years 2010–2014 52

Table 12: Bureau of Land Management Range Program 

Unauthorized Grazing Charges by Type and Grazing 

Year, 2010–2014 53

Table 13: Status of the Bureau of Land Management Range 

Program’s Unauthorized Grazing Bill Charges Issued for 

Grazing Years 2010–2014 54

Table14: Bureau of Land Management Range Program 

Compliance Inspections by State Office and Outcome, 

Grazing Years 2010–2014 55

Table 15: Bureau of Land Management Law Enforcement 

Unauthorized Grazing Incidents by State Office and 

Grazing Year, 2010–2014 56

Table 16: U.S. Forest Service Range Program Unauthorized 

Grazing Incidents by Region, Grazing Years 2010–2014 56

Table 17: U.S. Forest Service Range Program Unauthorized 

Grazing Incidents by Type and Grazing Year, 2010–2014 57
Page iii GAO-16-559 Unauthorized Grazing

Table 18: Amount Collected from the U.S. Forest Service’s Range 

Program Unauthorized Grazing Charges, by Type, 

Grazing Years 2010–2014 58

Table 19: U.S. Forest Service Law Enforcement Grazing Incidents 

by Region, Grazing Years 2010–2014 58

Table 20: U.S. Forest Service Law Enforcement Unauthorized 

Grazing Incidents by Type and Grazing Year, 2010–2014 59

Figures

Figure 1: Bureau of Land Management State Offices and Their 

Administrative Jurisdictions 5

Figure 2: U.S. Forest Service Regions and Their Administrative 

Jurisdictions 6

Figure 3: Unauthorized Grazing on Protected Habitat in New 

Mexico, 2015 17

Figure 4: Unauthorized Grazing on Protected Habitat and 

Overgrazed Vegetation in New Mexico, 2015 18

Figure 5: Before and After Unauthorized Grazing on a Riparian 

Area, Oregon, 2015 19

Figure 6: Protest Site at Bureau of Land Management Office, 

Nevada, 2015 21

Abbreviations

AUM animal unit month

BLM Bureau of Land Management

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Page 1 GAO-16-559 Unauthorized Grazing

441 G St. N.W.

Washington, DC 20548

July 7, 2016

The Honorable Rob Bishop

Chairman

The Honorable Raúl Grijalva

Ranking Member

Committee on Natural Resources

House of Representatives

Since the early 1900s, the federal government has required ranchers to 

pay a fee for grazing their livestock on millions of acres of federal land, 

primarily in western states. These ranchers must obtain permits or leases 

from the responsible federal agencies to graze livestock on federal lands, 

and must comply with the conditions of these permits or leases, such as 

grazing their livestock in the permitted numbers and locations, to help 

protect and preserve the range for multiple uses, such as sustainable 

grazing. Unauthorized grazing may take several forms, such as grazing 

during unauthorized times of the year, grazing more livestock than 

allowed by permit, or grazing outside of permitted areas or in areas 

closed to livestock. Such unauthorized grazing may be unintentional, 

such as when livestock stray outside of their permitted area through a 

broken fence and graze in an unauthorized area. In some cases 

unauthorized grazing is intentional, such as when ranchers purposely 

overstay their permitted grazing period or ranchers without permits 

purposely allow their livestock onto federal lands. Several recent highprofile incidents of intentional unauthorized grazing, including 

confrontations between ranchers and federal officials, have drawn 

attention to the extent and effects of unauthorized grazing.

The Bureau of Land Management (BLM), within the Department of the 

Interior, and the U.S. Forest Service, within the Department of Agriculture, 

are responsible for managing most of the nation’s public rangelands. 

Under the Taylor Grazing Act of 1934 for BLM and, among other statutes, 

the Organic Act of 1897 for the Forest Service, livestock grazing became 

a regulated activity.1 Both agencies administer grazing programs that 

allow ranchers to obtain permits, leases, or other permissions to graze 

 1

See 43 U.S.C. § 315 and 16 U.S.C. § 551.

Letter
Page 2 GAO-16-559 Unauthorized Grazing

their livestock on federal lands. BLM has the larger grazing program, 

administering about 17,600 grazing permits on 153 million acres in 

grazing year 2015; the Forest Service administered about 6,200 grazing 

permits on 102 million acres in grazing year 2015.2 As the administrators 

of their grazing programs, the agencies are responsible for detecting and 

deterring unauthorized grazing. In response to unauthorized grazing, the 

agencies’ staff may impose penalties against permittees and modify or 

cancel grazing permits.3 In addition, the agencies’ law enforcement 

officers may cite permittees or nonpermittees for violations that subject 

them to criminal penalties for unauthorized grazing.

In December 1990, we reported on BLM’s efforts to detect and deter 

unauthorized livestock grazing on public rangelands.4 We found that 

because many grazing areas were inspected infrequently or not at all 

during the year, offenders were not likely to be detected. When offenders 

were detected, BLM frequently exacted no penalties and, for the more 

serious violations, seldom assessed the minimum penalties its own 

regulations required. As a result, unauthorized grazing was not 

adequately deterred, which could lead to degradation of public 

rangelands, among other things. In our December 1990 report, we made 

five recommendations to improve BLM’s ability to prevent unauthorized 

grazing. BLM agreed with the recommendations and implemented one of 

the five. The agency took steps toward implementing some of the others, 

but did not fully implement the remaining four recommendations.

You asked us to update our December 1990 report and review BLM’s and 

the Forest Service’s efforts to address unauthorized grazing. This report 

(1) describes what is known about the frequency and extent of 

unauthorized grazing, and its effects, and (2) examines the agencies’

efforts to detect, deter, and resolve unauthorized grazing.

 2

A grazing year for billing purposes is March 1 to February 28 of the following calendar 

year. For example, grazing year 2016 covers the period of time from March 1, 2016, to 

February 28, 2017.

3

For the purposes of this report, we use “penalties for unauthorized grazing” to describe 

the monetary settlement costs based on usage rates applied by the agencies.

4

GAO, Rangeland Management: BLM Efforts to Prevent Unauthorized Livestock Grazing 

Need Strengthening, GAO/RCED-91-17 (Washington, D.C.: Dec. 7, 1990). This 

December 1990 report focused solely on BLM; grazing on Forest Service lands was not 

covered in the report.
Page 3 GAO-16-559 Unauthorized Grazing

To describe what is known about the frequency and extent of 

unauthorized grazing, we analyzed the agencies’ unauthorized grazing 

data, and to describe the effects of such grazing, we reviewed 

documentation, interviewed agency officials and stakeholder group 

representatives, and conducted site visits at agency field office locations. 

Specifically, we collected data from BLM’s and the Forest Service’s range 

management, financial, and law enforcement databases on the frequency 

and extent of unauthorized grazing for grazing years 2010 through 2014, 

the most recent and complete data available at the time of our review. 

We assessed the data provided by the agencies based on our review of 

database system documentation and discussions with agency database 

stewards and found the data to be sufficiently reliable for our purposes. 

We conducted in-person or telephone interviews with staff at 22 of the 

218 agency field office locations in eight western states: California, 

Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and Wyoming. We 

selected the 22 offices (13 BLM and 9 Forest Service offices) from among 

the agency field offices that had the highest numbers of unauthorized 

grazing incidents or that had been recommended by stakeholders. Of the 

22 offices, we conducted site visits at 6 offices in Nevada and Wyoming 

to interview agency range management and law enforcement staff about 

the agencies’ policies and practices for addressing unauthorized grazing, 

as well as to review paper case files and observe the effects of 

unauthorized grazing on federal lands. We conducted telephone 

interviews with staff in the remaining 16 of the 22 BLM and Forest Service 

field offices. Our interview results are not generalizable to all agency field 

office locations and grazing lands and instead are illustrative cases of the 

office locations reporting the highest number of unauthorized grazing 

incidents. We also interviewed representatives from 11 stakeholder 

groups, selected based on their interest in grazing issues.5

To examine the agencies’ efforts to detect, deter, and resolve 

unauthorized grazing, we analyzed federal laws to identify agency 

requirements for addressing unauthorized grazing, as well as the 

agencies’ regulations, policies, and practices. We qualitatively analyzed 

information obtained in agency and stakeholder interviews for common 

themes and patterns to describe how the agencies address unauthorized 

 5

The stakeholders we interviewed primarily represented cattlemen’s associations and 

rangeland, wild horse, and federal employee advocate groups.
Page 4 GAO-16-559 Unauthorized Grazing

grazing and the effectiveness of their efforts. We compared the agencies’

policies to their practices in the field, compared the policies’ objectives 

with their outcomes, and assessed the internal controls for the policies 

and practices. See appendix I for a more detailed description of our 

objectives, scope, and methodology.

We conducted this performance audit from May 2015 to July 2016 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The federal government manages about 640 million acres of land in the 

United States, including lands in national forests, grasslands, parks, 

refuges, reservoirs, and military bases and installations. Of the total 

federal lands, BLM and the Forest Service manage about 450 million 

acres for multiple uses, including grazing,6 timber harvest, recreation, 

minerals, water supply and quality, and wildlife habitat. BLM’s 12 state 

offices manage nearly 250 million acres in 12 western states, and the 

Forest Service’s 9 regional offices manage more than 190 million acres 

across the nation (see figs. 1 and 2).7 The majority of federal lands are 

located in the western half of the country.

 6

As we noted in September 2005, 10 federal agencies have programs to allow private 

ranchers to graze livestock on portions of the lands they manage: the Department of the 

Interior’s BLM, National Park Service, U.S. Fish and Wildlife Service, and Bureau of 

Reclamation; the Department of Agriculture’s U.S. Forest Service; the Department of 

Energy; and the Department of Defense’s Army, Army Corps of Engineers, Air Force, and 

Navy. See GAO, Livestock Grazing: Federal Expenditures and Receipts Vary, Depending 

on the Agency and the Purpose of the Fee Charged, GAO-05-869 (Washington, D.C.: 

Sept. 30, 2005). The report reviewed all10 federal agencies that manage grazing; BLM 

and the Forest Service managed 98 percent of federal land used for grazing.

7

Generally, there are 17 states, including the Great Plains states, considered to be 

western: Arizona, California, Colorado, Idaho, Kansas, Montana, Nebraska, New Mexico, 

Nevada, North Dakota, Oklahoma, Oregon, South Dakota, Texas, Utah, Washington, and 

Wyoming. However, depending on the situation, western states can be grouped and 

counted differently. Each of BLM’s state offices and Forest Service’s regional offices has 

field office locations.

Background
Page 5 GAO-16-559 Unauthorized Grazing

Figure 1: Bureau of Land Management State Offices and Their Administrative Jurisdictions
Page 6 GAO-16-559 Unauthorized Grazing

Figure 2: U.S. Forest Service Regions and Their Administrative Jurisdictions

Note: The Forest Service has no Region 7.
Page 7 GAO-16-559 Unauthorized Grazing

The federal government has managed grazing on federal lands for more 

than 100 years. Following the passage of the Taylor Grazing Act of 1934, 

the Department of the Interior created the Division of Grazing, later 

renamed the Grazing Service, to administer provisions of the act. 

Subsequently, the Grazing Service was merged with the General Land 

Office to form BLM. The act was passed to stop degradation of public 

lands caused by overgrazing and soil deterioration; to provide for the 

orderly use, improvement, and development of public lands; and other 

purposes. The act also provided for the issuance of permits and leases 

for these lands and set requirements for the distribution of funds received 

from grazing. The Forest Service managed grazing under its general 

authorities until 1950, when Congress enacted the Granger-Thye Act, 

specifically authorizing the Secretary of Agriculture to issue grazing 

permits on national forest lands and other lands under the department’s 

administration. Additional laws affecting grazing on both BLM and 

western Forest Service lands were enacted in the 1970s.8

BLM’s and the Forest Service’s range grazing programs administer 

livestock grazing for permittees.9 Agency law enforcement assists when 

necessary—primarily to address grazing violations by nonpermittees that 

cannot be handled administratively. To provide access to grazing, the 

agencies divide their rangelands into allotments, which can vary in size 

from a few acres to hundreds of thousands of acres. Because of the land 

ownership patterns that occurred when the lands were settled, the 

allotments can be adjacent to private lands or intermingled with private 

lands. Under its authorities, BLM issues permits for grazing in allotments 

within its grazing districts and leases for grazing on BLM-administered 

lands outside grazing districts. To be eligible for a permit or lease on one 

of BLM’s allotments, ranchers, among other things, are required to own or 

control land or water, called a base property, to which preference for 

 8

For example, the Federal Land Policy and Management Act of 1976 limited the length 

of permits and leases to 10 years and allowed shorter terms, authorized terms, and 

conditions to be placed on a permit or lease and allowed seasonal limits on grazing. 

Pub. L. No. 94-579, § 402, 90 Stat. 2743, 2773. The Public Rangelands Improvement Act 

of 1978 required BLM and the Forest Service to inventory their lands in western states. 

Pub. L. No. 95-514, § 4, 92 Stat. 1803, 1804.

9

BLM primarily manages grazing in 11 western states: Arizona, California, Colorado, 

Idaho, Montana, New Mexico, Nevada, Oregon, Utah, Washington, and Wyoming. The 

Forest Service manages grazing on forests in 16 western states, eastern states (including 

Texas), and the national grasslands.
Page 8 GAO-16-559 Unauthorized Grazing

obtaining a permit or lease is attached. The Forest Service, which does 

not have grazing districts, uses permits to authorize grazing in its 

allotments.10 To be eligible for a permit under Forest Service policy, 

ranchers, among other things, must own base property and the livestock 

to be permitted. The agencies’ permits and leases specify the number 

and type of livestock allowed on the allotments, the time and duration of 

use for grazing, and special conditions or use restrictions. Agency field 

office staff conduct compliance inspections to help ensure that permittees 

are meeting the terms and conditions of their permits or leases.11 The 

agencies may modify permits or leases if range conditions are being 

degraded or suspend or cancel them if permit conditions are violated.

