BLM Reports to Congress; so does WHE

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Photo taken at the recent Triple B roundup in NV. This roundup had multiple examples of the political prioritization of funding, the inability to place the welfare of the wild horses into the equation (even prioritizing a man grading a road over appropriate action for wild horses). The examples are voluminous in each and every action BLM takes west wide. We now have the opportunity to use each and every one in our response document, under legal review, that we send to Congress.

EDIT 3/19/19: On Valentine’s Day of this year Congress asked for a new report (HERE). That’s good news.

The bad news is that the new report is being heavily influenced by the same big money that created the old report. Instead of seeing research done into the flawed framework and how to fix it, we are seeing simply expanding of cost breakdowns for the options in the old report (rebates for adoptions that create a greater risk of wild horses going to slaughter or landing in bad situations like we saw at Sheldon USFWS, contracts for gelding and spaying, contracts for holding facilities). The influence is being created by those that have a lot of money already and hope to profit off of further exploitation, on all sides of the fence. 

At WHE our ground data and the issues we have documented in range management are being placed onto the pile of information Congress is using to address things like sage grouse and oil and gas, not wild horses. The reason? is because of well funded political games that have already sold the horses down river. We have basically been told that the options in the old report are a “done deal” and cost breakdown alone, not range data, will determine the course of action. 

Understand the old report as we get ready to battle the next one (due in summer). This next battle line will determine sterilized herds and a faster track to the kill pen. Are you with  us? Please read. (BLM report: BLM2018_Report2Congress)

For a Glimpse into the political corruption: https://wildhorseeducation.org/2019/03/06/underneath-the-headlines-wild-horses-and-national-monuments-hand-in-hand/


4 wild horses were left in a cattle grazing allotment (fenced) for over 100 cows. This is what BLM is using sage grouse funding for.

Laura Leigh, president of the Wild Horse Education horse protection advocacy group, said the report ignores the impact of cattle and sheep grazing on public rangeland and relies heavily on recommendations made at a meeting in Salt Lake City last year organized by livestock interests.

“The agency repeatedly scapegoats” the horses while “ignoring extreme deficits within the much larger livestock grazing program, diverting personnel from the (horse program) to placate other concerns, prioritizing existing funding based on political pressure not rangeland needs,” she said Friday.

Read more at US News and World Report HERE.

Wild Horse Education Response Article

The long awaited “report to Congress” by the Bureau of Land Management (BLM) has arrived. At Wild Horse Education (WHE) much of our work in the last year has been in anticipation of this document. The document crafted predominantly while John Ruhs (former acting associate in DC, former NV state director and pending lead for fire in Idaho) and Alan Shepherd (former Wild Horse and Burro lead for the state of NV) were both warming chairs in Washington; individuals we know very well at WHE.

Much of the content is exactly what was expected. Our official response document is being edited that includes much of the information we have been providing to the Office of the Inspector General, Office of Special Council, Government Accounting Office and a House Investigative Team since April of 2017. Our final compilation will be available online after legal review.

We are aware that our readers are anxious to see the BLM document and our review. To satisfy that curiosity we have linked the BLM document HERE: BLM2018_Report2Congress

Below is the draft of our Summary and Background sections. We will publish the final document after sending to the members of Congress we are working with in final, approved and edited, version.

Please note that our field work is vital to refute assertions, craft management alternatives and litigate (effectively) any actions that may be forthcoming from the creation of BLM’s report to Congress. A simplistic example is demonstrated after the second video presented in this article (HERE) with a conclusion that perhaps an investigation into statements made, under oath, is warranted. At this juncture accountability to falsehoods that create irreparable harm to public trust and wild herds must be an objective if we ever hope to achieve any semblance of the intention of the law; wild horses, and their habitat, preserved and protected on healthy public lands. (We have a generous matching donor through May 5)

Please remember this introduction to our analysis is in draft form. Our response document contains site specific trend examples. Long term, sustained, management of wild horses on our public land is within the realm of possibility. However those possibilities cease to exist when federal agencies perpetuate (juvenile) practices of reports without substance, propaganda to suit personal agenda and laziness. 

Please be aware that each photographic example BLM uses has a story behind it. Our report will explain each in detail and why the individuals at the helm at the time of the crafting of this report used them, are responsible for them and should be held accountable through a serious investigation into the WHB program.

Wild Horse Education Response Document:

BLM Report to Congress Management Options for a Sustainable Wild Horse and Burro Program (2018)



The Bureau of Land Management (BLM) has presented a report to Congress as required by law. Congress requested a report on the BLM wild horse and burro program. The Consolidated Appropriations Act of 2017 (Public Law 115-31), requires this compliance.

BLM manages wild horses and burros on 26.9 million acres of the 258 million surface and subsurface public lands in their jurisdiction. Wild horses exist on about 11% of BLM managed lands.

BLM makes a claim that their management goal for the Wild Horse and Burro Program (WHB Program) is to “ensure healthy wild horses and burros on thriving public rangelands.” This assertion has been nothing more than a public relations statement that is not carried out in practice. The agency repeatedly scapegoats the WHB program as land managers continue to repeat long ingrained patterns including: ignoring extreme deficits within the (much larger) livestock grazing program, diverting personnel from the WHB program to placate other concerns, prioritizing existing funding based on political pressure and not rangeland (healthy horses, healthy range) needs.

