The whole concept of "offsets" is rife with bureaucratic cronyism. It is left to mindless bureaucrats (BLM comes to mind) to make up the terms of the offsets. My experience with this concept proves that corruption is easily involved.
Look if this was land OWNED it the true sense of the word by the Federal government it could be sold to another country and all person could be ejected by that country when it became the new owner with no rights ...that doesn’t really happen that often even in war...
The government sold / granted a lease of grazing rights on public ( I.e held in common by the public..it is not government owned land)..a contract was made between the government as public agent and this rancher..
Was the understanding of that contract at the time is was made?...it can not be rewritten at will by the government....it a contract by many party and so ALL PARTYS have rights and restrictions based on the original contract of when the 1880?..
What was the federal, state, local, and private individual understood rights to this common public land use at that time?..
In fact the federal government is a creation of the states, and the states are a creation of the people as individuals.
I have contended for some time..that because the States wrote the Constitution and voted its enactment to create the Federal and the States control to amending or even, dissolve the Constitution and therefore the Federal..
..that states are the owners..the 50 States could have a Constitutional Convention and dissolve the Federal Government and Union at there will..
So who owns the directly owned federal property let alone the public property the Federal manages as a public agent?
The Constitution is the original contract that allows the Federal to act as a public agent of any kind. ...
What was the understanding at that time of that contacts writing?