With a few minor exceptions, permittees pay a grazing fee for the use of 

the federal land. The grazing fee BLM and the Forest Service charge in 

western states is based on a formula that was originally established by 

law to prevent economic disruption and harm to the western livestock 

industry, among other things. The formula expired after 7 years but 

was extended indefinitely by Executive Order 12,548 and has been 

incorporated into the agencies’ regulations.12 The fee derived from the 

formula is generally lower than the fees charged by other agencies, 

states, and private ranchers. In grazing year 2016, BLM charged ranchers 

$2.11 per animal unit month for horses/cattle and $0.42 for sheep and 

goats; the Forest Service charged the same rates per head month.13

According to the National Agricultural Statistics Service, based on the 

average private grazing land lease rate per animal unit month, the 

commercial value of forage in western states ranged from $9 to $39 in 

grazing year 2016. As we found in September 2005, the total grazing fees 

generated by federal agencies amounted to less than one-sixth of the 

 10The Forest Service refers to these as term permits.

11To conduct compliance inspections, field staff visit grazing allotments and check 

whether the proper number of livestock are in the correct locations. According to agency 

field staff we interviewed, such inspections may occur randomly; at designated times 

before, during, or after the grazing season; or in response to reports of potential permit 

violations.

12The Public Rangelands Improvement Act of 1978, Pub. L. No. 95-514, 92 Stat. 1803, 

and Exec. Order No. 12,548, 51 Fed. Reg. 5985 (Feb. 14, 1986).

13Treated as equivalent measures for fee purposes, BLM’s animal unit month and the 

Forest Service’s head month refer to the amount of forage a cow and her calf, one horse, 

or five sheep eat in a month.
Page 9 GAO-16-559 Unauthorized Grazing

agencies’ expenditures to manage grazing in 2004.14 We found that BLM 

and the Forest Service use most of the grazing fee receipts for range 

protection and improvements and deposit some receipts to the

Department of the Treasury’s general fund, with some receipts distributed 

to states and counties. See appendix II for additional information on 

grazing, permits, and fees for BLM and the Forest Service.

Unauthorized grazing includes instances in which livestock owners graze 

on BLM or Forest Service allotments without a permit or lease, as well as 

instances in which those with permits or leases violate the terms and 

conditions of those documents, such as by grazing more livestock than 

allowed by permit, grazing in areas that are closed to livestock, or grazing 

during unauthorized times of the year. It may be unintentional (non-willful) 

on the part of the livestock owner, such as when livestock stray through 

an unlatched gate into an area where they are not permitted to graze, or 

it may be intentional (willful or repeated willful) such as when a livestock 

owner purposefully grazes livestock in a manner that is not allowed by a 

permit or grazes livestock without obtaining a permit once or multiple 

times.

Under their applicable regulations, BLM and the Forest Service may 

address unauthorized grazing by charging permittees penalties for 

unauthorized grazing; revising their permits; impounding livestock; or 

taking action that could lead to criminal penalties, most commonly for 

nonpermittees, as follows:

• BLM’s grazing regulations establish three levels of unauthorized 

grazing—non-willful, willful, and repeated willful—with progressively 

higher penalties for each level.15 The regulations require that BLM 

send out a written notice for every potential unauthorized grazing 

incident.16 Under certain circumstances, BLM can approve a 

 14GAO-05-869.

1543 C.F.R. §§ 4150.1(a); 4150.3(a), (b), (c) (2005).

1643 C.F.R. § 4150.2(a) (2005).
Page 10 GAO-16-559 Unauthorized Grazing

nonmonetary settlement for non-willful unauthorized grazing.17 For 

willful and repeated willful incidents, in addition to the monetary 

penalties—the value of the forage consumed—the regulations specify 

that the offender shall be charged for any damages to the land and 

reasonable agency expenses incurred to resolve the violation, and 

BLM shall suspend or cancel all or portions of the grazing permit for 

repeated willful incidents. BLM may impound and dispose of livestock 

if the owner is unknown or the permittee fails to remove the livestock 

when ordered. BLM also has the authority to cite permittees and 

nonpermittees for grazing violations that subject them to criminal 

penalties.18

• The Forest Service’s grazing regulations require the agency, except 

in certain circumstances, to determine a grazing use rate for 

unauthorized grazing.19 The regulations define unauthorized grazing 

as (1) livestock not authorized by permit to graze upon the land, (2) an 

excess number of livestock grazed by permittees, or (3) permitted 

livestock grazed outside the permitted grazing season or allotment.20

Under the regulations, the Forest Service can cancel or suspend a 

permit if the permittee does not comply with provisions and 

requirements in the grazing permit or applicable regulations. The 

agency can impound and dispose of unauthorized livestock or 

livestock in excess of those authorized by a grazing permit if they are 

not removed from the area within the periods prescribed by regulation. 

The Forest Service also has the authority to cite permittees and 

 17Under 43 C.F.R. § 4150.3(a) (2005), BLM may approve nonmonetary settlement of nonwillful unauthorized use violations if BLM determines that the unauthorized use occurred 

through no fault of the rancher, the forage use is insignificant, the public lands have not 

been damaged, and that nonmonetary settlement is in the best interest of the United 

States.

1843 C.F.R. § 4170.2-2 (2005).

1936 C.F.R. § 222.50(a), (h). The exceptions are in 36 C.F.R. § 222.3(c)(2)(ii)(B) through 

(G). The exceptions are for uses where the Chief of the Forest Service may issue free 

permits such as for research purposes and administrative studies and other incidental 

uses. The exceptions do not apply to unauthorized grazing. All unauthorized grazing on 

Forest Service lands should be charged a penalty.

20The Forest Service refers to violations by permittees as excess grazing and by 

nonpermittees as unauthorized grazing. For the purpose of this report, we are referring 

to all grazing violations by permittees or nonpermittees as unauthorized grazing.
Page 11 GAO-16-559 Unauthorized Grazing

nonpermittees for grazing violations that subject them to criminal 

penalties.21

In our December 1990 report on unauthorized grazing on BLM lands, we 

found that BLM had no systematic method for detecting unauthorized 

grazing, and when offenses were detected, penalties were rarely 

assessed.22 We made five recommendations to improve the effectiveness 

of the BLM’S unauthorized grazing detection and deterrence efforts:

• Develop an unauthorized grazing detection strategy that will 

(1) establish detection as a workload measure and a reportable 

accomplishment for which managers are held accountable, (2) use 

visits to randomly selected allotments to provide systematic 

compliance coverage, and (3) target additional follow-up visits for 

those livestock operators who have a history of repeated violations.

• Either (1) ensure that penalties are assessed for all non-willful 

unauthorized grazing violations as provided for in BLM regulations or 

(2) amend BLM regulations to establish a procedure for the informal 

resolution of non-willful unauthorized grazing violations at the local 

level.

• Require that all unauthorized grazing incidents—including those now 

handled informally—be documented and made part of the permanent 

unauthorized grazing file.

• Ensure that field staff impose the penalties required under BLM 

regulations for willful and repeated willful unauthorized grazing.

• Develop a management information system to provide timely, reliable, 

and adequate information on such things as (1) the number of 

compliance visits conducted, (2) the number and level of violations 

identified, and (3) how each violation is resolved, including those 

resolved informally.

BLM agreed with the recommendations and implemented one of the five 

by developing an unauthorized grazing detection strategy. The agency 

took steps toward implementing some of the others, but did not fully 

implement the remaining four recommendations.

 2136 C.F.R. pt. 261.

22GAO/RCED-91-17.
Page 12 GAO-16-559 Unauthorized Grazing

The frequency and extent of unauthorized grazing on BLM and Forest 

Service lands are largely unknown because according to agency officials 

the agencies prefer to handle most incidents informally and do not record 

them. The agencies’ databases contained information on nearly 

1,500 incidents of unauthorized grazing where formal action was taken 

by the agencies’ range program or law enforcement field staff for grazing 

years 2010 through 2014. Unauthorized grazing incidents were recorded 

in the range management databases when a penalty for unauthorized 

grazing was billed to a permittee by program staff and in the law 

enforcement databases when a formal report or notice was entered by 

a law enforcement officer. However, agency field staff told us that most 

incidents they identify are handled informally—their preferred practice—

and are not recorded in their databases or consistently recorded in paper 

files. Agency field staff told us that unauthorized grazing can severely 

degrade the range under certain conditions, such as drought, and also 

told us of other effects, such as creating conflicts between the agencies’

staff, ranchers, and other stakeholders.

The agencies’ databases identified nearly 1,500 incidents of unauthorized 

grazing where formal action was taken by range program staff or by 

agency law enforcement officers for grazing years 2010 through 2014; 

BLM data identified a total of 859 incidents, and Forest Service data 

identified 618 incidents (see table 1).

Table 1: Number of Unauthorized Grazing Incidents Where Formal Action Was 

Taken by the Bureau of Land Management and U.S. Forest Service, Grazing Years 

2010–2014

Unauthorized grazing incidents where 

formal action was taken

Agency

By grazing 

program staff

By law 

enforcement staff Total

Bureau of Land Management 433 426 859

U.S. Forest Service 190 428 618

Total 623 854 1,477

Source: GAO analysis of Bureau of Land Management and U.S. Forest Service data. | GAO-16-559

Notes: The grazing year used for billing grazing fees is March 1 to February 28.

The Bureau of Land Management’s and U.S. Forest Service’s rangeland grazing programs administer 

livestock grazing for permittees. Agency law enforcement assists when necessary—primarily to 

address grazing violations by nonpermittees that cannot be addressed administratively.

The unauthorized grazing incidents identified in the Bureau of Land Management’s range 

management database represent those incidents that occurred in grazing years 2010 through 2014 

and were settled and billed by December 28, 2015. The incidents identified in the U.S. Forest 

Service’s range management database represent all those incidents where a penalty for unauthorized 

The Frequency 

and Extent of 

Unauthorized Grazing 

on Agency Lands Are 

Largely Unknown, 

and Its Effects May 

Include Rangeland 

Degradation

Agency Databases 

Identified Nearly 1,500 

Incidents of Unauthorized 

Grazing Where Formal 

Action Was Taken from 

2010 to 2014
Page 13 GAO-16-559 Unauthorized Grazing

grazing was billed in grazing years 2010 through 2014. The incidents in the law enforcement 

databases of both agencies represent incidents where formal documentation, such as an incident 

report (record of observation), warning notice, or violation notice was prepared and entered by a law 

enforcement officer. The possibility exists that a limited number of incidents were recorded in both the 

grazing program and law enforcement databases.

The agencies’ grazing program field staff generally handle unauthorized 

grazing by permittees through their administrative process, and law 

enforcement officers primarily handle unauthorized grazing by those 

without permits through warnings or criminal citations. Each agency has 

separate range management and law enforcement databases. For 

example, unauthorized grazing is recorded in BLM’s range management 

database when a formal action is taken to send a bill to a permittee for 

penalties—and in some cases charges for damage to the land or to 

recoup the administrative expenses of the agency—for incidents of 

unauthorized grazing.23 In some cases, BLM may include penalties for 

more than one incident of unauthorized grazing in one bill. The Forest 

Service’s range management database contains incidents where a formal 

action was taken to send a bill for penalties for unauthorized grazing 

incidents. The law enforcement databases of both agencies contain 

incidents where formal documentation, such as an incident report (record 

of observation), warning notice, or violation notice was prepared by a law 

enforcement officer and entered into the database.24 See appendix III for 

detailed information on the extent and frequency of unauthorized grazing 

formally reported in the agencies’ databases.

 23Incidents that are resolved nonmonetarily are not in the database because no bill is 

generated. BLM does not maintain a central database of notices of violation sent to 

permittees.

24The possibility exists that some incidents were recorded in both the range management 

and law enforcement databases. For example, if a BLM law enforcement officer recorded 

observations of potential unauthorized grazing in an incident report that is entered in the 

law enforcement database, and then passed that information to the range program staff 

for resolution with a permittee, the incident may have been recorded in the program’s 

database when a bill was issued. Based on our analysis, such situations cannot be 

identified with certainty within the databases, but agency officials told us they are unlikely 

to occur frequently.
Page 14 GAO-16-559 Unauthorized Grazing

The full extent and frequency of unauthorized grazing is unknown 

because most unauthorized grazing incidents identified by the agencies’

range program field staff are handled informally and are not recorded in 

their databases, according to agency officials. We found that these 

incidents were inconsistently documented in their paper files.25 The 

databases do not include incidents that are informally resolved with 

telephone calls or by visits from the agency program staff to the 

permittees asking them to remove their livestock from areas where they 

are not permitted.26 Staff we interviewed from all 22 BLM and Forest 

Service field offices told us they prefer such informal resolutions, 

particularly for incidents that appear to be non-willful and involve a few 

head of livestock with no resource damage. Agency staff said that these 

types of incidents account for the majority of unauthorized grazing they 

encounter. According to these field staff, the informal resolution allows 

them to resolve the problem quickly and remain focused on higher-priority 

activities, such as preparing environmental analyses, while maintaining 

collaborative and cooperative relations with permittees, who field staff 

said are largely compliant with their permits.

Agency field staff from both agencies told us that they maintain paper files 

for permittees that may contain notes on informally resolved unauthorized 

grazing incidents that are not included in the databases, or may record a 

telephone call to a permittee in their telephone log. However, they said 

that such information is not consistently recorded in the permittee files, in 

part because they do not consider recording such information a priority. 

As a result, the agencies do not have complete information on 

unauthorized grazing and therefore may not have the documentation 

 25Law enforcement officers we spoke with from both agencies told us that they usually 

report suspected unauthorized grazing incidents to program staff and issue a warning or 

citation at program staff’s request.

26Agency field staff told us that other incidents that would not be recorded include those 

referred from the program to law enforcement where no enforcement action is taken and 

those worked out between permittees with no agency intervention. Incidents that go 

undetected by the agencies would also not be recorded.

Agencies Report Handling 

Most Unauthorized 

Grazing Incidents 

Informally and Do Not 

Record Them in Their 

Databases
Page 15 GAO-16-559 Unauthorized Grazing

needed to deal with any instances of repeat offenders appropriately.27

Federal internal control standards call for agencies to clearly document 

all transactions and other significant events in a manner that allows the 

documentation to be readily available for examination.28 This provides a 

means to retain organizational knowledge and mitigate the risk of having 

that knowledge limited to a few personnel, as well as a means to 

communicate that knowledge as needed to external parties, such as 

external auditors. Until the agencies require that all incidents of 

unauthorized grazing be recorded, including those incidents resolved 

informally, BLM and the Forest Service will not have a complete record 

of unauthorized grazing incidents for tracking patterns of any potential 

repeat offenders.

