Wild Horse Education

The Game of AML, part one


The end of wild horses as we know them is in sight

UPDATE 3/5/2021 You can help us take action. HERE.

Appropriate Management Level (AML) is supposed to be set in an OPEN public process called a Herd Management Area Plan (HMAP). The HMAP begins with a public scoping (input) process where information about the herd and concerns can be presented along with management suggestions prior to the document going to the “EA comment” phase. The HMAP is supposed to include all objectives for the herd and tell the public the method for determining AML and the triggers to reevaluate AML.  AML is NOT supposed to be set in a “gather plan” or a Land Use Plan that is NOT informed by an HMAP.

The Appropriate Management Level (AML)* game deserves an entire article of it’s own. This game is played at two levels in this multi level chess game and then carried onto the law making table. Like all the myths it is wrapped in so many levels of bubblewrap that an honest conversation gets lost in the insulation created to perpetuate the insanity.

*The number of wild horses the Bureau of Land Management (BLM) claims the “land can sustain.”

In 1971 wild horses and burros were declared “fast disappearing.” The population estimate was 25,000 (primarily estimated in a drive through “windshield survey” method). A few years later an absurd number, 27,000, was agreed on as appropriate after the claiming period completed (where tens of thousands of wild horses were claimed as private property and eradicated).

The BLM now officially, after years of knowing the truth, recognizes counting methods were flawed.

So then the BLM changes counting methods, but they don’t apply the same changes to the original number.

It’s like a toddler sitting there saying they have 6 marbles, “I always had six marbles.” You tell him, “You have more under the couch and in the seat cushions.” You pull out 20 more marbles, that were always there. The toddler acts like he had 6 ,and the 6 magically multiplied, and now he has 26. “No dear, you always had 26.”

If you change methodology you have to change the original variable. It’s algebra 101. Maybe the toddler will understand when it hits third grade? However this is not a toddler, it’s a federal regulatory agency. The propaganda is perpetuated to forward a corrupt system of land management. You have patience with a toddler.

AML is also not a magic number that BLM must use to hit the benchmark for a roundup. In recent years it appears that politics has, once again, misled the public and media. BLM is mandated to manage, not remove. Determination of excess horses is supposed to involve multiple factors prior to a roundup occurring, not simply numbers. Management is also supposed to protect the range resources horses need to survive. In practice? we just give away the range and use faulty AMLs as the only benchmark.

Horse hit with chopper Triple B, 2011

The example of “stupid” that makes your head want to explode: humane handling and access. This can better help you understand that the “game of AML” is treated the same way. 

Using the examples of humane handling, or access issues, are always simplistic ways for me to illustrate the contradictions between words and actions. The federal government manages our western landscape on a hamster wheel of contradiction.

The line goes; “We are completely transparent and treat wild horses with absolute care, humanely.”

The reality goes: Day after day, year after, I would travel to trap site site and experience the exact opposite in practice. I was chased around the desert and threatened with arrest for trying to see wild horses in a temporary holding facility after capture while I had a court order in my hand where BLM agreed to a federal judge that they “would do everything in their power to accommodate access.” In freezing weather or blistering heat, day after day year after year.

I would fight in court, or on the ground, to see anything meaningful as they told media they were “completely transparent.” When I could see I witnessed babies run to collapse, wild horses run through barbed wire, kicked in the head, hotshots use in routine fashion to speed loading (not under “life and death” situations as they told the press), hot shot use on babies, helicopter even hitting a horse.

Court order after court order had to be won. A million miles, literally, had to be travelled back and forth from range to court to range to court to Congress. Every time I would appear in front of a judge they would ask BLM “what are you doing about this?” After simply denying it did not happen and facing disgust from a federal court judge, Honorable Howard D McKibben, who said “I find your defense a blame the horse affront,” BLM began to work on a policy. That was in 2011 and I had to go back to court again and again.

In 2015 BLM finally included a version of the “Comprehensive Animal Welfare Policy,” or CAWP, into roundup contracts.

In 2014 an agreement was made to make observation at roundups a priority, with specific parameters, and to open the Broken Arrow facility back up to public tours. At this time tensions in Nevada were off the charts with threats against federal workers and environmentalists. I worked hard with former Nevada State Director Amy Lueders to create an access protocol that could remain flexible to keep people safe from other people that might come to disrupt operations, not a policy to exclude meaningful access. Those conversations began in 2013 and lasted almost a year, after a 4.5 year court battle that had been successful up and down the legal system and when stacked stands taller than my mid thigh.

