The Bureau of Land Management (BLM) has another meeting of the National Wild Horse and Burro Advisory Board next week. To engage the board as a pragmatic advocate you first need to understand what the board is, and is not.
The board is a public interface required by the Wild Free Roaming Horses and Burros Act (WFRHBA).
Sec. 7. The Secretary of the Interior and the Secretary of Agriculture are authorized and directed to appoint a joint advisory board of not more than nine members to advise them on any matter relating to wild free-roaming horses and burros and their management and protection. They shall select as advisers persons who are not employees of the Federal or State Governments and whom they deem to have special knowledge about protection of horses and burros, management of wildlife, animal husbandry, or natural resources management. Members of this board shall not receive reimbursement except for travel and other expenditures necessary in connection with their services.
(For trivia buffs we know that this line is not strictly adhered to in any “black and white” sense as Boyd Spratling operated as not only a member of this board but co-chair as he also was a member of the board for the Nevada Dept. of Agriculture. Spratling is a proponent of horse slaughter and has been urging BLM to spay wild horses on the range for a decade. https://wildhorseeducation.org/2012/08/03/ndoa-meeting-and-action-request/ and http://wsm.wsu.edu/mystory/?p=2006)
The board serves in an “advisory” capacity only. There is no provision that gives this board any legal authority and the BLM is under absolutely no obligation to follow or adopt any recommendation from the board. This is critical to remember if you chose to engage the board. (additional note for advocates that watch and read process. We are aware that the BLM sites recommendations from this board in the EA on the experiments for spaying as justification. It is technically NOT a legal justification that carries anymore weight than any other public “recommendation,” particularly if it does not reflect scientific opinion, and it does not. It is also not an ethical one as Spratling led that “recommendation process” and represents those that stand to gain financially from spaying as he also held a position on a veterinary board in NV, as well as the Dept of Ag, that represents individuals and himself, that will likely be “hired” to do any “spaying.” The vets and entities would not be volunteers. Just a thought for those of you “thinking”).
If you prepare comments for the board the comments need to be addressed to the board. They should be prefaced with “I ask that you provide the following recommendation to the BLM (list your recommendation) for the following reasons (and provide the factual content that you base your recommendation on).” We often see comments sent to this board that are open attacks on the agency, or accusations that the board did some action taken by the BLM. The board is an “advisory” board, not the agency.
The board is an open public interface. So this is not like “comments to an EA” or other land use planning process. This IS a time when you can appropriately repeat the same comment multiple times for impact of public interest. This is a time you can address any aspect of the program you want to address from holding, adoptions, capture methods and on range practices. However you must remember the board is not the agency and the agency is under absolutely no legal obligation to adopt any recommendation from the board.
If you attend the meeting you will be held to a comment period of one to three minutes depending on the number of attendants that desire time to make open comment. One to three minutes happens fast. If you plan to go we recommend that if you are not a comfortable public speaker, that you grab a stop watch and practice speaking clearly and rapidly, to get your comment on record. However it is critical that you remember the board is not the agency and that the agency is under no legal obligation to adopt any recommendation from the board.
Many organizations and individuals have turned the comment period into a “three minute glory moment” for social media. They have given you an impression that they are “taking on the BLM.” No, they are addressing a board that has no legal authority. We have seen everything from extreme animal rights using bullhorns and being dragged out to crying cowboys at recent meetings (many of you will remember “That damn Laura Leigh,” being said between crocodile tears at a recent meeting by a rancher that ran in trespass for eight months, broke multiple codes of federal regulations and then tried to blame wild horse advocates for his conduct). At WHE we often refer to the Advisory Board as “the circus coming to town, pink elephants in the center ring.”
What we would suggest is that you take time to create written comment.