Unauthorized grazing may create various effects, such as severely 

degrading rangelands under certain conditions. Joint BLM/Forest Service 

riparian area management guidance states that compliance monitoring of 

grazing is critical because just a few weeks of unauthorized grazing can 

set back years of progress in restoring riparian areas29—such as the 

narrow bands of green adjoining rivers, streams, or springs. Agency field 

staff we interviewed from 17 out of the 22 offices told us that under 

certain circumstances, unauthorized grazing can be more damaging than 

permitted grazing, such as when livestock are allowed into closed riparian 

areas during times of low precipitation or drought or graze in pastures 

 27We recommended to BLM in 1990 that information on unauthorized grazing—including 

those incidents resolved informally—be documented. The agency agreed with, but has 

not implemented, the recommendation. We also recommended that BLM develop a 

management information system to provide timely, reliable, and adequate information on 

such things as (1) the number of compliance visits conducted; (2) the number and level 

of violations identified; and (3) how each violation is resolved, including those resolved 

informally. BLM developed the management information system but does not track 

unauthorized grazing incidents that are resolved informally in the system.

28GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). GAO has revised and reissued Standards for 

Internal Control in the Federal Government, with the new revision effective as of October 

1, 2015. GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).

29Bureau of Land Management and U.S. Forest Service, Riparian Area Management: 

Grazing Management for Riparian-Wetland Areas, Technical Reference TR-1737-14 

(1997).

Unauthorized Grazing May 

Degrade Rangelands 

under Certain Conditions 

and Can Cause Conflicts 

between the Agencies, 

Ranchers, and 

Stakeholders, among 

Other Effects
Page 16 GAO-16-559 Unauthorized Grazing

earlier than permitted in the spring when grass is first sprouting. 

Stakeholders told us that the loss of native grass through unauthorized 

overgrazing may allow invasive species such as cheatgrass to grow, 

creating a potential fire hazard, or may result in a loss of habitat for 

threatened species such as sage grouse. During our field visits, we 

observed locations where unauthorized grazing had resulted in severely 

damaged natural springs, overgrazed meadows, and trampled 

streambeds. Agency field staff provided photographs showing 

unauthorized grazing in protected habitat areas and the effects of 

overgrazing from unauthorized use (see figs. 3, 4, and 5).
Page 17 GAO-16-559 Unauthorized Grazing

Figure 3: Unauthorized Grazing on Protected Habitat in New Mexico, 2015
Page 18 GAO-16-559 Unauthorized Grazing

Figure 4: Unauthorized Grazing on Protected Habitat and Overgrazed Vegetation in 

New Mexico, 2015
Page 19 GAO-16-559 Unauthorized Grazing

Figure 5: Before and After Unauthorized Grazing on a Riparian Area, Oregon, 2015

Agency staff and stakeholders told us that unauthorized grazing can 

strain relationships and cause conflicts among various groups. Various 

stakeholders, such as range protection advocates and others, told us 

that they often observe unauthorized livestock grazing on the agencies’

allotments in the course of their resource monitoring or other activities 

and notify agency field staff. They are frustrated when it appears that the 

agencies do not take action. Agency staff we interviewed from 15 out of 

the 22 field offices told us that they are not always able to confirm and 

take action on such reporting because it is not timely or lacks specificity, 

and many staff said that following up to confirm such reports takes them 

away from higher-priority responsibilities. Agency staff also told us that 

permittees get frustrated if they do not take prompt action to stop 

unauthorized grazing by others, such as nonpermittees, which can also 

lead to conflicts among ranchers, for example, if a nonpermittee’s stray 

livestock consume the forage on a permittee’s allotment through 

unauthorized grazing. According to a wild horse advocate we interviewed, 

the advocate had experienced threats from ranchers engaged in 

unauthorized grazing on the range while the advocate was working with 

BLM to protect and manage the horses.
Page 20 GAO-16-559 Unauthorized Grazing

Agency field staff and stakeholders told us there are only a small number 

of confrontational ranchers who do not recognize the agencies’ authority 

to manage the range and engage in willful unauthorized grazing, but they 

are concerned that the problem will grow. Agency field staff we 

interviewed from 5 out of the 22 field offices told us that high-profile cases 

of intentional unauthorized grazing and related antigovernment protests 

can affect agency decision making regarding enforcement, and staff at 

4 out of the 22 field offices told us that not taking enforcement action on 

violators is likely to encourage more unauthorized grazing. For example, 

staff at one Forest Service office in Oregon told us that they were 

prepared to suspend a rancher’s permit for repeated unauthorized 

grazing violations but decided not to because of the standoff by 

antigovernment activists at Malheur National Wildlife Refuge. Agency 

staff we interviewed from 6 of the 22 field offices told us that lack of 

support from higher-level managers for strong enforcement action does 

not incentivize field staff to act on unauthorized grazing and, in some 

cases, lowers staff morale. The leaders of two stakeholder groups, 

Western Watersheds Project and Public Employees for Environmental 

Responsibility, jointly wrote a letter to the Secretary of the Interior in 2015 

to express concern about the lack of effective range management of BLM 

lands in Nevada because of what they characterized as higher-level 

pressure on local managers to accept ranchers’ demands when settling 

unauthorized grazing incidents; agency staff from three of the local offices 

we spoke with shared this concern.30 BLM responded to the stakeholders’

letter on behalf of the Secretary, stating that the agency is committed to 

collaborating with permittees to resolve problems that reflect the interests 

of affected communities while also ensuring that public lands are 

managed and conserved for the future.

Agency field staff we interviewed from 14 out of the 22 offices told us they 

generally do not have safety concerns while performing their duties, or did 

not mention any such concerns, even with the potential for confrontational 

tactics by some ranchers. BLM and Forest Service law enforcement 

officials told us that the overall trend for assaults and threats to agency 

staff had been down in recent years, but they do not track assaults and 

threats specifically related to grazing incidents. However, BLM field staff 

 30Letter from Western Watersheds Project and Public Employees for Environmental 

Responsibility to the Secretary of the Department of the Interior, June 10, 2015.
Page 21 GAO-16-559 Unauthorized Grazing

in Southern Nevada were directed by the state office not to visit grazing 

allotments after an armed standoff with a rancher over the agency’s 

impoundment of his cattle for unauthorized grazing. At one BLM field 

office we visited in Northern Nevada, there was a protest site established 

across the street in response to the office’s efforts to enforce 

unauthorized grazing regulations (see fig. 6). Field staff told us that as a 

result of a statewide BLM assessment, the office upgraded its security to 

include video cameras, card key locks, and entrance barricades.

Figure 6: Protest Site at Bureau of Land Management Office, Nevada, 2015

Finally, unauthorized grazing that is not detected or not formally acted on 

when identified cannot be billed penalties for unauthorized grazing, 

resulting in forgone revenues. The agencies track penalties for 

unauthorized grazing billed and collected but do not track those forgone. 

Based on information from the agencies’ databases, BLM and the Forest 

Service collected nearly $450,000 for unauthorized grazing in grazing 

years 2010 through 2014. BLM collected about $426,000 and has a 

balance due of about $8,000 for unauthorized grazing during that time 

frame. The Forest Service collected about $24,000 and reported no 

balance due for the same time frame.
Page 22 GAO-16-559 Unauthorized Grazing

BLM and the Forest Service undertake similar efforts to detect and deter 

unauthorized grazing, such as conducting compliance inspections on 

grazing allotments and charging penalties for unauthorized grazing, but 

agency field staff told us that such efforts have limited effectiveness for 

various reasons. While it is the preferred practice of agency field staff to 

resolve incidental unauthorized grazing informally, BLM and Forest 

Service regulations do not provide agency staff with the flexibility to 

resolve incidents informally with no written notice of violation and no 

penalty for unauthorized grazing charged.

BLM and the Forest Service have undertaken a number of similar efforts 

to detect and deter unauthorized grazing. These include conducting 

compliance inspections, charging penalties for unauthorized grazing, 

issuing willful and repeated willful violations, modifying permits, and 

issuing criminal citations. However, BLM and Forest Service field staff 

we spoke with said that these efforts can have limited effectiveness in 

practice for various reasons, such as field staff being unavailable to 

conduct compliance inspections because of other priorities or the penalty 

for unauthorized grazing being lower than the current commercial value 

of forage.

Field staff from both agencies told us that conducting compliance 

inspections is one of their more effective efforts for detecting and 

deterring unauthorized grazing. Specifically, staff we interviewed from 

16 of the 22 agency offices said that compliance inspections are always 

or usually effective in detecting unauthorized grazing, and staff from 

13 of the 22 said that such inspections are always or usually an effective 

deterrent. However, field office staff we spoke with told us that they have 

a limited number of knowledgeable staff—in part because of significant 

staff turnover, including transfers and retirements—administering vast 

acres of rangeland, and growing workloads that require multitasking and 

spending significant time in the office. In addition, grazing allotments are 

often in remote locations that can take hours to access by vehicle, 

horseback, or hiking. As a result, they said that compliance inspections 

are not a top priority and some allotments are seldom visited, which may 

diminish inspections’ deterrent effect. The number of field range staff 

available to conduct compliance inspections declined for both agencies 

Agencies’ Efforts to 

Detect, Deter, and 

Resolve 

Unauthorized Grazing 

Have Shortcomings 

That Limit Their 

Effectiveness

BLM and the Forest 

Service Have Similar 

Detection and Deterrence 

Efforts, but Effectiveness 

Is Limited for Various 

Reasons

Compliance Inspections
Page 23 GAO-16-559 Unauthorized Grazing

from 2010 to 2014—from 1,829 to 1,795 for BLM and from 443 to 399 for 

the Forest Service.31 On average, each BLM range staff member is 

responsible for approximately 85,000 acres, and each Forest Service 

range staff member is responsible for approximately 255,000 acres. 

At one BLM field office in Utah, field staff told us that 2 range staff are 

responsible for 2 million acres and that competing work priorities often 

keep these staff in the office rather than out in the field. Many field staff 

said they focus inspections on areas with a history of compliance issues 

but that some unauthorized grazing likely goes undetected.

Agency field staff—primarily those from the Forest Service—told us that 

penalties for unauthorized grazing are too low under current agency 

policy to act as an effective deterrent. Field staff we interviewed from 

6 out of the 9 Forest Service offices and 4 out of the 13 BLM offices said 

that penalties for unauthorized grazing are rarely or never an effective 

deterrent. As a result, some told us that there are permittees who view 

the penalties for unauthorized grazing as a cost of doing business 

because paying the penalties is cheaper than seeking forage elsewhere. 

For example, Forest Service staff at one field location told us that they are 

reluctant to send a bill for penalties for unauthorized grazing because it 

shows how low the penalty is and may encourage additional unauthorized 

grazing.

We found that for grazing years 2008 through 2014, the Forest Service 

penalty for unauthorized grazing was $2.51 or less per head month, 

which was substantially less than BLM’s penalty for unauthorized grazing. 

The Forest Service calculates this penalty using the same formula that it 

and BLM use each year to calculate the permitted grazing fee. The 

formula for the permitted fee has a preset base value of $1.23 and other 

input values, such as the prices of private forage and beef cattle, which 

can vary annually. To calculate its penalty for unauthorized grazing using 

this formula, the Forest Service applies a higher preset base value of 

$3.80 rather than $1.23. (For more detailed information on the formula 

and calculation, see app. II.) For grazing years 2009 through 2012, the 

Forest Service’s unauthorized grazing penalty formula calculation would 

have resulted in a negative number or a number lower than the permitted 

 31BLM provided data on staff at the end of each fiscal year; the Forest Service provided 

information on staff as of January 31 of each year.

Penalties for Unauthorized 

Grazing
Page 24 GAO-16-559 Unauthorized Grazing

grazing fee. To address this situation, a Forest Service official told us that 

the agency decided to hold the penalty for unauthorized grazing at 

$2.24 per head month until the formula calculation resulted in a higher 

penalty. In contrast, as shown in table 2, the BLM penalty for non-willful 

unauthorized grazing—based on commercial forage rates in each state—

ranged from $8 to $33.50 per animal unit month for grazing years 2008 

through 2014, and BLM doubled the penalty for willful incidents and 

tripled it for repeated willful incidents. In addition, with higher-level 

offensives (willful and repeated willful), BLM regulations require 

unauthorized grazing bills to also include “all reasonable expenses 

incurred by the United States in detecting, investigating, resolving 

violations, and livestock impoundment costs.”32

Table 2: Bureau of Land Management’s and U.S. Forest Service’s Permitted Grazing Fee and Unauthorized Grazing Penalties, 

Grazing Years 2001–2016

Bureau of Land Management penalty for unauthorized grazing

Grazing

yeara Permitted 

grazing feeb

U.S. Forest Service

penalty for 

unauthorized grazingc Non-willful penaltyd Willfulpenaltyd Repeated willfulpenaltyd

2001 $1.35 $3.34 $7.00 – $20.00 $14.00 – $40.00 $21.00 – $60.00

2002 1.43 4.41 7.00 – 20.60 14.00 – 41.20 21.00 – 61.80

2003 1.35 3.80 7.50 – 22.00 15.00 – 44.00 22.50 – 66.00

2004 1.43 4.41 7.00 – 21.60 14.00 – 43.20 21.00 – 64.80

2005 1.79 6.12 8.00 – 23.00 16.00 – 46.00 24.00 – 69.00

2006 1.56 4.83 8.00 – 22.50 16.00 – 45.00 24.00 – 67.50

2007 1.35 4.10 8.00 – 24.00 16.00 – 48.00 24.00 - 72.00

2008 1.35 2.24 8.00 – 23.00 16.00 – 46.00 24.00 – 69.00

2009 1.35 2.24 8.50 – 25.00 17.00 – 50.00 25.50 – 75.00

2010 1.35 2.24 8.33 – 24.80 16.66 – 49.60 24.99 – 74.40

2011 1.35 2.24 9.00 – 25.60 18.00 – 51.20 27.00 – 76.80

2012 1.35 2.24 9.00 – 27.30 18.00 – 54.60 27.00 – 81.90

2013 1.35 2.51 9.00 – 28.50 18.00 – 57.00 27.00 – 85.50

2014 1.35 2.31 9.00 – 33.50 18.00 – 67.00 27.00 – 100.50

 3243 C.F.R. § 4150.3 (2005).
Page 25 GAO-16-559 Unauthorized Grazing

Bureau of Land Management penalty for unauthorized grazing

Grazing

yeara Permitted 

grazing feeb

U.S. Forest Service

penalty for 

unauthorized grazingc Non-willful penaltyd Willfulpenaltyd Repeated willfulpenaltyd

2015 1.69 2.89 9.00 – 38.00 18.00 – 76.00 27.00 – 114.00

2016 2.11 10.68 9.00 – 39.00 18.00 – 78.00 27.00 – 117.00

Source: Bureau of Land Management and U.S. Forest Service data. | GAO-16-559

a

The grazing year used for billing grazing fees is March 1 to February 28.

b

The permitted grazing fee is for cattle and horses, and it is based on the formula and constraints in 

the Public Rangelands Improvement Act of 1978 and Executive Order No. 12,548 (Feb. 14, 1986). 

