WHE Comments to the Advisory Board


EDITED: We removed the information on the April 2014 meeting to add the information on the August 25th meeting in Wyoming. To view the meetings the link is the same as last time: http://www.blm.gov/live/

Advisory Board meeting will be held in the Little Theater (SC 109), located in the Student Center Building of Central Wyoming College, 2660 Peck Avenue, Riverton, Wyoming 82501, phone number 1-800-735-8418. The agenda of the meeting can be found in the Friday, July 25, 2014, Federal Register (at http://www.gpo.gov/fdsys/pkg/FR-2014-07-25/pdf/2014-17378.pdf).

The public may address the Advisory Board on Monday, August 25, from 1:00 p.m. to 2:30 p.m., local time. Individuals who want to make a statement at Monday’s meeting should register in person with the BLM by 12:00 p.m., local time, on that same day at the meeting site. Depending on the number of speakers, the Board may limit the length of presentations, set at three minutes for previous meetings.

Speakers should submit a written copy of their statement to the BLM at the addresses below or bring a copy to the meeting. There may be a Webcam present during the entire meeting and individual comments may be recorded. Those who would like to comment but are unable to attend may submit a written statement to: National Wild Horse and Burro Program, WO-260, Attention: Ramona DeLorme, 1340 Financial Boulevard, Reno, Nevada, 89502-7147. Comments may also be e-mailed to the BLM (at wildhorse@blm.gov); please include “Advisory Board Comment” in the subject line of the e-mail.

To read our post on the Advisory Board go HERE: http://wildhorseeducation.org/2014/04/11/wild-horse-advisory-board-meets/

Wild Horse Education will NOT be in attendance at the meeting. Pressing issues on the range take priority for us. Our history with the meetings are that the public is given out of context opportunity to comment, has a two or three minute on “air” moment, the conversations at the board are not meaningful and anything accomplished can be accomplished without attending. There may be local or national media in attendance but we have found that the issues surrounding the media is more of a “circus” at these events than productive dialogue. Instead we will submit written comments. If the board begins to address the public in an interactive fashion and create meaningful recommendation we may attend in the future.

Comments listed below are the same comments we submitted in April. We will submit these same comments in August and WILL NOT attend a meeting of a board that we find offensive in it’s skewed membership, lack of action and lack of original thought. As long as Boyd Spratling, (a member of the Nevada Department of Agriculture, proponent of horse slaughter, participant in propaganda utilized by the Nevada Association of Counties (NACO) that has filed suit against the BLM to remove and destroy Nevada’s wild horses) sits on the board we will not attend any further meetings.

Wild horse youngsters in a trap at holding, Diamond Complex 2013.

Wild horse youngsters in a trap at holding, Diamond Complex 2013.

BLM Advisory Board meeting April 14, 2014 AND August 25, 2014 (with amended final paragraph)

Written Comments

submitted for inclusion in the record by Laura Leigh, President of Wild Horse Education

Advisory Board Members,

At this juncture we continue to address long standing issues with the Wild Horse and Burro Program that have gone unaddressed. The lack of action on core issues has now compounded to the extent that we are literally “between a rock and a hard place.”

In the past we have attended multiple Advisory Board meetings and workshops. The meetings produce nothing more than a sensation of procrastination on core issues. Token gesture have been made in issues of humane care and adoption recommendations. Yet the majority of the discussion by the board continues to be representative of profit driven public land “interests” instead of representative of the majority of public opinion or true welfare of wild horses and burros.

It is with extreme frustration that we continue to ask the Advisory Board to make recommendations to the Bureau of Land Management toward addressing these fundamental flaws. We hope that the board will begin to discuss something more than sterilization and euthanasia as “range management options.” We have entered into an extremely tense time on our Western public lands. However none of this is unforeseen. In much of our west the natural cycle is to have 3 years of drought in every ten year cycle. We have used our range resources in a manner that simply says “here is the amount of grass we expect” and then divide that amount using an antiquated equation based on historical use and never taking into account the fact that the historical use was “over use.”

Now we face, yet again, a “blame the horse” mentality that is far from accurate. Reductions in livestock AUMs have become a fact of life the last couple of years. These reduction are occurring everywhere, not just in areas that overlap current wild horse herd management areas. The only thing so far that has saved the wild horses from paying the price for years of misappropriating grazing AUMs is that there is no space in holding. Instead of emergency measures to rectify the faulty allotment of AUMs we have conversations occurring in “emergency” measures that may involve euthanizing wild horses in holding and on the range.

Immediate protection of resources to maintain wild horse populations, intact, should be the goal of any agency or board whose mandated mission is protection of wild horses and burros.

Perspective is often lacking in recommendations that come from this board. We urge you to reflect on the facts prior to any recommendations instead of revising the facts to suit recommendations.

Fact 1: Wild Horses and Burros exists on less than 12% of public land while overlapping uses have extensive public land resources and private property options.

Fact 2: Within the 12% of our public land base that has been deemed legal wild horse ranges, wild horses and burros are most often allocated less than 16% of available resource. This figure never fluctuates and does not reflect the required resource required for sustained use by viable herds. It is a “left over” quotient after other uses are prioritized.