In 2017, after the most amazing storm of twisted nonsense, I was once again waking before dawn and traveling hours to a trap site to be denied access day after day. When I did have access (over 1.5 miles away) a 400mm lens, on a doubler, reveled a barbed wire fence being used as a trap wing.

Then the district manager in that area said (after I had been treated really poorly for months, a complete disregard for professionalism, and was then held with no access for a week), “We have to treat you like this because ranchers don’t feel we listen to them.”

Appropriate Management levels, AML

AML has a three level approach to the perpetuation of the fiction, national, state and field office. Most myths that require this type of insular practice have this same approach. These insular myths are always wrapped in one or more myths. The lower down the food chain you go, the more insulation is required to prop up the top.

National: At the national level we always have a broad brush statement. 2014, “The Bureau of Land Management says that Western rangelands can sustain about 26,000 wild horses. There are now 48,000.” in 2017, “46,000 wild horses and burros in corrals. Another 73,000 of the animals roam freely across the western states.” The numbers really are not important except this one “26,000,” and we will explain later in the article.

State goes like this: “The BLM’s Appropriate Management Level—the population of horses for a thriving natural ecological balance—here is between 101 and 170 horses, but the current population is nearing 500, pretty standard overpopulation rate for Nevada wild horse herds. Statewide, the appropriate management level is 12,800, but the current population is estimated to be more than 34,000.”

When you get to the field level the entire burden gets placed on the shoulders of the wild horse and burro specialist (whbs). This person is either someone that took the job as an entry to a federal pension and is looking to transfer to a “better” position in a year, someone from the local ranching community, or someone that actually cares about horses but is so swamped with tasks that in truth, “copy paste” becomes the standard practice and the more “copy paste” the more pages you create, that create the impression of depth, to hide a broken heart. (I have watched many of those hearts either turn cold or drown. They are human and need insulation. The insulation usually comes from creating an “enemy mindset” against those that challenge you and hiding in the bureaucratic  bubblewrap, transferring or quitting).

Now it’s time to look at that 26,000 number, the number the “land can sustain” according to the top level officials, the ones that engage the law makers.

In 1971 the Wild Free Roaming Horses and Burros Act (WFRHBA) was passed into law and stated that “wild horses and burros were fast disappearing from the landscape. Law makers, that were not creating an environmental protocol based on science, but a law under pressure from the public in an election year, agreed that wild horses would be managed at the current estimated population level. Not exactly scientific recognition of anything and the “game of numbers” begins.

A little discussed National Academy of Sciences review in 1982 found that BLM’s “population survey methods” were extremely flawed and the number of horses claimed on the range was woefully inaccurate and severely underestimated. The 1980, 1982 and 1991 report are all cited in the 2013 National Academy of Sciences (NAS) review and, one more time, reiterates that the original and subsequent survey methods are severely flawed. In addition the 2013 report cites severe flaws in methodology through 2013.

In addition there was a “claiming period.” Essentially mustanging continued after the act was passed for 4 years. During the claiming period nearly 17,000 wild horses were claimed as “private property” in one year just in Nevada alone. None of those individual animals, are included in any equation that has any validity, in what the “land can sustain.”

The BLM continually referencing that the first survey numbers that found “26,000” as a sustainable number, and that subsequent surveys support that assertion, is as accurate as “we manage them with full transparency and humanely.”

That’s the “AML” game presented to law makers. The one at the field level falls under another heading “the game of healthy horses, healthy rangeland.” That myth is wrapped in the game of friends, family and “keep that gun out of my face.”

Any “AML” of wild horses that asserts a “healthy range” component must contain a valid equation for management of public resource in the bigger picture. That is where myth, fact and insanity collide; “on the land where they now stand.”

UPDATE and action item on the Appropriations language, aimed at putting a bullet in the head of tens of thousands of wild horses HERE.

Game of AML, part two (Bubblewrap) 

If you really want to understand why wild horse management by the federal government is a train wreck, you need to understand how they are trapped in the public land seizure movement. A series of articles here: https://wildhorseeducation.org/wild-wild-horses-and-the-public-land-seizure-movement/https://wildhorseeducation.org/wild-wild-horses-and-the-public-land-seizure-movement/https://wildhorseeducation.org/wild-wild-horses-and-the-public-land-seizure-movement/


Our founder 6 years ago at a press conference in Phoenix.

Categories: Wild Horse Education