For example, under the executive order the grazing fee cannot be less than $1.35 and it cannot 

change more than 25 percent of the previous year’s fee. BLM charges the rate by animal unit month 

and Forest Service charges the rate by head month. Treated as equivalent measures for fee 

purposes, each is the amount of forage needed to support one cow and her calf, one horse, or five 

sheep for a month.

c

The Forest Service calculates its penalty for unauthorized grazing using the same formula that is 

used to calculate the permitted grazing fee, but with a higher base value of $3.80 as compared with 

$1.23. Furthermore, the Forest Service’s formula for calculating its penalty for unauthorized grazing 

does not include a lower limit or a limit on the yearly increase or decrease. In grazing year 2008 the 

penalty fell to $2.24 and would have fallen into negative numbers under the formula in subsequent 

years. To address this situation, Forest Service officials decided to hold the penalty at $2.24 from 

2009 to 2012 until the formula calculated a higher penalty in 2013, $2.51. In 2015, the Forest Service 

erroneously applied a limit of 25 percent on the increase of the penalty; the penalty with the limit was 

$2.89, while the penalty without an increase limit under the formula would have been $6.48. The 

agency did not apply a limit on the increase in 2016 to calculate a penalty of $10.68.

d

BLM bases its penalty for non-willful unauthorized grazing on a state-by-state commercial value of 

forage—that is, the average private grazing land lease rate per animal unit month—as determined 

annually by the National Agricultural Statistics Service. For willful unauthorized grazing, the penalty 

is doubled; for repeated willful, it is tripled.

Compared to BLM’s penalties, the Forest Service penalty for 

unauthorized grazing is less likely to be a deterrent for unauthorized 

grazing, and the differing penalty structures result in inconsistency 

between the two federal agencies. As we noted in March 2003,33

penalties generally should be designed in such a way as to serve as 

a deterrent for unauthorized activities. Forest Service regulations 

incorporate Office of Management and Budget guidance, which directs 

that a fair market value be obtained for all services and resources 

 33GAO, Civil Penalties: Agencies Unable to Fully Adjust Penalties for Inflation Under 

Current Law, GAO-03-409 (Washington, D.C.: Mar. 14, 2003). In this March 2003 report, 

we concluded that civil monetary penalties are an important element of regulatory 

enforcement and that suitably severe maximum penalties allow agencies to punish willful 

and egregious violators appropriately and serve as a deterrent to future violations. In 

addition, we concluded that civil penalties should be periodically adjusted for the effects 

of inflation so that they do not lose their relevancy.
Page 26 GAO-16-559 Unauthorized Grazing

provided to the public through establishment of a system of reasonable 

fee charges.34 By adopting a penalty structure for unauthorized grazing 

use that is, similar to BLM’s, based on the current commercial value of 

forage (a fair market value), the Forest Service’s penalty for unauthorized 

grazing can better serve as a deterrent to such grazing and be consistent 

with BLM’s penalty.

The Forest Service recognized that its formula for calculating its penalty 

for unauthorized grazing was problematic in grazing year 2009 when the 

formula produced a negative value. A Forest Service official told us that 

the agency is considering options for revising the penalty as part of its 

ongoing update of grazing guidance, but the update has not been 

completed because of higher priorities. The Forest Service does not 

have a time frame for when the penalty for unauthorized grazing will be 

revised, according to agency officials. Until the Forest Service revises its 

penalty for unauthorized grazing to reflect current forage rates, similar to 

BLM’s, the penalty has limited value as a deterrent to unauthorized 

grazing.

BLM field staff generally told us that willful and repeated willful 

unauthorized grazing incidents are rare; most unauthorized grazing is 

incidental and non-willful. However, staff we interviewed from 3 of the 13 

BLM field offices who had encountered willful and repeated willful 

unauthorized grazing incidents said that such violations are difficult to 

support because staff must prove that the unauthorized grazing was the 

fault of the livestock owner and show that a record of prior willful 

violations existed for repeat offenses, per agency regulations and policy. 

As mentioned previously, because BLM staff generally prefer informal 

resolution for most incidents of unauthorized grazing, there may not be a 

paper trail documenting repeated incidents. In some offices this was 

exacerbated by staff turnover. Specifically, field staff we interviewed from 

7 of the 22 offices told us that institutional knowledge is lost when staff 

depart who are familiar with the extent and circumstances of unauthorized 

grazing that was resolved informally. As a result, BLM staff told us that 

they generally only pursue willful or repeated willful violations for the most 

egregious, long-term cases of unauthorized grazing.

 3436 C.F.R. § 222.50(b).

Willful and Repeated Willful 

Violations
Page 27 GAO-16-559 Unauthorized Grazing

Agency regulations also direct BLM staff to collect reasonable agency 

expenses for resolving willful and repeated willful incidents, but field staff 

told us that they have discretion in determining what is reasonable and 

therefore may not charge violators for agency expenses. For example, 

field staff said that they may agree to waive the expenses if they were 

insignificant or to make it less likely that the permittee will appeal the 

decision. Our review of willful and repeated willful unauthorized grazing 

incidents in BLM’s grazing program database from grazing years 2010 

through 2014 found that the administrative expenses were billed to 

violators in 98 out of 164, or 60 percent, of such incidents. We reviewed 

the paper file documentation for BLM’s 24 willful and 3 repeated willful 

unauthorized grazing cases in grazing year 2014, and found that in most 

cases field staff had documented how they determined the appropriate 

penalties and expenses to bill.35

Agency staff and cattlemen’s association representatives told us that the 

agencies’ policies for modifying permits, such as reducing the number 

of permitted livestock for an allotment or suspending or canceling the 

permits, are likely to be the greatest deterrent to unauthorized grazing, in 

part because they directly affect the permittees’ livelihoods. Field staff we 

interviewed from 18 of the 22 offices said that permit modifications are 

always or usually an effective deterrent. In practice, field staff from 19 of 

the 22 said that they generally view this as a last resort penalty and 

seldom modify, suspend, or cancel permits for unauthorized grazing in 

part because the warning is usually sufficient to obtain compliance. In 

one example, Forest Service staff at an office in Nevada said they had 

canceled only one permit, for a permittee with a particularly long record 

of persistent unauthorized grazing. Staff said that a warning about the 

potential for permit action is generally enough to achieve immediate 

compliance in almost all detected unauthorized grazing cases involving 

permittees.

According to agency field staff, misdemeanor criminal citations are 

primarily issued to nonpermittees for unauthorized grazing and can be an 

effective deterrent. However, law enforcement officers and program staff 

 35For the cases where the determination of penalties and expenses was not documented, 

agency staff told us, for example, that a bill for unauthorized grazing penalties may have 

been sent based on a verbal agreement with the violator, or the expenses may have been 

considered minimal and therefore were not documented or included in the bill.

Permit Modifications

Citations
Page 28 GAO-16-559 Unauthorized Grazing

we interviewed from 5 out of the 22 offices told us that federal attorneys 

may choose not to prosecute citations or the courts may lower the 

penalties, which may diminish the effectiveness of this deterrent. For 

example, a Forest Service law enforcement officer in Utah said that circuit 

courts typically lower penalties to a couple hundred dollars or less, which 

is below the cost of buying forage elsewhere. Furthermore, law 

enforcement officers and program staff we interviewed from 7 out of the 

22 offices told us that when on patrol the officers are generally focused on 

higher priorities, such as public safety. In addition, staff from 7 of the 

22 offices we interviewed said that the officers usually do not have 

knowledge of permit conditions and therefore do not know when livestock 

should or should not be in a certain location.

BLM and Forest Service regulations do not provide field staff of both 

agencies with the flexibility to follow their preferred practice of informally 

resolving unauthorized grazing incidents with no written notice of violation 

and no penalty for unauthorized grazing. We recommended in 1990 that 

BLM either ensure that all penalties are assessed for non-willful 

unauthorized grazing, as provided for in its regulations, or amend its 

regulations to establish a procedure for informal resolution.36 The agency 

amended its regulations to add the option for the nonmonetary resolution 

of certain non-willful incidents, but the amendment did not remove the 

requirement for a written notice of violation. Forest Service regulations 

do not specifically require a written notice of violation but require that a 

penalty be determined; nonmonetary resolution is not an option.37 As a 

result, informal resolution with no written notice and no penalty—the 

preferred practice for field staff in dealing with unauthorized grazing—is 

not allowed for under either agency’s regulations.

 36GAO/RCED-91-17.

37The Forest Service issued interim grazing permit suspension and cancellation 

procedures in October 2001 following the ruling of the United States Court of Appeals for 

the Ninth Circuit in Anchustegui v. Department of Agriculture, 257 F.3d 1124 (9th Cir. 

2001). The procedures provided guidance for implementing the court’s finding that under 

the Administrative Procedures Act, the Forest Service is required to give notice in writing 

of the facts which may warrant action, and must give an opportunity to the permit holder to 

achieve compliance, when the violation is non-willful. The Forest Service has not revised 

its regulations or policies to reflect these procedures.

BLM and Forest Service 

Regulations Do Not 

Provide Flexibility for the 

Agencies’ Preferred 

Practice of Informal 

Resolution for 

Unauthorized Grazing
Page 29 GAO-16-559 Unauthorized Grazing

While not provided for under the regulations, most agency field staff told 

us that informal resolution is the most effective way to achieve the 

objective of quickly resolving non-willful unauthorized grazing with 

minimal conflict, and is the most efficient use of their time given multiple 

higher-priority responsibilities. As discussed in federal internal control 

standards, program operations are effective and efficient in achieving 

agency objectives when they produce the intended results and minimize 

the waste of resources.38 Management is responsible for designing the 

policies and procedures to fit an entity’s circumstances and building them 

in as an integral part of the entity’s operations. BLM and Forest Service 

officials stated that handling incidental unauthorized grazing informally is 

necessary and effective because they have limited staff and permittees 

tend to be largely compliant. However, the agencies have not established 

in regulations procedures for such informal resolution or alternatively 

taken steps to ensure that staff comply with existing regulations as 

written. By amending the regulations to establish procedures for the 

informal resolution of violations of the grazing regulations at the local 

level, agency management could achieve the objective of quickly 

resolving incidental unauthorized grazing with minimal conflict, in a 

manner consistent with its regulations and with the most efficient use of 

the agency’s resources. Alternatively, rather than amending their existing 

regulations to match their practices, the agencies could change their 

practices to comply with their existing regulations. BLM officials told us 

that the agency has faced challenges in revising its grazing regulations, 

including the incorporation of our 1990 recommendations; the most recent 

revision was enjoined by the court from implementation in 2006 after it 

was challenged by interest groups.39 The Code of Federal Regulations 

currently contains the enjoined regulations; agency officials plan to 

replace these regulations with the regulations that were in effect prior to 

the court’s action but have not set a date for completing the process.

Furthermore, BLM has not updated its Unauthorized Grazing Use 

Handbook since 1987—in part because of the enjoined regulations—

and it contains guidance that differs in some cases from the existing 

regulations. For example, the handbook does not reference the option 

 38GAO/AIMD-00-21.3.1.

39Western Watersheds Project v. Kraayenbrink, 538 F. Supp. 2d 1302 (D. Idaho 2008), 

aff’d in relevant part 632 F.3d 472 (9th Cir. 2011), cert. denied 132 S.Ct. 366 (2011).
Page 30 GAO-16-559 Unauthorized Grazing

of nonmonetary settlement for certain non-willful unauthorized grazing 

incidents that is contained in the regulations. In addition, the handbook 

description of penalties differs from that in the regulations for willful 

violations—the regulations state that the rate is twice the value of forage 

consumed, while the handbook states that the rate is three times the 

value of forage consumed. Furthermore, the regulations state that the 

value of damages to public lands shall be included in settlement for willful 

and repeated willful violations, and the handbook states generally that the 

value of damages “must be charged,” without specifying which violations 

must incur the charge. As a result, staff using the handbook may not be 

consistently following the regulations. Federal internal control standards 

call for agency management to periodically review policies, procedures, 

and related control activities for continued relevance and effectiveness in 

achieving the entity’s objectives or addressing related risks.40 Without 

revising the agency’s grazing guidance to make it consistent with the 

grazing regulations, BLM does not have reasonable assurance that its 

staff consistently apply the grazing regulations.

BLM and the Forest Service face the daunting task of effectively 

managing grazing on millions of acres of remote rangeland with a limited 

number of field staff who have multiple responsibilities and competing 

priorities. Given the large number of acres and permits managed under 

the agencies’ programs, the number of unauthorized grazing incidents 

that are formally reported is relatively small, and the reportedly larger 

number of incidents that are resolved informally and not recorded in any 

database or consistently recorded in paper case files are most often 

considered by agency field staff to be incidental and quickly remedied 

with minimal impact on range resources. By amending the regulations to 

establish procedures for the informal resolution of non-willful violations of 

the grazing regulations at the local level, agency management could 

achieve the objective of quickly resolving incidental unauthorized grazing 

with minimal conflict, in a manner consistent with its regulations and with 

the most efficient use of the agency’s resources. Alternatively, rather than 

amending their existing regulations to match their practices, the agencies 

could change their practices to comply with their existing regulations. 

While it may be reasonable for the agencies to handle incidental 

 40GAO/AIMD-00-21.3.1.