As a step in becoming an effective pragmatic advocate we urge you to take the time to create written comment, even if you do it as an exercise of your “education.” Take one of the things you would like BLM to do and then find the validation for your request. “I want more horses on the range.” If that is your comment research how and why BLM has set the number they have. You will find it is a complex process that takes place in land use planning that translates into an area by area conversation. So then how would you address that as a recommendation to the board? You might find it a more suitable comment to suggest something like “I ask the board to recommend that the BLM reevaluate AML (a baseline for the number of horses allowed legally on the range. This is not the only parameter that determines excess under law, that is another myth) utilizing criteria outlined in the National Academy of Sciences (NAS) study released in 2013. The study directly assesses the agency as having a lack of data on the herds that includes valid equations of genetics and resource preservation,” and then site the paragraphs in the study to support your recommendation. (you can download a copy of the report in the post https://wildhorseeducation.org/2013/06/05/nas-report-a-first-look/)
Creating these comments can give you insight into the issues, what arguments are valid, what organizations create valid engagement in process and take you a step closer to becoming an educated advocate, the one thing our wild ones desperately need more than anything else. Then send in your comments, they will likely be much longer than a three minute “glory moment” at a microphone in Elko NV. It will be much more effective in preparing YOU to address comments in public process where your ability to create appropriate comment becomes crucial.
YOU are the voice of the “wild horse and burro.” Become an effective one.
BLM Sets Meeting of National Wild Horse and Burro Advisory Board for September in Elko, Nevada
September 8–9 meeting will be livestreamed at http://www.blm.gov/live
The Bureau of Land Management’s National Wild Horse and Burro Advisory Board will meet September 8-9, 2016, in Elko, Nev., to discuss issues relating to the management and protection of wild horses and burros on Western public rangelands. The two-day meeting will take place on Thursday, September 8, from 1:00 p.m. to 5:15 p.m., and Friday, September 9, from 8:00 a.m. to 4:30 p.m. (The meeting times are local time; Elko is in the Pacific Time Zone.) The meeting will be live-streamed at http://www.blm.gov/live.
The agenda of the upcoming meeting can be found in the August 1, 2016, Federal Register at http://go.usa.gov/x4TRJ. The meeting will be held at Stockmen’s Hotel and Casino, 340 Commercial Street, Elko, Nev. The hotel’s website address is http://www.northernstarcasinos.com/Stockmens-hotel-casino; its phone number is (775) 738-5141.
The Advisory Board provides advice and recommendations to the BLM as it carries out its responsibilities under the 1971 Wild Free-Roaming Horses and Burros Act. The law mandates the protection and management of these free-roaming animals in a manner that ensures healthy herds at levels consistent with the land’s capacity to support them. According to the BLM’s latest official estimate, approximately 67,027 wild horses and burros roam on BLM-managed rangelands in 10 Western states.
The public may address the Advisory Board on Thursday, September 8, from 3:15 to 5:15 p.m., local time. Individuals who want to make a statement at Thursday’s meeting should register in person with the BLM by 3:15 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 will 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-261, Attention: Ramona DeLorme, 1340 Financial Boulevard, Reno, Nev., 89502-7147. Comments may also be e-mailed to the BLM (at firstname.lastname@example.org); please include “Advisory Board Comment” in the subject line of the e-mail.
For additional information regarding the meeting, please contact Ms. DeLorme, Wild Horse and Burro Administrative Assistant, at (775) 861-6583. Individuals who use a telecommunications device for the deaf (TDD) may reach Ms. DeLorme during normal business hours by calling the Federal Information Relay Service at 1-800-877-8339.
The Advisory Board generally meets twice a year and the BLM Director may call additional meetings when necessary. Members serve without salary, but are reimbursed for travel and per diem expenses according to government travel regulations.
In its management of wild horses and burros, the BLM is taking a number of steps to ensure healthy horses and burros thrive on healthy public lands , including sponsoring a significant research program focused on fertility control; transitioning horses from off-range corrals to more cost-effective pastures; working to increase adoptions with new programs and partnerships; and requesting two new pieces of legislative authority — one to allow for the immediate transfer of horses to other agencies that have a need for work animals and one that would create a congressionally-chartered foundation that could help fund and support adoption efforts.
The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to sustain the health, diversity, and productivity of AmericaÂ’s public lands for the use and enjoyment of present and future generations. In Fiscal Year 2015, the BLM generated $4.1 billion in receipts from activities occurring on public lands.
Main website http://WildHorseEducation.org
Categories: Wild Horse Education