The Bureau of Land Management (BLM) has withdrawn a permanent instructional memorandum (PIM) that would have prioritized certain grazing permits on public lands, potentially causing delays in others.
Last December, BLM released PIM 2025-004, titled “Setting Priorities for Review and Processing of Grazing Authorizations and Related Livestock Grazing Monitoring, and Incorporating Thresholds and Responses into Grazing Permits/Leases.” The PIM was part of a series of memoranda related to plans that were unable to be implemented during the Biden administration.
The Public Lands Council applauded the memorandum’s withdrawal, saying it would have led to delayed grazing permits in several states, required a risk of contact model in areas with bighorn sheep populations and confused the management of areas with sage grouse populations.
Memo details
The memo, posted Dec. 20, 2024, provided guidance for prioritizing data collection, evaluating land health and implementing management of grazing permits and leases. The document also provided guidance for analyzing and incorporating thresholds and responses into grazing permit terms and conditions and National Environmental Policy Act (NEPA) analyses.
“This policy is intended to ensure that land health considerations, including habitat for sage-grouse, bighorn sheep and threatened and endangered species, as well as areas with special or administrative designations, are the primary bases for prioritizing the processing of grazing permits and leases, monitoring the effectiveness of grazing management, and making progress toward achieving land health standards,” the memo read.
The agency continued that it has a large administrative and civil litigation workload related to grazing permits, and has also lost rangeland management specialists, which has led to the renewal of permits and leases without NEPA analysis or other required analyses.
“Through the implementation of the policy contained in this document, the BLM will be better poised to focus its limited resources on high priority resources when conducting the grazing permit renewal process and to provide for increased public transparency,” BLM said.
The memo lined out the highest priority as permits needing legal requirements met (court orders, compliance with the Endangered Species Act, etc.), followed by active grazing allotments with high-priority resources such as sage grouse and bighorn sheep. Areas that were not meeting land health standards or where standards had not been evaluated within the past 15 years were next on the priority list. Finally, areas designated as critical habitat for threatened or endangered species, or areas with special or administrative designations—such as national monuments—were prioritized.
BLM field offices were directed to complete data collection and land health standard assessments within three years, and determine causes of land health issues and adjust grazing if needed before the next grazing year. Offices were then directed to conduct an Environmental Analysis under NEPA in all cases and issue a grazing decision or renew or deny a permit.
When grazing permits were processed, field offices were directed to develop thresholds and responses through the NEPA process. Thresholds could include percent utilization, bank alteration limits, drought severity utilization limits and browse utilization limits.
BLM was directed to prioritize fully processing permits and leases that were already renewed at least once under Section 402(c)(2) of the Federal Land Policy and Management Act, and try to fully process permits and leases before they were automatically renewed a second time.
BLM also planned to make annual prioritization schedules available to the public upon request, to “make the priority and timing for processing grazing permits and leases transparent to the public.” Once a site and process were established, BLM was to release schedules on the BLM website. This was set to begin by Oct. 1.
Finally, field offices were set to work with grazing permit holders, the public, state agencies, Tribes and other federal agencies when gathering data.
“Developing thresholds and responses is complex and often requires the consideration of many factors, which may increase the costs and timeframes of processing individual permits,” BLM noted, but, “once in place, the ability to adjust management to address changing conditions without requiring additional NEPA review can provide significant cost and time savings.” — Anna Miller, WLJ managing editor