Conclusions
Page 31 GAO-16-559 Unauthorized Grazing

unauthorized grazing informally, given their limited staff and a largely 

compliant pool of permittees, it is important that each agency’s practices 

accurately reflect its grazing regulations to ensure clarity and consistency 

in application for staff and permittees.

Furthermore, without recording the incidents of unauthorized grazing that 

are informally resolved, neither agency has complete information on the 

extent and frequency of unauthorized grazing for tracking patterns of any 

potential repeat offenders. In addition, until BLM revises its grazing 

guidance to make it consistent with the grazing regulations, the agency 

does not have reasonable assurance that its staff consistently apply the 

regulations. Finally, until the Forest Service revises its unauthorized 

grazing penalty structure to reflect the current value of forage, similar to 

BLM, the deterrent effect of the penalty will be limited, and some ranchers 

will continue to view the penalty as a cost of doing business.

To improve the effectiveness of BLM’s efforts to track and deter 

unauthorized grazing, we recommend that the Secretary of the Interior 

direct the Director of BLM to take the following three actions:

• amend the regulations on unauthorized grazing use—43 C.F.R. 

Subpart 4150 (2005)—to establish a procedure for the informal 

resolution of violations at the local level, or follow the existing 

regulations by sending a notice of unauthorized use for each potential 

violation as provided by 43 C.F.R. § 4150.2(a) (2005);

• record all incidents of unauthorized grazing, including those resolved 

informally; and

• revise the agency’s Unauthorized Grazing Use Handbook to make it 

consistent with 43 C.F.R. pt. 4100 (2005).

To improve the effectiveness of the Forest Service’s efforts to track and 

deter unauthorized grazing, we recommend that the Secretary of 

Agriculture direct the Chief of the Forest Service to take the following 

three actions:

• amend the regulations on range management—36 C.F.R. pt. 222—to 

provide for nonmonetary settlement when the unauthorized or excess 

grazing is non-willful and incidental, or follow the existing regulations 

by determining and charging a grazing use penalty for all 

unauthorized and excess use when it is identified as provided by 

36 C.F.R. § 222.50(a) and (h);

Recommendations for 

Executive Action
Page 32 GAO-16-559 Unauthorized Grazing

• record all incidents of unauthorized grazing, including those resolved 

informally; and

• adopt an unauthorized grazing penalty structure that is based, similar 

to BLM’s, on the current commercial value of forage.

We provided the Departments of Agriculture and the Interior with a draft 

of this report for their review and comment. In its written comments, 

reproduced in appendix IV, the Forest Service generally concurred with 

our findings and recommendations. In its comments, the Forest Service 

stated that it has taken preliminary steps toward updating its guidance to 

field units, including guidance for unauthorized grazing penalties similar 

to BLM’s. In its written comments reproduced in appendix V, the 

Department of the Interior generally concurred with our findings and

recommendations. In its comments, the Department of the Interior stated 

that it will revise its guidance to better describe procedures for following 

existing regulations, to provide procedures for documenting and recording 

all unauthorized grazing incidents, and will ensure that its guidance is 

consistent with its regulations. The Department of the Interior also 

provided technical comments that were incorporated, as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretaries of Agriculture and the Interior, 

and other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or fennella@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. Key contributors to this report are listed in 

appendix VI.

Anne-Marie Fennell

Director, Natural Resources and Environment

Agency Comments 
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-16-559 Unauthorized Grazing

Our objectives were to (1) describe what is known about the frequency 

and extent of unauthorized grazing, and its effects, and (2) examine the 

Bureau of Land Management’s (BLM) and the U.S. Forest Service’s 

efforts to detect, deter, and resolve unauthorized grazing.

To describe the frequency and extent of unauthorized grazing, we 

analyzed the agencies’ unauthorized grazing data, and to describe the 

effects of such grazing, we reviewed documentation, interviewed agency 

officials and stakeholder group representatives, and conducted site visits 

at agency field office locations. We collected data from BLM’s and the 

Forest Service’s range management, financial, and law enforcement 

databases on the frequency and extent of unauthorized grazing for 

grazing years 2010 through 2014,1 the most recent and complete data 

available at the time of our review. We also collected information on 

grazing acres, usage, and permits, which came from different years 

depending on what was the most recently available at the time of our 

request. For BLM, we obtained range management data from its 

Rangeland Administration System; financial data on unauthorized grazing 

bills from its Collection and Billing System; and law enforcement data 

from its Incident Management, Analysis, and Reporting System. For the 

Forest Service, we obtained range management and billing data from its 

INFRA system and law enforcement data from its Law Enforcement and 

Investigations Management Attainment Reporting System.2 We assessed 

the data provided by the agencies based on our review of database 

system documentation and discussions with agency database stewards 

and found the data to be sufficiently reliable for our purposes.

We conducted in-person and telephone interviews with staff in 22 of the 

218 agency field office locations in eight western states where most such 

grazing had occurred. We selected the 22 offices from among the agency 

field offices that had the highest numbers of unauthorized grazing 

incidents or that had been recommended by stakeholders. From the 

22 selected offices, we conducted site visits to 6 offices located in 

Nevada and Wyoming to interview agency range management and law 

 1

A grazing year for billing purposes is March 1 to February 28. For example, grazing year 

2016 covers the period of time from March 1, 2016, to February 28, 2017.

2

INFRA is a database tool for tracking infrastructure within the Forest Service’s Natural 

Resource Manager system.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-16-559 Unauthorized Grazing

enforcement staff about the extent of unauthorized grazing and the 

agencies’ policies and practices for addressing it, as well as to review 

paper case files and observe the effects of unauthorized grazing on 

federal lands. We also conducted telephone interviews with staff in 16 of 

the 22 BLM and Forest Service field locations in California, Colorado, 

Idaho, Nevada, New Mexico, Oregon, and Utah. Our interview results are 

not generalizable to all agency field office locations and grazing lands and 

instead are illustrative cases of the office locations reporting the highest 

numbers of unauthorized grazing incidents. Tables 3 and 4 provide more 

information about the agency field office locations where we conducted 

interviews.

To obtain the views of interested stakeholders, we conducted interviews 

with representatives of 11 stakeholder groups, including telephone 

interviews with cattlemen’s association representatives in California, 

Colorado, Nevada, New Mexico, and Oregon. We also conducted 

telephone interviews with representatives of other stakeholders, including 

Public Employees for Environmental Responsibility, Forest Service 

Employees for Environmental Ethics, Western Watersheds Project, 

Wildlands Defense, and others, such as a wild horse advocate. We 

selected these groups based on information provided by agency officials 

or other stakeholder groups involved in grazing issues; in one case, we 

spoke with a stakeholder who contacted us after learning of our review. 

We qualitatively analyzed agency and stakeholder interviews for common 

themes and patterns to describe how the agencies address unauthorized 

grazing and the effectiveness of these policies and practices. We coded 

interviews using qualitative data analysis software that allows 

organization and analysis of information from a variety of sources. Our 

coding process involved one independent coder putting information into 

initial categories and a second independent coder verifying that initial 

work. The coders discussed and resolved any discrepancies in coding.
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-16-559 Unauthorized Grazing

Table 3: Bureau of Land Management Field Offices Where GAO Conducted 

Interviews from August 2015 through January 2016

Field Office name State

Fillmore Utah

Humboldt River Nevada

Lander Wyoming

Las Vegas Nevada

Monticello Utah

Mount Lewis Nevada

Rio Puerco New Mexico

Shoshone Idaho

Stillwater Nevada

Surprise California

Taos New Mexico

Upper Snake Idaho

Worland Wyoming

Source: GAO. | GAO-16-559

Table 4: U.S. Forest Service Field Offices Where GAO Conducted Interviews from 

August 2015 through January 2016

National Forest name State

Bridger-Teton Wyoming

Cibola New Mexico

Humboldt-Toiyabe Nevada

Lincoln New Mexico

Malheur Oregon

Manti-LaSal Utah

Santa Fe New Mexico

Uinta-Wasatch-Cache Utah

White River Colorado

Source: GAO. | GAO-16-559
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-16-559 Unauthorized Grazing

To examine the agencies’ efforts to detect, deter, and resolve 

unauthorized grazing, we analyzed federal laws to identify agency 

requirements for addressing such grazing as well as the agencies’

regulations, policies, and practices. We qualitatively analyzed information 

obtained in agency and stakeholder interviews for common themes and 

patterns to describe how the agencies address unauthorized grazing and 

the effectiveness of their efforts. We compared the agencies’ policies to 

their practices in the field, compared the policies’ objectives with their 

outcomes, and assessed the internal controls for the policies and 

practices. We also compared the agencies’ policies and practices to our 

recommendations in our December 1990 report to evaluate whether 

those recommendations have made or could make improvements in the 

detection and deterrence of unauthorized grazing.3

We conducted this performance audit from May 2015 to July 2016 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 3

GAO, Rangeland Management: BLM Efforts to Prevent Unauthorized Livestock Grazing 

Need Strengthening, GAO/RCED-91-17 (Washington, D.C.: Dec. 7, 1990). This 

December 1990 report focused solely on BLM; grazing on Forest Service lands was not 

covered in the report.
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 37 GAO-16-559 Unauthorized Grazing

This appendix provides detailed information on grazing permits, leases, 

fees, and penalties on lands managed by the Bureau of Land 

Management (BLM), within the Department of the Interior, and the 

U.S. Forest Service, within the Department of Agriculture. Specifically, 

the information includes acres available for grazing on lands the agencies 

manage, the animal unit months (AUM) approved for grazing, and the 

AUMs billed for BLM and the Forest Service;1 BLM and Forest Service 

permits and leases by size; and information on BLM and Forest Service 

grazing fees for permitted grazing and penalties for unauthorized grazing. 

The agencies are in two different departments and their grazing programs 

are covered by different laws and regulations. Therefore, the agencies 

maintain their own databases and, in some cases, track different data 

elements. As a result, consistent information was not always available 

from the two agencies, and in some cases the information provided was 

from different years depending on what was the most recently available at 

the time of our request.

This section provides an overview of the most recent information 

available at the time of our review on grazing that occurred on BLM and 

Forest Service lands. The acres of BLM and Forest Service land available 

for grazing each year can change, depending on the results of 

environmental assessments conducted on grazing allotments, and the 

amount of grazing that is allowed each year can change, depending on 

annual assessments of forage and range conditions. Both agencies 

measure the number of acres of their lands available for grazing by 

allotment each year, but the two agencies use different terms to measure 

the amount of grazing. BLM calls this amount active or authorized, and 

the Forest Service calls this amount permitted. Similarly, BLM refers to 

the amount of grazing that it bills for annually—which can vary from the 

amount it authorizes because of range or climate conditions—as billed, 

and the Forest Service refers to this amount of grazing as authorized. 

 1

Treated as equivalent measures for fee purposes, BLM’s AUM and the Forest Service’s 

head month refer to the amount of forage necessary for the sustenance of one cow or its 

equivalent for a period of one month. We use AUM in this appendix to refer to both AUM 

and head month. For grazing fee purposes, BLM defines an AUM as a month’s use and

occupancy of range by 1 cow, bull, steer, heifer, horse, burro, mule, 5 sheep, or 5 goats, 

over the age of 6 months at the time of entering the public lands or other lands 

administered by the BLM; by any such weaned animals regardless of age; and by such 

animals that will become 12 months of age during the authorized period of use.

Appendix II: Grazing Information for the 

Bureau of Land Management and 

U.S. Forest Service

Acres and AUMs of 

Grazing
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 38 GAO-16-559 Unauthorized Grazing

We use “AUMs approved” to refer to the amounts of grazing authorized 

by BLM and permitted by the Forest Service and “AUMs billed” to refer to 

the amount of grazing for which BLM billed ranchers and the amount of 

grazing authorized each year on Forest Service lands. Table 5 shows the 

acres and AUMs approved as of January 2016 and AUMs grazed for 

BLM’s field offices in fiscal year 2014, the most recent year available.

Table 5: Bureau of Land Management (BLM) Data on Acres and Animal Unit Months (AUM) by Field Office as of January 2016 

and AUMs Billed for Fiscal Year 2014

State Acres AUMs approved AUMs billed

Arizona

Agua Fria National Monument 79,553 13,492 5,950

Arizona Strip 1,780,689 118,756 79,528

Grand Canyon/Parashant National Monument 722,473 35,600 21,302

Hassayampa 957,484 68,074 54,072

Ironwood Forest National Monument 135,278 8,049 6,449

Kingman 2,715,596 120,660 119,205

Las Cienegas National Conservation Area 44,474 10,212 19,795

Lower Sonoran 779,431 15,513 7,073

Safford Field 1,373,882 133,913 80,363

San Pedro Riparian National Conservation Area 14,993 1,536 1,540

Sonoran Desert National Monument 472,817 17,785 4,546

Tucson 425,410 37,465 34,530

Vermilion Cliffs National Monument 233,305 25,774 5,831

Yuma 965,352 27,353 10,024

Subtotal 10,700,737 634,182 450,208

California

Alturas 455,535 51,801 29,056

Arcata 21,832 963 1,073

Bakersfield 307,820 30,287 20,818

Barstow 455,651 6,053 1,108

Bishop 603,302 35,156 7,063

Carrizo Plain National Monument 160,069 59,865 0

Eagle Lake 996,323 52,991 25,916

Hollister 178,069 24,650 15,274

King Range National Conservation Area 11,110 2,030 605

Mother Lode 43,821 3,645 2,883

Needles 560,576 7,737 3,746
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 39 GAO-16-559 Unauthorized Grazing

