Now back at the Interior Department as associate deputy secretary, the agency’s third highest-ranking position, Budd-Falen’s portfolio has expanded, yet her potential conflicts of interest related to ranching and land use remain strikingly similar, as detailed in her 2025 financial disclosure. Despite the clear language of her earlier recusal, evidence suggests Budd-Falen has been actively involved in several grazing-related issues during her current tenure. These include a contentious, long-running dispute over beef and dairy operations within the environmentally sensitive Point Reyes National Seashore in California and the department’s recent significant overhaul of the National Environmental Policy Act (NEPA), a move widely seen as beneficial to public land ranchers across the nation.

Before her government service, Budd-Falen carved out a career as a private attorney, representing numerous ranching entities in legal battles against environmental regulations and the very public land management agencies she now helps oversee. Her and her husband’s financial disclosures reveal stakes in multiple ranching operations, some of which hold federal permits to graze cattle on vast tracts of public land. One of these ranches, Home Ranch, LLC, is central to a lucrative financial transaction involving Budd-Falen’s husband and the developer of a major Nevada lithium mine. This deal, initially brought to light by investigative reporting, has ignited calls for a formal investigation into potential impropriety.

A critical point of contention is the apparent absence of an updated ethics recusal covering Budd-Falen’s current role. Should such a document exist, and if it permits her involvement in grazing policy, the rationale remains unclear, especially given that her most recent financial disclosure details ranching assets closely mirroring those she held during her initial Trump administration appointment. Documents released by the Interior Department last month to the Center for Western Priorities, a Colorado-based conservation advocacy group, included only her 2018 ethics filings, alongside general ethics guidance and a redacted draft list of her recent legal clients. The lack of a current, specific recusal has fueled concerns among environmental groups and ethics watchdogs.

The Interior Department has consistently declined to answer questions regarding whether Budd-Falen’s 2018 ethics documents remain binding. While a spokesperson stated last month that she had filed all appropriate paperwork and that her relevant ethics filings "have been supplied," this assertion did not address the core issue of an updated recusal specifically addressing her grazing interests. Following inquiries in March about Budd-Falen’s involvement in grazing matters, a "conflict of interest waiver" for her suddenly appeared in the U.S. Office of Government Ethics disclosure database. The specifics of what this waiver covers, and why it appeared at this juncture, have not yet been publicly disclosed, further intensifying calls for transparency.

Patrick Kelly, the Montana and Washington state director for the environmental advocacy group Western Watersheds Project, voiced strong concerns, stating, "If Budd-Falen is indeed still bound by her 2018 ethics recusal, then her recent conduct plainly violates it." Kelly elaborated that the original agreement prevented her participation in federal grazing matters precisely because she opted not to divest her personal grazing interests. "No replacement ethics disclosure has surfaced suggesting the restriction has been lifted," he noted, adding, "Her recent and very public involvement in grazing disputes — including the ranching settlement at Point Reyes — would place her squarely in violation of the prohibition against participating in grazing-related discussions. This represents a glaring conflict of interest and raises profound questions about whether federal public-lands decisions are being shaped in the public interest or at the behest of the livestock industry."

Budd-Falen was already facing mounting scrutiny over her deep financial ties to the Thacker Pass lithium mine in Nevada. This massive mining project, approved during the first Trump administration, became a point of controversy when it was revealed in December that her husband sold crucial water rights from Home Ranch, LLC – one of the family’s ranching operations – to Lithium Nevada Corp., the mine’s developer, in 2018. Crucially, Budd-Falen did not publicly disclose this significant water sale in her annual financial disclosure forms. While she received a waiver in 2018 allowing her to retain her financial interest in Home Ranch and other family ranching assets, this waiver explicitly stipulated that she would not participate in matters that involved or could financially benefit these operations. The implications of this undeclared transaction and her subsequent involvement in relevant policy have prompted House Democrats to formally request an investigation by the Interior Department’s internal watchdog.

The global demand for critical minerals like lithium, essential for electric vehicle batteries and the broader energy transition, has intensified the debate surrounding projects like Thacker Pass. While proponents argue for the strategic necessity of domestic lithium production, environmentalists and indigenous communities have raised alarms about the potential for significant ecological damage, including impacts on water resources and sacred ancestral lands. The intertwining of Budd-Falen’s family business interests with such a high-stakes, globally significant project underscores the complexity of managing public resources while upholding governmental ethics.

Budd-Falen’s influence extends to critical environmental policy frameworks. The Trump Interior Department’s press release announcing its NEPA reforms highlighted that the changes would "reduce delays and costs for projects across public lands, including energy development, critical minerals, livestock grazing approvals" and other activities. Budd-Falen was prominently quoted in the announcement, praising the administration’s actions as "a decisive step toward fixing a broken permitting system." She asserted, "Interior is restoring NEPA to what Congress intended — a procedural law that informs decisions, not a regulatory maze that delays them for years. These reforms will help unleash American energy, strengthen rural communities and deliver real results faster for the American people." Critics, however, contend that such reforms weaken environmental protections by streamlining the review process, potentially leading to less rigorous assessments of project impacts on public lands.

Beyond policy overhauls, Budd-Falen has also directly intervened in the long-standing dispute over grazing at Point Reyes National Seashore, a unique coastal national park north of San Francisco known for its biodiversity and scenic beauty. For decades, cattle and dairy ranching have coexisted, often uneasily, with conservation efforts within the park boundaries. In the final days of the Biden administration, a landmark agreement was reached between environmental groups and ranchers to phase out most grazing operations at the preserve, with affected ranchers receiving compensation. However, the deal faced unexpected political intervention, with Health and Human Services Secretary Robert F. Kennedy Jr. reportedly attempting to derail it. Subsequently, Interior Secretary Doug Burgum tasked Budd-Falen with "broker[ing] a Point Reyes solution."

Earlier this month, Budd-Falen traveled to Point Reyes, engaging in meetings with a diverse array of stakeholders, including park leaders, environmentalists, affected ranchers, and what local newspaper The Point Reyes Light described as "a motley crew of ranching advocates who have spent over a year attempting to unravel the deal." Her direct involvement in this highly localized yet nationally watched grazing dispute, given her explicit 2018 recusal, has intensified questions about her adherence to ethics rules and the integrity of her office.

Craig Holman, a government affairs lobbyist and ethics expert at the progressive watchdog group Public Citizen, emphasized that ethics rules generally carry over when an individual leaves and then reenters government service, remaining in effect until explicitly altered or nullified. Holman stressed that the primary issue is not necessarily Budd-Falen’s ethics recusal itself, but rather a perceived lack of enforcement. "Literally, all the agencies charged with enforcing these ethics rules have been dominated by Trump loyalists who do not believe in the rules," Holman observed, reflecting a broader concern about the weakening of institutional checks and balances. "Trump personally finds ethics restrictions as obstacles to his interests and has revoked the presidential ethics executive orders. More importantly, he has neutered the very agencies charged with enforcing governmental ethics." This perspective highlights the systemic challenges in upholding ethics standards within an administration perceived as less inclined to prioritize regulatory oversight, leading to a potential erosion of public trust in the impartiality of government decision-making regarding valuable public lands and resources.