Fact 3: “Overpopulation” is based on an arbitrary number called “Appropriate Management Level,” AML. AML is not reflective of any valid equation. This statement is supported by the following factors:

a) Forage allocations do not reflect “actual use” by wild horses. Often when populations are over “AML,” even by two or three times, only a fraction of allotted AUMs are actually utilized.

b) “Over AML” does not mean “over allocated use.” The National Academy of Sciences (NAS) report published last June stated that BLM was basically vacant of data in the wild horse and burro program. The report cited that population counts are inaccurate and likely reflect an under counting. We have heard this statement manipulated to suggest that wild horses are more “over populated” than we think. However in truth this statement must be applied to all relevant aspects dependent on any “number” generated. IF there is an undercount then the undercount occurred when AML was set. If methodology for doing population surveys improve and reflect more wild horses that methodology should not be applied to an inaccurate baseline. A new baseline must be determined.

c) When the current “AMLs” were set there was no element that took preservation of intact wild herds into account. Genetic viability was not a factor in creating this baseline. We know now that genetic factors are at risk. Simply introducing a “few studs” from another area does not decrease the risk of genetic loss or development of anomalies in a population. The element of “releasing a few studs” is currently a present alternative to rectifying genetic risk. However most often a “zeroing out”  of an existing herd at risk is the conversation at hand instead of it’s preservation.

Fact 4: We still have no humane handling “Policy.” We have complaints of a failing adoption program yet we still fail to value wild horses and burros enough to enact a policy reflective of any value. “Memos” that give authority to determine what is appropriate action into the hands of the very people performing an action is not acceptable. In recent years multiple court orders have been gained by my organization against conduct. Any policy must be a tool that gives specific parameters for conduct and not a broad “domestic livestock” procedure guideline. Wild horses are horses, not cattle or sow. The only acceptable policy must reflect domestic equine practices. (Please see attachment).

Fact 5: HMA/HA boundary lines are flawed. These boundary lines are reflective of the inaccurate data noted in the NAS report and were highly influenced by local politics. Data must be gained on actual movement of wild horses and burros and if seasonal use of off “HMA” areas is noted, then those areas must be included as “historic use.” In many areas we have HMA boundary lines where the water sources are “off HMA” and show seasonal use. In many ares we have HMA lines that were drawn to exclude resources in what was a Herd Area (HA) that consistently have seasonal use but are considered “off HMA.” In many areas that are now excluded as legal for wild horse (HA) use we have domestic livestock production. All of the mentioned issues with territory legally available for wild horses and burros must be rectified.

Fact 6: The current challenge from the BLM to find a more effective birth control that includes permanent sterilization techniques is more than offensive. The utilization of scarce resource to create another tool to continue to mismanage wild horses and burros is irresponsible. Only after all of the flaws in the program are addressed that include faulty AML and forage allocations can any determination of an actual “over population” be valid. If an over population is valid then selective removal of adoptable animals, that have significant existing genetic representation, would be appropriate. During selective removal appropriate use of PZP-22, that has been shown effective in multiple situations, could be applied.

Fact 7: The adoption program is not a failure, it is a scapegoat. When adoptions are publicized and engaged by providing information that is more than a “number” wild horses get adopted. Trap site adoptions and several recent events clearly demonstrate this. When BLM relies on “removal” as it’s primary management tool and “adoption” as the catch all, the adoption program appears to be at fault. Over burdening the adoption program is the failure.

These comments could continue for several more pages. However the truth is that the basic flaws in management will most likely continue to be ignored by this board. In light of recent events that reality is becoming increasingly disturbing.

In Clark County Nevada last week we had a violent demonstration by a public land rancher that failed for years to recognize the authority of the federal government to restrict his use of public land. He failed to recognize the authority of the federal courts. Instead when an attempt was made to enforce compliance the rancher essentially engaged in inciting a violent uprising. That uprising resulted in BLM backing down from removal of trespass cattle on public land. This has created a very dangerous example.

We appreciate that the BLM took steps to ensure public and personnel safety in this instance. But we are extremely concerned about the impression of the public that BLM “backed down” in the face of a violent presence. We are sure that BLM will enforce the order of the courts at a more appropriate time and we will see ramifications. Yet this incident points to the very real concerns of an increasingly frustrated public.

Wild horse and burro advocates are very patient, law abiding participants in their attempts to gain pro-active “on the range” management solutions. Yet the inaction toward resolving these issues continues to be met with discussions from BLM and this very board about selling wild horses without limitation (to slaughter) or to actually euthanizing horses in holding so that BLM can continue it’s flawed practices.

In light of recent events it would be appropriate for BLM and this board to commend wild horse and burro advocates for their conduct. It would be very appropriate for BLM and this board to begin to actually address the concerns of those working so hard, within the system, to gain workable solutions to grievous errors in the historic management of wild horses and burros. It would be very appropriate for BLM and this board to begin to take actual steps to protect and preserve wild horses and burros according to the concerns of the vast majority of Americans and not a select handful of private profit interests. At this juncture it would be sheer irresponsible behavior to repeat the cycle of the past.

Currently the conflicts of interest apparent on the board with the continued participation of certain members and the lack of any additional members from mainstream advocacy, are very disturbing. Dr Spratling’s participation in support of the Nevada Association of Counties legal action through multiple channels is not acceptable. His conflicts of interest range from his position on the Nevada Department of Agriculture Board to appearances in films produced by pro-slaughter entities (United Horseman) are more than offensive as acting co-chair of a board intended to advise BLM on a program whose intention was to preserve and protect wild horses and burros as integral to the landscape. Until such time as the board either dismisses those with such conflicts, or creates a balanced board by inclusion of members of mainstream advocacy, the board itself lacks any true credibility. It can only be assumed that those appointed by BLM mirror the type of recommendations desired and those whose appointments are continually overlooked would create recommendations BLM has no desire to consider.

Thank you.

Laura Leigh

President and founder, Wild Horse Education

Reno, Nevada


Wild HorseEducation is devoted to gaining protections for wild horses and burros from abuse, slaughter and extinction.