10/28/2026
𝗗𝗢𝗜 𝗦𝗲𝗰𝗿𝗲𝘁𝗮𝗿𝘆 𝗗𝗼𝘂𝗴 𝗕𝘂𝗿𝗴𝘂𝗺 𝗗𝗲𝗰𝗹𝗮𝗿𝗲𝘀 𝗪𝗮𝗿 𝗔𝗴𝗮𝗶𝗻𝘀𝘁 𝗔𝗺𝗲𝗿𝗶𝗰𝗮𝗻 𝗪𝗶𝗹𝗱 𝗛𝗼𝗿𝘀𝗲𝘀 𝗮𝗻𝗱 𝗪𝗶𝗹𝗱𝗹𝗶𝗳𝗲'
𝗡𝗲𝘄 𝗢𝗿𝗱𝗲𝗿 𝗲𝗳𝗳𝗲𝗰𝘁𝗶𝘃𝗲𝗹𝘆 𝘀𝘁𝗿𝗶𝗽𝘀 𝗽𝗿𝗼𝘁𝗲𝗰𝘁𝗶𝗼𝗻𝘀 𝗳𝗼𝗿 𝘄𝗶𝗹𝗱𝗹𝗶𝗳𝗲 𝗶𝗻 𝗔𝗺𝗲𝗿𝗶𝗰𝗮 - 𝗵𝗮𝗻𝗱𝘀 𝗼𝘃𝗲𝗿 𝘄𝗶𝗹𝗱-𝗹𝗮𝗻𝗱𝘀 𝘁𝗼 𝗿𝗮𝗻𝗰𝗵𝗲𝗿𝘀 𝗮𝗻𝗱 𝘁𝗵𝗲 𝗺𝗼𝘀𝘁 𝗱𝗲𝘀𝘁𝗿𝘂𝗰𝘁𝗶𝘃𝗲 𝗶𝗻𝘃𝗮𝘀𝗶𝘃𝗲 𝘀𝗽𝗲𝗰𝗶𝗲𝘀 𝗵𝗲𝗿𝗯𝗶𝘃𝗼𝗿𝗲𝘀, 𝗰𝗮𝘁𝘁𝗹𝗲 𝗮𝗻𝗱 𝘀𝗵𝗲𝗲𝗽.'
On October 27, 2026, Interior Secretary Doug Burgum signed Secretary’s Order No. 3454, “Supporting America’s Ranchers through Resilient Rangelands.”
Framed as support for rural economies and wildfire mitigation, the Order is a systematic expansion of livestock grazing priority across Department of the Interior lands. It accelerates permit renewals, reinstates suspended Animal Unit Months (AUMs), opens additional lands, eases constraints on predator control, and explicitly targets wild horses and burros for reduction to free forage for cattle and sheep.
The cumulative effect is a transfer of public rangelands from multi-species ecological function to industrial livestock production, with severe consequences for native predators, bison, and free-roaming equines.
Expanding Livestock at the Expense of Native Systems
The Order establishes a Department-wide Rangeland Health Initiative whose primary purpose is to facilitate livestock use.
Within 30 days, BLM, Bureau of Reclamation, Fish and Wildlife Service (FWS), and National Park Service must identify lands for long-term or emergency grazing. Within 120 days they must outline steps to issue permits. A goal of “no net loss of AUMs” is set, and BLM must inventory and evaluate reinstatement of suspended AUMs. Vacant and ungrazed allotments are to receive streamlined application processes, with preference for full 10-year terms for local livestock operators under the Taylor Grazing Act. Technology (“super intelligence”) is directed to clear permit backlogs and draft environmental documents for no-change renewals.
These directives lock in higher livestock densities on more acres for longer periods. Cattle and sheep are non-native, production-oriented herbivores whose grazing, trampling, and selective feeding have documented effects on western rangelands:
destruction of biological soil crusts,
soil compaction and erosion,
reduction of native perennial grasses,
and facilitation of invasive annuals such as cheatgrass.
Peer-reviewed analyses show livestock on public lands in the western United States are significant greenhouse-gas sources and shift ecosystems toward warmer, drier conditions that favor fire-prone invasives. A 1991 GAO report and subsequent studies found livestock grazing among the leading causes of species endangerment on public lands, particularly plants, with long recovery times in arid systems.
The Order’s emphasis on reinstating AUMs and opening new lands occurs without equivalent requirements to reduce livestock where rangeland health standards are already failing due to current grazing.
Predators and Other Wildlife Lose Protections
Section 5(f) and 6(b) require bureaus to identify and recommend changes to regulations, policies, and guidance that limit protection of livestock from predators. FWS must, within 90 days, review Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act processes affecting avian depredation and recommend changes to maximize livestock protection. Within 15 days, FWS must review the ESA section 10(j) rule and the Colorado gray-wolf reintroduction Memorandum of Understanding for greater responsiveness to livestock depredation, including criteria for lethal removal. FWS is also directed to initiate compatibility determinations for grazing in National Wildlife Refuge System units, including both temporary and 10-year authorizations.