State Acres AUMs approved AUMs billed

Palm Springs-South Coast 83,851 2,542 0

Redding 24,331 4,015 3,818

Ridgecrest 1,192,904 12,260 4,421

Surprise 1,450,332 84,710 54,317

Ukiah 10,960 1,528 1,788

Subtotal 6,556,486 380,233 171,886

Colorado

Canyon Ancients National Monument 158,051 6,739 4,110

Colorado River Valley 506,024 43,224 28,553

Dominguez-Escalante National Conservation Area 198,349 12,684 5,255

Grand Junction 1,037,874 64,791 31,474

Gunnison 517,175 34,571 17,616

Gunnison Gorge National Conservation Area 88,064 6,117 1,315

Kremmling 337,162 34,822 30,324

Little Snake 1,323,289 142,312 74,395

McInnis Canyons National Conservation Area 69,585 2,192 128

Royal Gorge 608,052 35,163 19,494

San Luis Valley 456,357 29,184 11,009

Tres Rios 416,128 20,672 17,944

Uncompahgre 651,417 35,972 18,088

White River 1,460,013 118,299 61,978

Subtotal 7,827,540 586,742 321,683

Idaho

Birds of Prey National Conservation Area 584,696 46,828 26,190

Bruneau 1,400,837 127,233 69,108

Burley 862,278 141,872 100,429

Challis 737,886 58,098 31,859

Cottonwood 93,236 5,268 3,905

Craters of the Moon National Monument 111,101 14,956 3,675

Four Rivers 737,656 106,048 73,831

Jarbidge 1,635,041 184,000 140,907

Owyhee 1,239,234 105,705 94,875

Pocatello 574,541 84,948 69,483

Salmon 492,410 62,610 44,755

Shoshone 1,440,777 182,188 92,726

Upper Snake River 1,594,266 206,306 130,469

Subtotal 11,503,959 1,326,060 882,212
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 40 GAO-16-559 Unauthorized Grazing

State Acres AUMs approved AUMs billed

Montana

Billings 403,179 54,419 46,871

Butte 264,905 23,343 19,270

Dillon 835,039 101,902 68,105

Glasgow 1,012,713 144,830 142,529

Havre 646,536 94,072 79,738

Lewistown 830,505 124,665 115,529

Malta 1,020,225 169,361 157,316

Miles City 2,891,140 550,778 520,310

Missoula 99,327 5,500 4,719

North Dakota 52,263 9,270 7,303

South Dakota 273,664 73,762 70,067

Subtotal 8,329,496 1,351,902 1,231,757

Nevada

Black Rock 1,863,296 56,159 42,132

Caliente 3,957,689 147,477 53,933

Egan 3,627,448 143,832 62,776

Humboldt River 7,411,067 279,276 154,848

Las Vegas 192,824 0 649

Mount Lewis 4,323,051 244,790 121,258

Schell 3,522,686 223,067 87,868

Sierra Front 1,138,540 55,760 15,268

Stillwater 3,903,234 103,269 39,058

Tonopah 6,026,508 134,092 68,155

Tuscarora 2,974,584 370,574 243,668

Wells 4,194,182 320,527 170,712

Subtotal 43,135,109 2,078,823 1,060,325

New Mexico

Carlsbad 1,996,948 375,688 285,216

Farmington 1,371,751 121,757 82,615

Fort Stanton Snowy River Cave National Conservation 

Area 80 15 24

Las Cruces 4,028,279 554,220 403,910

Organ Mountains Desert Peaks National Monument 903,664 86,271 56,417

Prehistoric Trackways National Monument 19,292 1,457 884

Rio Puerco 950,758 127,520 85,759

Roswell 1,428,688 310,903 231,063
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 41 GAO-16-559 Unauthorized Grazing

State Acres AUMs approved AUMs billed

Socorro 1,491,206 230,287 171,803

Taos 519,358 42,570 21,119

Subtotal 12,710,024 1,850,688 1,338,810

Oregon

Andrews Resource Area 1,154,850 66,237 37,569

Ashland Resource Area 195,874 5,043 4,180

Baker 395,564 46,965 40,997

Border Resource Area 124,415 12,452 10,811

Butte Falls Resource Area 136,408 5,062 1,480

Central Oregon Resource Area 884,499 62,624 39,411

Coos Bay 541 49 0

Deschutes Resource Area 696,364 52,629 33,752

Jordan 2,537,453 187,049 127,513

Klamath Falls Resource Area 208,878 12,762 9,656

Lakeview Resource Area 2,931,263 164,311 100,636

Malheur Resource Area 2,081,454 233,223 209,744

Roseburg 11,879 0 0

Steens Mountain Cooperative Management and 

Protection Area 442,872 29,682 21,375

Three Rivers Resource Area 1,679,931 152,101 123,915

Wenatchee Resource Area 198,064 20,374 18,096

Subtotal 13,680,309 1,050,563 779,135

Utah

Cedar City 2,079,317 140,227 93,080

Fillmore 4,315,435 262,250 177,505

Grand Stairway-Escalante National Monument 1,807,456 76,551 46,171

Kanab 435,168 18,932 10,449

Moab 1,808,949 90,331 46,856

Monticello 2,012,867 74,438 51,160

Price 2,218,572 100,346 58,871

Richfield 2,250,671 101,518 83,568

Salt Lake 2,374,663 180,986 123,232

St. George 566,127 27,826 20,219

Vernal 1,704,141 129,448 77,078

Subtotal 21,573,366 1,202,853 788,189

Wyoming

Buffalo 798,328 104,059 107,773
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 42 GAO-16-559 Unauthorized Grazing

State Acres AUMs approved AUMs billed

Casper 1,313,617 185,631 169,283

Cody 1,109,918 77,439 32,878

Kemmerer 1,447,232 152,228 123,512

Lander 2,349,790 254,166 161,493

Newcastle 288,048 48,719 46,981

Pinedale 885,129 111,041 93,004

Rawlins 3,542,028 448,947 247,746

Rock Springs 3,602,134 303,268 131,703

Worland 2,055,501 221,874 147,763

Subtotal 17,391,725 1,907,372 1,262,136

Total 153,408,751 12,369,418 8,286,341

Source: BLM data. | GAO-16-559

Notes: Public acres (BLM land) in allotments available for grazing and permitted active AUMs, as of 

January 2016. Billed AUMs are for bills due from October 1, 2013, through September 30, 2014. We 

use “AUMs approved” to refer to the amounts of grazing authorized by BLM and “AUMs billed” to 

refer to the amount of grazing for which BLM billed ranchers.

Treated as equivalent measures for fee purposes, BLM’s AUM and the Forest Service’s head month 

refer to the amount of forage necessary for the sustenance of one cow or its equivalent for a period 

of one month. We use AUM in this appendix to refer to both AUM and head month. For grazing fee 

purposes, BLM defines an AUM as a month’s use and occupancy of range by 1 cow, bull, steer, 

heifer, horse, burro, mule, 5 sheep, or 5 goats, over the age of 6 months at the time of entering the 

public lands or other lands administered by the BLM; by any such weaned animals regardless of age; 

and by such animals that will become 12 months of age during the authorized period of use.

Table 6 shows the acres of grazing available, approved AUMs, and billed 

AUMs in grazing year 2015 for Forest Service administrative offices and 

grasslands. The data on acres include acres in active and vacant 

allotments but not in allotments that have been closed that are not 

available for grazing. The data on AUMs include data that the Forest 

Service calls head months. Unlike BLM, the Forest Service uses two 

methods to tally the amount of grazing that occurs—AUMs and head 

months. The agency uses AUM to refer to the amount of forage 

consumed by different types of livestock, while it uses the term head 

months to refer to the number of livestock (head) that are grazed and that 

are subject to billing. We used the Forest Service head month data 

because they are equivalent to the BLM’s data on billed AUMs, but we 

used AUM to simplify the comparison with BLM’s grazing data.
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 43 GAO-16-559 Unauthorized Grazing

Table 6: U.S. Forest Service Data on Acres and Animal Unit Months (AUM), by Forest and Grassland, Grazing Year 2015

Regions Acres AUMs approved AUMs billed

Region 1, Northern Region

Beaverhead-Deerlodge National Forest 2,551,472 169,030 163,438

Bitterroot National Forest 188,577 1,499 1,500

Idaho Panhandle National Forests 139,487 2,536 2,206

Flathead National Forest 102,747 1,407 1,032

Custer Gallatin National Forest 1,292,085 210,727 197,326

Helena National Forest 561,019 36,765 38,049

Kootenai National Forest 480,919 4,769 4,303

Lewis and Clark National Forest 921,533 57,611 54,560

Lolo National Forest 159,993 2,069 2,069

Nez Perce-Clearwater National Forest 672,190 26,532 26,375

Dakota Prairie Grasslands 1,802,159 679,288 917,935

Subtotal 8,872,181 1,192,233 1,408,793

Region 2, Rocky Mountain Region

Bighorn National Forest 977,074 82,473 79,079

Black Hills National Forest 1,276,337 111,453 109,816

Grand Mesa, Uncompahgre, and Gunnison National 

Forests 2,818,480 255,528 232,636

Medicine Bow-Routt National Forest 3,638,739 329,378 251,981

Nebraska National Forest 1,123,701 334,960 422,303

Rio Grande National Forest 1,613,849 75,990 73,076

Arapaho-Roosevelt National Forest 773,610 56,013 102,647

Pike-San Isabel National Forest 1,977,583 139,249 139,221

San Juan National Forest 1,632,333 89,987 89,745

Shoshone National Forest 1,164,058 42,737 43,331

White River National Forest 1,523,509 111,614 106,458

Subtotal 18,519,273 1,629,382 1,650,293

Region 3, Southwestern Region

Apache-Sitgreaves National Forest 8,052,607 129,802 120,980

Carson National Forest 1,348,869 93,847 86,925

Cibola National Forest 1,793,238 147,990 134,348

Coconino National Forest 1,610,501 81,977 79,912

Coronado National Forest 1,596,356 256,652 251,567

Gila National Forest 2,978,328 231,123 211,164

Kaibab National Forest 1,386,138 65,145 57,798

Lincoln National Forest 978,702 120,792 132,678
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 44 GAO-16-559 Unauthorized Grazing

Regions Acres AUMs approved AUMs billed

Prescott National Forest 1,354,782 146,521 127,957

Santa Fe National Forest 1,492,128 78,815 76,461

Tonto National Forest 2,784,970 169,095 164,877

Subtotal 25,376,619 1,521,759 1,444,667

Region 4, Intermountain Region

Ashley National Forest 1,049,888 54,993 50,708

Boise National Forest 1,700,996 39,066 37,399

Bridger-Teton National Forest 3,712,552 117,273 110,009

Dixie National Forest 1,738,683 86,186 84,689

Fishlake National Forest 1,448,260 155,862 152,054

Manti-LaSal National Forest 1,330,748 122,631 121,362

Payette National Forest 1,085,383 60,579 57,799

Salmon-Challis National Forest 2,596,054 108,251 101,540

Sawtooth National Forest 1,699,128 138,219 131,700

Caribou-Targhee National Forest 2,382,927 280,938 273,173

Humboldt-Toiyabe National Forest 5,607,269 244,621 236,951

Uinta-Wasatch-Cache National Forest 1,535,377 161,818 161,837

Subtotal 25,887,265 1,570,437 1,519,221

Region 5, Pacific Southwest Region

Angeles National Forest 0 0 0

Cleveland National Forest 144,215 2,419 2,418

Eldorado National Forest 536,927 4,738 4,059

Inyo National Forest 971,786 17,005 17,054

Klamath National Forest 968,233 20,345 18,412

Lassen National Forest 1,195,377 19,869 14,763

Los Padres National Forest 854,003 9,359 9,304

Mendocino National Forest 568,918 5,439 5,439

Modoc National Forest 1,788,200 109,588 97,691

Six Rivers National Forest 294,977 4,846 4,732

Plumas National Forest 904,698 18,037 14,707

San Bernardino National Forest 230,179 1,504 1,505

Sequoia National Forest 941,611 24,615 24,412

Shasta Trinity National Forest 633,732 3,059 2,970

Sierra National Forest 921,905 15,676 15,659

Stanislaus National Forest 802,969 17,477 17,291

Tahoe National Forest 536,853 7,348 6,269

Lake Tahoe Basin Management Unit 33,993 0 0
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 45 GAO-16-559 Unauthorized Grazing

Regions Acres AUMs approved AUMs billed

Subtotal 12,328,576 281,324 256,685

Region 6, Pacific Northwest Region

Deschutes National Forest 229,888 18,388 12,538

Fremont-Winema National Forests 2,022,393 85,016 85,395

Gifford Pinchot National Forest 32,988 1,366 1,366

Malheur National Forest 1,679,423 118,363 108,492

Mt Baker-Snoqualmie National Forest 0 0 0

Mt Hood National Forest 172,087 1,515 1,515

Ochoco National Forest 667,468 56,932 51,914

Olympic National Forest 0 0 0

Rogue River-Siskiyou National Forest 577,953 12,234 10,826

Siuslaw National Forest 0 0 0

Umatilla National Forest 859,814 47,592 43,901

Umpqua National Forest 130,813 1,110 1,107

Wallowa Whitman National Forest 1,599,135 120,381 112,169

Okanogan-Wenatchee National Forests 1,590,538 46,689 45,198

Willamette National Forest 0 0 0

Colville National Forest 896,133 28,709 26,564

Columbia River Gorge National Scenic Area 5,000 118 117

Subtotal 10,463,633 538,413 501,102

Region 8, Southern Region

National Forests in Alabama 0 0 0

Daniel Boone National Forest 0 0 0

Chattahoochee-Oconee National Forest 1,811 1,768 0

Cherokee National Forest 254 0 0

National Forests in Florida 5,000 792 0

Kisatchie National Forest 24,153 271 232

National Forests in Mississippi 200 37 37

George Washington And Jefferson National Forests 8,223 5,859 3,011

Ouachita National Forest 114,612 3,435 1,064

Ozark-St. Francis National Forest 118,344 4,111 3,226

National Forests in North Carolina 0 0 0

Francis Marion-Sumter National Forests 0 0 0

National Forests in Texas 37,395 5,805 7,044

Subtotal 309,992 22,078 14,614

Region 9, Eastern Region

Chippewa National Forest 75 221 0
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 46 GAO-16-559 Unauthorized Grazing

Regions Acres AUMs approved AUMs billed

Huron Manistee National Forest 0 0 0

Mark Twain National Forest 19,544 15,601 2,375

Ottawa National Forest 0 0 0

Shawnee National Forest 1,489 0 0

Superior National Forest 0 0 0

Hiawatha National Forest 0 0 0

Hoosier National Forest 0 0 0

Chequamegon-Nicolet National Forest 0 0 0

Wayne National Forest 960 0 0

Midewin National Tallgrass Prairie 4,683 10,202 8,833

Allegheny National Forest 0 0 0

Green Mountain and Finger Lakes National Forests 5,053 12,603 0

Monongahela National Forest 6,086 5,654 730

White Mountain National Forest 0 0 0

Subtotal 37,890 44,281 11,938

Total 101,795,429 6,799,907 6,807,313

Source: U.S. Forest Service data. | GAO-16-559

Notes: The Forest Service has no Region 7.

