The Bureau of Land Management (BLM) is having another meeting of the Wild Horse and Burro Advisory Board in Oklahoma, yesterday and today.
The meeting, as always, can be viewed live online at http://blm.gov/live Todays broadcast can be seen started at 1 pm Eastern time. WHE has intentionally not published our comments until after the meeting. We view these meetings as simply “public outreach” as that is the only actual opportunity this board has presented in recent years. The outcome has never been productive, factual, dialogue.
In recent years WHE has viewed these meeting as “more provocative than productive.” This “strategy” by the board has fueled discontent and contributed to the current environment that has fueled fictions rather than facts. In our opinion that will be evident to anyone that watches these meetings.
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 email@example.com); please include “Advisory Board Comment” in the subject line of the e-mail.
WHE is not in attendance, for multiple reasons. However our written comments can be viewed below:
Advisory Board Members,
The following comments are respectfully submitted to the board. We hope you consider them, in their entirety.
As participants in this process for several years our comments extend beyond the scope of recommendations to the Bureau of Land Management (BLM) made by this board. Our comments include aspects of board protocol.
Over the last few years the board has created a situation where provocative conduct is repeatedly rewarded and not discouraged. By continually placing members on the board that have put other interests and opinions forward as factual statements, instead of limiting discussion points to factual basis in law for management practices, a huge disservice to both the board and the public has been committed. We believe that public conduct exhibited today will clearly demonstrate this as a factual situation.
The Bureau themselves are complicit in creating this climate. Severe lack of proactive public outreach on public lands management process, and a lack of internal requirements geared at engaging employees toward rigorous understanding of policy, is a major underlying cause.
Our organization, Wild Horse Education (WHE), has been repeatedly portrayed as an “extremist” organization. In no way has that portrayal been factual.
WHE is an organization that was proactive toward the creation of CAWP. Conversations were slow and often nonproductive. As the issue dealt with immediate risks to the safety and well being of wild horses and burros we took appropriate steps and litigated. When one ruling was not enough to demonstrate the immediate need for such a policy, we litigated again. That does not make WHE extremist, it makes us expedient.
WHE is an organization that also had little patience for the “cat and mouse” game that failed to allow appropriate access to view, document and hold a government agency accountable to their actions. We litigated, successfully, on this issue for nearly five years. This does not make us “extremist,” it puts our organization very much in line with the intentions of the Constitution of the United States.
WHE has been working diligently to assist the agency with protocol, objectives and man-power toward creating a sound basis for a strong decision record. Each decision created in the wild horse and burro program can not be based on guesswork or outdated historical practices. Decisions must be based on the best available science, geared to create a scientific platform or they are not sound practices. That does not make us “extremists,” it makes us practical.
WHE has invested considerable time and resource to create plans based on sound practice and utilize the best available tools that meet all current legal mandates placed on the program. Our efforts include utilization of fertility control. We have invested considerable time and effort both in planning and execution. This does not make us “extremist,” it makes us proactive.
We urge the board to recognize that first and foremost members of the board must become familiar with the law, not interpretations of the law. We urge that an understanding that the Wild Free Roaming Wild Horses and Burros Act predates the Federal Land Policy Management Act (FLPMA) and, according to provisions in FLPMA, is not derogated.
We urge the board to recognize facts as such. Opinions on facts are to be related as “opinion” or interpretation. As an example wild horses in the US are a reintroduced native species. Each person is entitled to an opinion on what to do with a reintroduced species, but the terminology used will dictate the tone of conversation.
We urge the board to continue to recommend that the BLM:
Create decision records designed to acquire necessary data to create sound management decisions.
Utilize available approved fertility control as data gaps, that create measurable success variables that include genetic mapping and resource utilization, are put into immediate practice.
Urge BLM to prioritize humane management practices, sound equations that address resource use for ALL uses in any HMA, create defensible decision records.
As always we stand ready to engage any discussion, plan or action based on factual dialogue and sound adherence to viable management under all lawful mandates.
Urge BLM to understand that cronyism should not be tolerated. BLM is a regulatory agency, not a social club.
Questions by the board will be promptly responded to: WildHorseEducation@gmail.com
Wild Horse Education
Categories: Wild Horse Education