These provisions tilt management toward increased lethal control of wolves, mountain lions, bears, coyotes, and other predators when they prey on livestock. Reduced native prey bases (deer, elk) from forage competition and habitat alteration already drive predators toward livestock; expanded grazing intensifies that dynamic.
Refuge grazing expansions risk degrading habitat used by bison, predators, and their prey.
The Order’s wildfire and “rangeland health” framing prioritizes livestock return after fire over recovery of native cover and structure needed by wildlife.
Direct Assault on Wild Horses and Sustainable Preservation
Section 6(a)(7) instructs BLM, “to the maximum extent practicable,” to reduce impacts on rangeland health from wild horses and burros. It requires improved tracking of fertility-control treatments, data collection on impacts to allotments, and a plan to reach and maintain Appropriate Management Levels (AML) “to ensure cessation of the destruction of rangelands by excess wild horses and burros.” This accelerates roundups, fertility control (including EPA-registered pesticides), and population suppression in service of livestock AUMs.
The Order’s background cites wild-horse “overpopulation” as a cause of reduced forage, reinforcing the narrative that horses must be reduced to free capacity for cattle and sheep. Free-roaming horses, managed as wild, function as ecosystem engineers in appropriate wilderness: year-round grazing reduces fine fuels, creates firebreaks, and can promote plant diversity and heterogeneity relative to sheep grazing. European rewilding studies (Portugal’s Greater Côa Valley; Iberian and Mediterranean systems) show semi-wild horses reduce grass height and biomass, lowering wildfire risk while favoring forbs. In contrast, cattle and sheep are seasonally managed, concentrate impacts near water and fences, and have been linked to cheatgrass expansion and loss of soil crusts. The Order ignores this distinction and treats horses as the problem to be solved for livestock.
Cattle and Sheep as Destructive Invasive Herbivores
Cattle and sheep are Eurasian domesticates introduced to North America. On arid and semi-arid public lands they differ fundamentally from native large herbivores or free-roaming equines.
Their heavy hoof action destroys biological soil crusts that stabilize soils and fix nitrogen. Selective grazing reduces native bunchgrasses, creating openings for invasive annuals. Trampling and nutrient redistribution alter plant communities, increase erosion, and degrade riparian zones.
Multiple studies document livestock as a primary driver of plant endangerment and landscape conversion on western public lands. While targeted grazing can sometimes reduce fuels, the Order’s expansionist approach—no-net-loss AUMs, reinstatement of suspended capacity, and opening of new lands—does not require the careful intensity, timing, or rest that even proponents of strategic grazing acknowledge as necessary. The result is further conversion of native systems toward livestock forage, at the expense of predators, bison, wild horses, and the biodiversity that depends on intact plant communities.
Institutional Momentum Against Multi-Use Balance
Tight timelines (30–180 days), preference for local livestock operators, coordination with USDA/Forest Service, and the Rangeland Health Initiative’s focus on livestock production create lasting institutional bias. The Wild Free-Roaming Horses and Burros Act, FLPMA’s multiple-use mandate, and refuge purposes are cited, yet implementation prioritizes livestock expansion and predator control over the ecological roles of free-roaming equines or the prey base for native carnivores. Existing failures of rangeland health standards due to livestock are not addressed with equivalent urgency.
Order 3454 is not neutral range management. It is a deliberate shift that expands the footprint and legal priority of non-native livestock, reduces constraints on lethal predator control, and accelerates suppression of wild horses to free forage. The ecological record shows cattle and sheep as agents of soil crust destruction, native-plant decline, and invasive-grass expansion. Treating them as the solution while targeting free-roaming horses and native predators is a policy of landscape conversion, not resilience.
References
Secretary’s Order No. 3454, Supporting America’s Ranchers through Resilient Rangelands (signed Oct. 27, 2026):
https://www.doi.gov/sites/default/files/document_secretarys_orders/so-3454-supporting-americas-ranchers-through-resilient-rangeland-2026-10-27-signed_508.pdf
BLM press release on the Order:
https://www.blm.gov/press-release/secretary-burgum-signs-order-support-american-ranchers-expand-grazing-and-cut-red-tape
Western Watersheds Project analysis of the Order:
https://westernwatersheds.org/2026/10/new-secretarial-order-prioritizes-grazing-above-all-else-on-public-lands/
Livestock Use on Public Lands in the Western USA Exacerbates Climate Change (Environmental Management, 2022):
https://link.springer.com/article/10.1007/s00267-022-01633-8
Managed as wild, horses influence grassland vegetation differently than domestic herds (Biological Conservation, 2024):
https://www.sciencedirect.com/science/article/pii/S0006320724000302
New paper highlights the benefits of grazing with wild horses (Rewilding Europe, Greater Côa Valley study):
https://rewildingeurope.com/news/new-paper-highlights-the-benefits-of-grazing-with-wild-horses/
Landscape-Scale Ecological Benefits of Properly Managed Free-Roaming Wild Horses (Pitchstone Waters synthesis):
https://www.pitchstonewaters.com/landscape-scale-ecological-benefits-of-properly-managed-free-roaming-wild-horses-in-appropriate-wilderness-ecosystems-an-empirical-and-scientific-synthesis-mini-dissertation/
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