The Forest Service charges the grazing fee rate by head month, which is an equivalent measure to 

AUM for fee purposes—the amount of forage one cow and her calf, one horse, or five sheep eat in a 

month.

We use “AUMs approved” to refer to the amounts of grazing permitted by the Forest Service and 

“AUMs billed” to refer to the amount of grazing authorized each year on Forest Service lands.

Because the number of AUMs per permit or lease can vary greatly, the 

number of AUMs controlled by permittees or lessees also varies greatly. 

Tables 7 through 9 show the number of BLM and Forest Service permits 

and leases, and AUMs, by permit size. Multiple permits or leases may be 

contained on a single allotment, just as one permit or lease may span 

multiple allotments. In addition, several ranchers may share one permit 

or lease, just as one rancher may possess multiple permits or leases; 

therefore, the number of permits and leases does not necessarily 

correlate to the total number of ranchers. Table 7 shows the size of BLM 

Permits and Leases 

by Size
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 47 GAO-16-559 Unauthorized Grazing

permits and leases, using approved AUMs as of December 2015. The 

data do not include permits and leases with less than two AUMs.2

Table 7: Number of Bureau of Land Management Grazing Permits and Leases by 

Size, as of December 2015

Size of permit or lease in

animal unit months (AUM)

Number of permits

and leases

Total approved 

AUMs

2 to 10 1,216 8,326

11 to 100 6,011 267,857

101 to 500 5,574 1,372,933

501 to 1,000 1,920 1,362,542

1,001 to 5,000 2,512 5,244,949

5,001 to 10,000 279 1,879,153

Over 10,000 137 2,233,618

Total 17,649 12,369,378

Source: Bureau of Land Management data. | GAO-16-559

Notes: 43 C.F.R. § 4100.0-5 defines an AUM as the amount of forage necessary for the sustenance 

of one cow or its equivalent for a period of 1 month.

We start with two AUMs because we re-created a table from previous reports: GAO, Rangeland 

Management: Profile of the Bureau of Land Management’s Grazing Allotments and Permits,

GAO/RCED-92-213FS (Washington, D.C.: June 10, 1992), and Livestock Grazing: Federal 

Expenditures and Receipts and Vary, Depending on the Agency and the Purpose of the Fee 

Charged, GAO-05-869 (Washington, D.C.: Sept. 30, 2005).

Table 8 shows Forest Service permits for cattle for regions with lands in 

western states (regions 1 through 6). The data do not include horses or 

other livestock and do not include permits with fewer than two AUMs of 

grazing for cattle.

 2

The agencies re-created tables that we produced in a previous report: GAO, Livestock 

Grazing: Federal Expenditures and Receipts and Vary, Depending on the Agency and the 

Purpose of the Fee Charged, GAO-05-869 (Washington, D.C.: Sept. 30, 2005). The tables 

in the September 2005 report were also re-created versions of tables used in two older 

previous reports: GAO, Rangeland Management: Profile of the Bureau of Land 

Management’s Grazing Allotments and Permits, GAO/RCED-92-213FS (Washington, 

D.C.: June 10, 1992), and Rangeland Management: Profile of the Forest Service’s 

Grazing Allotments and Permittees, GAO/RCED-93-141FS (Washington, D.C.: Apr. 28, 

1993).
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 48 GAO-16-559 Unauthorized Grazing

Table 8: Number of U.S. Forest Service Cattle Permits by Size, Grazing Year 2015

Size of permits in

animal unit months (AUM) Number of permits Total approved AUMs

2 to 10 17 99

11 to 100 586 34,684

101 to 500 2,123 579,308

501 to 1,000 1,206 866,929

1,001 to 5,000 1,700 3,477,745

5,001 to 10,000 177 1,195,694

Over 10,000 51 1,840,639

Total 5,860 7,995,098

Source: U.S. Forest Service data. | GAO-16-559

Notes: The Forest Service charges the grazing fee rate by head months, an equivalent measure to 

AUMs for fee purposes—the amount of forage one cow and her calf, one horse, or five sheep eat in 

a month.

We start with two AUMs because we re-created a table from previous reports: GAO, Rangeland 

Management: Profile of the Forest Service’s Grazing Allotments and Permittees,

GAO/RCED-93-141FS (Washington, D.C.: Apr. 28, 1993), and Livestock Grazing: Federal 

Expenditures and Receipts and Vary, Depending on the Agency and the Purpose of the Fee 

Charged, GAO-05-869 (Washington, D.C.: Sept. 30, 2005).

Forest Service sheep permits are shown in table 9. For the purposes of 

conversion, five sheep equal one AUM. In addition to the sheep, an 

insignificant number of horses are included in the data because, in some 

cases, permittees may keep a horse for herding the sheep.

Table 9: Number of U.S. Forest Service Sheep Permits by Size, Grazing Year 2015

Size of permits in 

animal unit months (AUM) Number of permits Total approved AUMs

50 to 500 63 18,067

501 to 1,500 131 131,512

1,501 to 5,000 131 346,036

5,001 to 15,000 24 181,022

15,001 to 25,000 0 0

Over 25,000 1 26,000

Total 350 702,637

Source: U.S. Forest Service data. | GAO-16-559

Notes: The Forest Service charges the grazing fee rate by head month, an equivalent measure to 

AUMs for fee purposes—the amount of forage one cow and her calf, one horse, or five sheep eat in 

a month.

This table does not include permits with less than 50 AUMs. We start at 50 AUM because we recreated a table from a previous report, GAO, Livestock Grazing: Federal Expenditures and Receipts 
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 49 GAO-16-559 Unauthorized Grazing

and Vary, Depending on the Agency and the Purpose of the Fee Charged, GAO-05-869 (Washington, 

D.C.: Sept. 30, 2005).

Historically, BLM and Forest Service permitted grazing fees were 

established to achieve different objectives—to recover administrative 

expenses or to reflect livestock prices, respectively—but the agencies 

began using the same approach to setting fees in 1969. Over the years, 

the agencies, as well as outside entities, have conducted numerous 

studies attempting to establish a permitted grazing fee that meets the 

objectives of multiple parties. As of March 2016, the permitted grazing fee 

for BLM and the Forest Service in 16 western states is based on a 

formula which incorporates factors that take into account ranchers’ ability 

to pay and was established in 1978 based on studies conducted in the 

1960s and 1970s.3

In 2016, the permitted grazing fee for lands managed by BLM and the 

Forest Service in 16 western states was $2.11 per AUM—or the amount 

of forage needed to sustain a cow and her calf for 30 days.4 This 

permitted grazing fee is set annually according to a formula established 

in the Public Rangelands Improvement Act of 1978 and extended 

indefinitely by Executive Order 12,548 that has been incorporated into 

the agencies’ regulations.5 The formula is as follows:

Fee = $1.23 x (FVI +BCPI – PPI)/100

where $1.23 = the base value, or the difference between the costs of 

conducting ranching business on private lands, including any grazing fees 

charged, and public lands, not including grazing fees. The costs were 

computed in a 1966 study that included 10,000 ranching businesses in 

the western states.

 3

The 16 western states are Arizona, California, Colorado, Idaho, Kansas, Montana, 

Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Oregon, South Dakota, Utah, 

Washington, and Wyoming.

4

While BLM uses AUM as a unit for purposes of charging fees, the Forest Service uses 

head month. The two units are calculated the same way. We use AUM in this appendix to 

refer to both AUM and head month.

5

Pub. L. No. 95-514, 92 Stat. 1803.

Calculation of 

Grazing Fees and 

Unauthorized Grazing 

Penalties for BLM’s 

and the Forest 

Service’s Western 

States
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 50 GAO-16-559 Unauthorized Grazing

FVI = Forage Value Index, or the weighted average estimate of the 

annual rental charge per head per month for pasturing cattle on private 

rangelands in 11 western states (Arizona, California, Colorado, Idaho, 

Montana, New Mexico, Nevada, Oregon, Utah, Washington, and 

Wyoming) divided by $3.65 per head month (the private grazing land 

lease rate for the base period of 1964-68) and multiplied by 100.

BCPI = Beef Cattle Price Index, or the weighted average annual selling 

price for beef cattle (excluding calves) in the 11 western states divided by 

$22.04 per hundredweight (the beef cattle price per hundred pounds for 

the base period of 1964-68) and multiplied by 100.

PPI = Prices Paid Index, for selected components from the Department of 

Agriculture’s National Agricultural Statistics Service’s Index of Prices Paid 

by Farmers for Goods and Services, adjusted by different weights (in 

parentheses) to reflect livestock production costs in the western states 

[fuels and energy (14.5), farm and motor supplies (12.0), autos and trucks 

(4.5), tractors and self-propelled machinery (4.5), other machinery (12.0), 

building and fencing materials (14.5), interest (6.0), farm wage rates 

(14.0), and farm services (cash rent) (18.0)].

The Public Rangelands Improvement Act of 1978 limited the annual 

increase or decrease in the resulting fee to 25 percent. It also established 

the fee formula for a 7-year trial period and required that the effects of the 

fee be evaluated at the end of that period. Although the permitted grazing 

fee formula under the act expired in 1986, the use of the fee formula was 

extended indefinitely by Executive Order 12,548 and incorporated into the 

agencies’ regulations. The executive order requires the Secretaries of the 

Interior and Agriculture to establish permitted grazing fees according to 

the act’s formula, including the 25 percent limit on increases or decreases 

in the fee. In addition, the order established that the permitted grazing fee 

should not be lower than $1.35 per AUM.

To calculate its penalty for unauthorized grazing, the Forest Service uses 

the same formula as for the permitted fee but replaces the base value of 

$1.23 with a higher base value of $3.80. In addition, the Forest Service 

does not apply the 25 percent limit on the annual increase or decrease 

in the penalty and does not set a lower limit on the penalty as with the 

permitted fee formula (see table 10). In contrast, BLM bases its penalties 

for unauthorized on the state by state commercial value of forage. 

According to the National Agricultural Statistics Service, based on the 

average private grazing land lease rate per AUM, the state-by-state 
Appendix II: Grazing Information for the 

Bureau of Land Management and U.S. Forest 

Service

Page 51 GAO-16-559 Unauthorized Grazing

commercial value of forage in western states ranged from $9 to $39 in 

grazing year 2016.

Table 10: U.S. Forest Service’s Formula Results for Permitted Grazing Fees and Unauthorized Grazing Penalties, Grazing 

Years 2001–2016

Permitted grazing fees

U.S. Forest Service penalties for 

unauthorized grazing

Grazing year Formula result Fee Formula result Penalty

2001 $1.08 $1.35 $3.34 $3.34

2002 1.43 1.43 4.41 4.41

2003 1.23 1.35 3.80 3.80

2004 1.43 1.43 4.41 4.41

2005 1.98 1.79 6.12 6.12

2006 1.56 1.56 4.83 4.83

2007 1.33 1.35 4.10 4.10

2008 0.73 1.35 2.24 2.24

2009 (0.65) 1.35 (2.01) 2.24

2010 (0.22) 1.35 (0.68) 2.24

2011 (0.33) 1.35 (1.03) 2.24

2012 0.28 1.35 0.87 2.24

2013 0.81 1.35 2.51 2.51

2014 0.75 1.35 2.31 2.31

2015 2.10 1.69 6.48 2.89

2016 3.46 2.11 10.68 10.68

Source: GAO analysis and U.S. Forest Service data. | GAO-16-559

Note: The Forest Service’s formula for calculating its penalty for unauthorized grazing does not 

include a lower limit or a limit on the increase or decrease. In grazing year 2008, the penalty fell to 

$2.24 and would have fallen into negative numbers under the formula in subsequent years. To 

address this situation, the Forest Service decided to hold the penalty at $2.24 from 2009 to 2012 

until the formula produced a higher penalty in 2013: $2.51. In 2015, the Forest Service erroneously 

applied a limit of 25 percent on the increase of the penalty; the penalty with the limit was $2.89, while 

the penalty without an increase limit under the formula would have been $6.48. The agency did not 

apply a limit on the increase in 2016 to calculate a penalty of $10.68.
Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized Grazing

Page 52 GAO-16-559 Unauthorized Grazing

This appendix provides detailed information on the extent and frequency 

of unauthorized grazing incidents and charges recorded in the Bureau of 

Land Management’s (BLM) and the U.S. Forest Service’s range 

management and law enforcement databases, for grazing years 2010 

through 2014.1 BLM, within the Department of the Interior, and the U.S. 

Forest Service, within the Department of Agriculture, are in two different 

departments and their grazing programs are covered by different laws 

and regulations. Therefore, the agencies maintain their own databases 

and, in some cases, track different data elements. As a result, consistent 

information was not always available from the two agencies.

BLM’s range management database contained records of 433 

unauthorized grazing incidents that occurred in grazing years 2010 

through 2014 and were settled and billed by December 28, 2015 (the date 

the data were queried) (see table 11). Incidents not billed by December 

28, 2015, are not included, nor are incidents that were resolved 

nonmonetarily. The number of incidents ranged from 76 in Idaho to 5 in 

Arizona.

Table 11: Bureau of Land Management Range Program Unauthorized Grazing 

Incidents by State Office, Grazing Years 2010–2014

State office Incidents

Arizona 5

California 29

Colorado 38

Idaho 76

Montana/Dakotas 29

New Mexico 65

Nevada 44

Oregon 48

Utah 52

Wyoming 47

Total 433

Source: Bureau of Land Management data. | GAO-16-559

 1

A grazing year for billing purposes is March 1 to February 28. For example, grazing year 

2014 was from March 1, 2014, to February 28, 2015.

Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized 

Grazing

BLM Range Program 

Data
Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized Grazing

Page 53 GAO-16-559 Unauthorized Grazing

Notes: The unauthorized grazing incidents occurred in grazing years 2010 through 2014 and were 

settled and billed by December 28, 2015. Incidents not billed by December 28, 2015, are not 

included, nor are incidents that were resolved nonmonetarily.

