The Honorable Debra Haaland


The Honorable Debra Haaland
Secretary of Interior
1849 C Street Northwest
Washington, DC 20240                                                                                                                                                                  

Dear Secretary Haaland,

The Organization for Competitive Markets (OCM) requests your consideration of this opportunity to express our concerns relating to communications recently directed to your office (dated April 9, 2021) by multiple organizations and individuals, advocating for the elimination of livestock grazing on BLM Herd Management Areas (HMAs)

 OCM is a multidisciplinary nonprofit organization founded in 1998 by farmers, ranchers, and other industry leaders focused upon the explicit mission statement, “To establish fair and competitive markets for agricultural products and to protect those markets from the abuse of power.”   Our work in establishing and protecting markets for farmers and ranchers also encompasses our responsibility to advocate for farm family production as well as the marketing of their produce.

OCM, in concurrence with its mission, opposes the prior multi-organizational request to cease farmer and rancher grazing on both current and future federal HMAs. OCM also does not support the taking or devaluation of producers’ grazing preferences (allotments).  Producer granted allotments have been long established as private property with rights protected by the Guadalupe Hidalgo Treaty, the Organic Administration Act, the Taylor Grazing Act, and by the doctrine of custom usage as laid down by the Supreme Court.  In addition, the United States Internal Revenue Service also recognizes these grazing preferences as private property subject to taxation codes.

Most OCM members manage multi-species operations including equine and they realize the importance of species management for the maintenance of healthy ecosystems.  Currently, federal grazing allotments account for nearly one-third of our nation’s true wealth in conjunction with many wildlife and recreational benefits.  From local fire suppression to global carbon sequestration the benefits from multi-species grazing enrich our daily lives.  As various livestock species forage differing roughage sources, we feel our public lands are best utilized through the continuation of cooperative participation between producers and local BLM officials.

In summary, OCM does not support the requesting organizations’ one-sided approach of giving precedence to single species domination of our Federal lands ecosystem.  OCM is disconcerted by the suggestion of control measures that infringe upon producers’ Fifth Amendment property rights.  OCM encourages further collaboration between local Dept. of Interior officials and permit holders in seeking solutions to the wild and feral horse overpopulation.

OCM thanks you for your consideration of this correspondence and welcomes future discussion of these issues.

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