The agency continues to use the excuse that a provision in the 1971 Wild Free-Roaming Horses and Burros Act, as amended, is a necessity as they are repeatedly hamstrung from using the 2004 Burns Rider that allowed wild horses to be sold to slaughter. BLM continually excludes that prior to the insertion of the stealth rider that BLM employees had been caught selling wild horses to slaughter, in contravention of existing law prior to 2004. Essentially BLM personnel were violating existing law for personal gain. The provisions to deny funding for slaughter sales has only existed for 13 years, prior to that it was simply illegal. The BLM program has been repeatedly found to be an abysmal failure in data collection and analysis since 1982 by the National Academy of Sciences (NAS) and that finding was repeated again in the 2013 NAS review. Funding the “sales without limitation” provision of the 2004 stealth rider would simply provide BLM with a way to sweep decades of ineptitude aside, nothing more.

This report continues to make assertions instead of admitting to a lack of substantive long term trend data and the need to establish that data prior to the issuance of any “report to Congress.” Core problems are absent from this report and repetitive assertions, without providing content or context, is egregious. The common mantra; wild horses have no natural predators, reproduce at a rate of 20% (populations doubling every 4 years), claims Appropriate Management Levels (AML) is an accurate representation of the number of wild horses the land can sustain, wild horses destroy habitat for every species (not limited to 26.9 million acres as wild horses are) from sage grouse to elk. (Reminder: the NAS has repeatedly failed the BLM on data and analysis since the 1980’s and repeated that finding in 2013).

This report relies on a “summit” organized by livestock interests and many involved in the political push to shrink federal control over public resources to the extent that this report has a distinct authorship signature. Not one national advocacy organization was invited that did not have members of either interest above. The use of any recommendations from the “Summit,” while footnoting random public comments that represent no organized conference and are not in any way an inclusive representation, continue to demonstrate the prioritization of political and personal interests held by agency employees. At the time of the referenced “summit” Resource Advisory Councils (RACs) had been shut down, and the National WHB Advisory Board was also suspended, limiting any official record of public engagement, timely, to political maneuvers.

BLM’s assertions that changing land use plans would be required to achieve certain alternatives, then simply ignoring those alternatives, is another example of status quo practices that we will describe in the document. BLM has been aware of multiple deficits in existing land use plans for over a decade, diverts personnel from changing those deficits, and continues a cycle of a “set up” for failure of the WHB program.

This response document will address BLM’s report and utilize site specific examples of long term trends to refute claims made in the BLM document. (BLM report can be found at this link for comparative purposes)


In 1971 the Wild Free Roaming Horses and Burros Act (WFRH&B Act) was passed unanimously by Congress. The American public had an expectation that wild horses and burros would be protected, and their habitat preserved for their sustained use, by the federal government.

In close to 50 years the BLM has not made any concerted, reasonable, effort to fulfill that expectation.

The first removal of wild horses under the WFRH&B Act at Stone Cabin was met with litigation. BLM had not prepared any analysis and simply cited deteriorating range conditions and herd health. The state of Nevada claimed the federal government had no right to carry out the roundup and wanted custody of the 80 wild horses captured for the purposes of selling them to slaughter. The court found that the BLM had the authority but could not simply remove wild horses to create more habitat for domestic livestock and must comply with the National Environmental Policy Act (NEPA) for any future removals.

The resentment over federal authority, the proximity of the special interests (livestock) to the federal employees in the community, has perpetuated a continuance of the identical practices present at the first roundup in 1975 with the only changes akin to simple window dressing in NEPA analysis that has been limited to impacts of removals, not management of a living species and it’s habitat.

The BLM handbook states that a Herd Management Area Plan (HMAP) be created that outlines objectives for herd and habitat preservation. To date only a handful of these HMAP’s even exist. Instead the BLM has relied on a “copy/paste” mentality that has created an impression of underlying data that justifies removals in Environmental Assessments (EA) for roundup operations. The HMAP, the intention of which was to provide an underlying framework for land use planning, has been ignored. Instead of utilizing a “best practices for the public good” strategy, federal land managers have simply bandied about the word “discretion” like a broom that sweeps aside all ineptness and corruption of the intention of law.

Please remember this introduction to our analysis is in draft form. Our response document contains site specific trend examples.

To support our field work, document preparation and distribution, engagement with Congress and Oversight, litigation please go to this link https://wildhorseeducation.org/2018/04/26/double-up-and-buckle-up/


Further reading:

The hearings in Congress in 2016 were seriously flawed and influenced by politics (all sides) https://wildhorseeducation.org/2017/05/17/posttruth-a-few-wild-facts-you-should-know-in-these-dangerous-times-part-one/

All the Pretty Horses Must Die: https://wildhorseeducation.org/2017/09/09/all-the-pretty-horses-must-die/

Categories: Lead, Wild Horse Education