The administrative state is not the same as the geographic state; the administrative state can cross 

geographic state lines. The Montana/Dakotas State Office covers Montana, North Dakota, and South 

Dakota. The New Mexico State Office covers New Mexico, Kansas, Oklahoma, and Texas. The 

Oregon State Office covers Oregon and Washington. The Wyoming State Office covers Wyoming 

and Nebraska.

The grazing year used for billing grazing fees is March 1 to February 28.

The bills identified for the 433 incidents in BLM’s range management 

database included 466 charges for different types of unauthorized 

grazing; non-willful (unintentional), willful (intentional), and repeated 

willful, each of which is charged at a different rate (see table 12). The total 

charges (466) exceeds the total number of incidents settled and billed 

(433) because each bill can include charges for more than one type of 

unauthorized grazing and for more than 1 grazing year. Non-willful 

unauthorized grazing was the most common type in grazing years 2010

through 2014, accounting for 299—or 64 percent—of the charges 

recorded; willful unauthorized grazing was 31 percent of the total, and 

repeated willful was 5 percent.

Table 12: Bureau of Land Management Range Program Unauthorized Grazing Charges by Type and Grazing Year, 2010–2014

Grazing year

Unauthorized grazing type 2010 2011 2012 2013 2014 Total

Percentage 

of total

Non-willful 56 52 74 81 36 299 64%

Willful 30 20 28 42 24 144 31%

Repeated willful 3 3 6 8 3 23 5%

Total 89 75 108 131 63 466 100%

Source: GAO analysis of Bureau of Land Management data. | GAO-16-559

Notes: A single bill for unauthorized grazing may include charges for multiple types of unauthorized 

grazing. For example, a bill may include charges for non-willful (unintentional) unauthorized grazing 

and for willful or repeated willful (intentional) unauthorized grazing, each of which is charged at a 

different rate. Therefore, in this table the total number of charges (466) exceeds the total number of 

bills issued (433). For the purpose of this report, we used the number of bills to represent the number 

of unauthorized grazing incidents.

The unauthorized grazing bills reflect incidents that occurred in grazing years 2010 through 2014 and 

were settled and billed by December 28, 2015. Additional incidents not billed by December 28, 2015, 

are not included.

The grazing year used for billing grazing fees is March 1 to February 28.
Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized Grazing

Page 54 GAO-16-559 Unauthorized Grazing

BLM’s unauthorized grazing bills included charges for unauthorized 

grazing penalties; administrative charges for costs of the agency’s 

response; and other charges, fees, and interest. As of March 1, 2015, 

BLM had billed about $441,000 for unauthorized grazing charges in 

grazing years 2010 through 2014 (see table 13). BLM had collected about 

$426,000 of the amount; after adjustments, about $8,000 of the charges 

remained due.

Table 13: Status of the Bureau of Land Management Range Program’s Unauthorized Grazing Bill Charges Issued for Grazing 

Years 2010–2014

Type of charge Billed amount Amount collected Adjustments Balance due

Unauthorized grazing penalties $325,850.64 $319,977.98 ($1,408.06) $4,464.60 

Administrative charges 108,433.71 102,500.02 (2,491.43) $3,442.26 

Service fees 770.00 729.30 (40.70) $0.00 

Handling charges 345.00 210.00 (105.00) $30.00 

Interest charges 160.37 96.44 (47.61) $16.32 

Late fees 4,729.93 1,740.43 (2,700.70) $288.80 

Penalty charges 922.14 538.55 (285.65) $97.94 

Total $441,211.79 $425,792.72 ($7,079.15) $8,339.92 

Source: GAO analysis of Bureau of Land Management data. | GAO-16-559

Notes: Data are accurate as of March 1, 2016, when the data were queried from the Bureau of Land 

Management’s Collection and Billing System database. The data reflect charges with a bill date in 

grazing years 2010 through 2014 and therefore do not correspond directly to incidents that occurred 

during this period.

BLM’s unauthorized grazing bills included charges for unauthorized grazing penalties; administrative 

charges for costs of the agency’s response; and other charges, fees, and interest.

The grazing year used for billing grazing fees is March 1 to February 28.

BLM’s range management database contained records of nearly 

53,000 grazing compliance inspections performed by agency field staff 

during grazing years 2010 through 2014 (see table 14). Of the nearly 

53,000 inspections, about 1,500—or 3 percent—identified possible 

noncompliance. Possible noncompliance means noncompliance was 

suspected but not yet confirmed by the individual completing the 

compliance inspection and was identified for further investigation. 

Therefore some inspections recorded as a finding of possible 

noncompliance, upon further investigation, may not have resulted in 

a finding of a violation.
Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized Grazing

Page 55 GAO-16-559 Unauthorized Grazing

Table14: Bureau of Land Management Range Program Compliance Inspections by State Office and Outcome, Grazing Years 

2010–2014

Outcome of compliance inspection

State office

No noncompliance 

identified

Possible 

noncompliance 

identified Total

Percentage

with possible 

noncompliance 

identified

Arizona 1,307 48 1,355 4%

California 1,936 184 2,120 9%

Colorado 3,974 143 4,117 3%

Idaho 22,106 144 22,250 1%

Montana/Dakotas 5,213 159 5,372 3%

New Mexico 1,936 65 2,001 3%

Nevada 3,319 229 3,548 6%

Oregon 2,666 194 2,860 7%

Utah 3,349 162 3,511 5%

Wyoming 5,524 190 5,714 3%

Total 51,330 1,518 52,848 3%

Source: GAO analysis of Bureau of Land Management compliance inspection data. | GAO-16-559

Note: Possible noncompliance means noncompliance was suspected but not confirmed and identified 

for further investigation by the individual completing the grazing compliance inspection. Therefore, 

some inspections recorded as a finding of possible noncompliance, upon further investigation, may 

not have resulted in a finding of a violation.

BLM’s law enforcement database contained records of 426 incidents 

where formal documentation, such as an incident report (record of 

observation), warning notice, or violation notice, was prepared by a law 

enforcement officer and entered into the database in grazing years 2010 

through 2014 (see table 15). The number of incidents ranges from 71 in 

Wyoming to 17 in Arizona and Utah. From grazing years 2010 through 

2014, the year with the most incidents recorded in the law enforcement 

database was 2013; 123 incidents were recorded, or nearly 30 percent of 

the 426 total incidents. According to agency officials, some of the data 

may include incidents that were miscoded as grazing related when 

entered into the law enforcement database, and a small proportion of the 

incidents include violations of grazing permits other than unauthorized 

grazing, such as supplementing the existing forage with additional 

livestock feed.

BLM Law 

Enforcement Data
Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized Grazing

Page 56 GAO-16-559 Unauthorized Grazing

Table 15: Bureau of Land Management Law Enforcement Unauthorized Grazing 

Incidents by State Office and Grazing Year, 2010–2014

State office 2010 2011 2012 2013 2014 Total

Arizona 1 5 3 5 3 17

California 13 7 8 27 5 60

Colorado 6 14 12 16 8 56

Idaho 5 5 6 14 7 37

Montana/Dakotas 8 2 7 10 8 35

New Mexico 9 4 7 13 24 57

Nevada 37 1 3 5 2 48

Oregon 8 5 5 4 6 28

Utah 1 4 5 6 1 17

Wyoming 15 14 15 23 4 71

Total 103 61 71 123 68 426

Source: Bureau of Land Management data. | GAO-16-559

Notes: According to agency officials, some of the data may include incidents that were miscoded as 

grazing related when entered into the law enforcement database.

Some incidents include violations of grazing permits other than unauthorized grazing, such as 

supplementing the existing forage with additional livestock feed.

The grazing year used for billing grazing fees is March 1 to February 28.

The Forest Service’s range management database contained records of 

190 unauthorized grazing incidents in grazing years 2010 through 2014 

(see table 16). The number of incidents is based on the number of bills 

issued and also includes some unauthorized grazing incidents confirmed 

by Forest Service field offices as having occurred where no bill was 

issued. Additional incidents may have occurred that were not billed and 

were not entered in the Forest Service database. The number of incidents 

ranged from 65 in the Southwestern Region to 2 in the Southern Region.

Table 16: U.S. Forest Service Range Program Unauthorized Grazing Incidents by 

Region, Grazing Years 2010–2014

Forest Service region Incidents

Northern 19

Rocky Mountain 47

Southwestern 65

Intermountain 36

Pacific Southwest 8

Pacific Northwest 9

Forest Service Range 

Program Data
Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized Grazing

Page 57 GAO-16-559 Unauthorized Grazing

Forest Service region Incidents

Southern 2

Eastern 4

Total 190

Source: GAO analysis of U.S. Forest Service data. | GAO-16-559

Notes: The number of incidents is based on the number of bills issued by the Forest Service for 

unauthorized grazing and incidents confirmed by Forest Service field offices as incidents in which bills 

were not issued. Additional incidents may have occurred that were not billed and therefore were not 

entered in the Forest Service database.

The grazing year used for billing grazing fees is March 1 to February 28.

The 190 incidents identified primarily by bills in the Forest Service’s range 

management database included charges for different types of 

unauthorized grazing incidents, excess use (by a permittee), and 

unauthorized use (by a nonpermittee) (see table 17).2 Excess use by 

permittees was the most common incident type in grazing years 2010 

through 2014, accounting for 173—or 91 percent—of the incidents 

recorded; unauthorized use was 9 percent of the total.

Table 17: U.S. Forest Service Range Program Unauthorized Grazing Incidents by Type and Grazing Year, 2010–2014

Grazing year

Unauthorized grazing type 2010 2011 2012 2013 2014 Total Percentage

Excess use 49 22 47 36 19 173 91%

Unauthorized use 6 1 5 3 2 17 9%

Total 55 23 52 39 21 190 100%

Source: GAO analysis of U.S. Forest Service data. | GAO-16-559

Notes:The number of incidents is based on the number of bills issued by the Forest Service for 

excess use and unauthorized use, and excess and unauthorized incidents confirmed by Forest 

Service field offices as those where bills were not issued. Additional incidents may have occurred 

that were not billed and therefore were not entered in the Forest Service database.

The Forest Service refers to violations by permittees as excess use and by nonpermittees as 

unauthorized use.

The grazing year used for billing grazing fees is March 1 to February 28.

The Forest Service’s unauthorized grazing bills included charges for 

excess use and unauthorized use. The Forest Service collected a total of 

about $24,000 from these charges in grazing years 2010 through 2014; 

 2

For the purpose of this report, we generally refer to all types of incidents as unauthorized.
Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized Grazing

Page 58 GAO-16-559 Unauthorized Grazing

nearly $18,000 from excess use by permittees, and about $6,000 from 

unauthorized use by nonpermittees (see table 18). The amount collected 

includes credits used by livestock owners to pay excess or unauthorized 

use charges.

Table 18: Amount Collected from the U.S. Forest Service’s Range Program 

Unauthorized Grazing Charges, by Type, Grazing Years 2010–2014

Unauthorized grazing type Amount collected

Excess use $17,809.79

Unauthorized use 6,147.34

Total $23,957.13

Source: GAO analysis of U.S. Forest Service data. | GAO-16-559

Notes: The data include amounts collected from excess use and unauthorized use grazing bills and 

incidents in which livestock owners used existing credit toward excess or unauthorized use charges.

The Forest Service refers to violations by permittees as excess use and by nonpermittees as 

unauthorized use.

The grazing year used for billing grazing fees is March 1 to February 28.

The Forest Service’s law enforcement database contained records of 

428 incidents where formal documentation, such as an incident report 

(record of observation), warning notice, or violation notice, was prepared 

by a law enforcement officer and entered into the database in grazing 

years 2010 through 2014 (see table 19). The number of incidents ranges 

from 102 in the Intermountain Region to 24 in the Pacific Northwest and 

Eastern Regions.

Table 19: U.S. Forest Service Law Enforcement Grazing Incidents by Region, 

Grazing Years 2010–2014

Forest Service region Incidents

Northern 73

Rocky Mountain 73

Southwestern 45

Intermountain 102

Pacific Southwest 30

Pacific Northwest 24

Southern 57

Eastern 24

Total 428

Source: U.S. Forest Service data. | GAO-16-559

Note: The grazing year used for billing grazing fees is March 1 to February 28.

Forest Service Law 

Enforcement Data
Appendix III: Detailed Information on the 

Extent and Frequency of Unauthorized Grazing

Page 59 GAO-16-559 Unauthorized Grazing

From grazing years 2010 through 2014, the year with the most 

unauthorized grazing incidents recorded in the Forest Service’s law 

enforcement database was 2013; 100 incidents were recorded, or about 

23 percent of the 428 total incidents (see table 20).

Table 20: U.S. Forest Service Law Enforcement Unauthorized Grazing Incidents by Type and Grazing Year, 2010–2014

Grazing year

Type of record 2010 2011 2012 2013 2014 Total

Percentage

of total

Incident report 39 26 45 49 31 190 44%

Warning notice 28 25 33 33 29 148 35%

Violation notice 27 26 11 18 8 90 21%

Total 94 77 89 100 68 428 100%

Source: U.S. Forest Service data. | GAO-16-559

Notes: The Forest Service law enforcement database contains incident reports (records of 

observation), warning notices, and violation notices prepared by law enforcement officers.

The grazing year used for billing grazing fees is March 1 to February 28.
Appendix IV: Comments from the Department 

of Agriculture

Page 60 GAO-16-559 Unauthorized Grazing

Appendix IV: Comments from the 

Department of Agriculture
Appendix V: Comments from the Department 

of the Interior

Page 61 GAO-16-559 Unauthorized Grazing

Appendix V: Comments from the Department 

of the Interior
Appendix V: Comments from the Department 

of the Interior

Page 62 GAO-16-559 Unauthorized Grazing
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 63 GAO-16-559 Unauthorized Grazing

Anne-Marie Fennell, (202) 512-3841 or fennella@gao.gov

In addition to the contact named above, Jeffery D. Malcolm (Assistant 

Director), Brad C. Dobbins, Karen (Jack) Granberg, and Katherine M. 

Killebrew made key contributions to this report. Important contributions 

were also made by Kevin S. Bray, Martin (Greg) Campbell, Elizabeth 

Martinez, Alana R. Miller, and Cynthia M. Saunders.

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361645)
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