Wild Horse Education

The Devils in the Details (BLM Report + 10 Years to AML, part two)

Owyhee_092618 - 1 (28)At this juncture most people in wild horse advocacy are aware of the joint document created by HSUS, Return to Freedom, ASPCA, American Mustang Foundation, National Cattlemen’s Beef Association and the Farm Bureau (HERE).

This is not a random document created by these massive corporations (like a generalized petition or talking point sign on letter), this document was created with the intent of doing an end run around the legislative process of creation of a stand alone bill. This document is formatted as a “proposal.” (Many are confused as there were so many “sign on letters.”)

This document was intended to change law through the Appropriations bill for 2020 (much like the Burns Amendment). It changes law/regulations to allow entire herds to be sterilized, creates massive new subsidies for “public/private partnership” that can turn over your wild horses into a permittee paycheck and guts the NEPA process, the only place you have a voice in land management.

It is important to understand that this document was not created in a day, week, or a month. This effort involves years of playing a cloak and dagger game; back stabbing, lying to the public and prioritizing “dividing the pie of wild horse dollars.” (none of this is new in the wild horse world and extends back to the days of Velma Johnston.)

We know you are angry about all of the things you are learning about this “deal making.” The task at hand is the pending BLM report to Congress that will determine how funding is allocated and what portions of the “ask” will be funded.

We created an abbreviated piece that gives you important context. (part one HERE)


Are wild herds a bargaining chip?

The two reports, the draft run

The BLM Report to Congress, released last year, incorporated the document you are reacting to today; “Ten Years to AML” created by HSUS, ASPCA, Return to Freedom and, the mystery organization, the American Mustang Foundation. The document represented over two years of “collaboration” with livestock industry and organizations representing public lands ranching. (it is important to remember that many organizations are made up of many of the same people, but with different websites; ie Cattlemen’s Ass’n and the Public Lands Council.)

This BLM Report in 2018 (for the 2019 budget) was a first run for the BLM proposed plans that incorporate these entities. It came in a year of continuing resolutions on the budget that created chaos, in every aspect of the federal government. (All those “shutdowns” you saw in the news had funding going out in small pieces and a destabilizing effect on oversight as projects were approved hand-over-fist.)

This next run at the budget is being seen as a last run at getting the fast track to legislative changes through Appropriations (funding bill, ala the Burns Amendment), before a challenge to the leadership of the Senate in the next election, by many in Congress. This is important to understand. If you thought regular Appropriations time was chaotic with all the misleading claims and roller coaster emotions, this one will be worse.

We have recently had some changes to BLM policy that represent some of the changes needed in the framework to move this “proposal of the alliance” forward. Space in holding is being created with the new subsidy (the $1,000 to adopters), BLM has gone back to the old sales policy (the one that allowed 24 at a time was no longer needed as BLM cleared out a record number of wild horses from holding to make room for the next roundup schedule) and the time to protest a decision has been shortened to 14 days (the public reasoning from BLM is that wild horse advocacy organizations do not participate in it anyway. WHE does. But it also shortens the time between signing a decision on a new roundup EA and beginning the actual roundup. (Read more here)

If you are going to roundup 20,000 in 2020 (the fiscal year begins in October) you need the space and the ability to move your paperwork fast.

If you read the BLM Report and the “Ten Years to AML” you can begin to see the change in verbiage, but the meanings are identical. The justifications are identical. The BLM report even sites the support of HSUS et al. (remember the new report will be out in about 30 days)

The BLM report of 2018 outlines 4 options. Option IV takes the longest to achieve the “national AML” that has barely budged since 1975 and is corrupted, inaccurate and created to satisfy politics, not the reality of what the range looked like in 1975. (more here)


This is the option that outlines the “plan” that takes the longest to reach AML that would imply the use of the “least aggressive” tactics planned

If you read “Option 4” above you can see the direction of the “ask” to Congress. Many readers will recognize language repeated at the “Summit of the Wild Horse” that excluded any nationally recognized wild horse organization in attendance.

You can chose any of the options in the BLM report to see how the two “agendas” meet. Other options use a bit more fertility control drugs, but the gist is essentially the same. We chose 4 because “sterilization” can not be missed, glossed over or minimized. Click HERE

However, the groups that created the “Ten Years to AML” had already begun meeting with the people in attendance at the “summit” in private, back in 2016. (website here)

There are public relations, talking point sheets, being circulated by the “advocacy” organizations that created the “Ten Years to AML” document, utilized in the 2018 report, that at no time do they support, or even suggest, sterilization. (This is an easy to understand example of their hypocrisy and outright fabrications. Another is that they are “fighting for your voice in NEPA.”)


From the HSUS, ASPCA, Return to Freedom, American Mustang Foundation document. Please note that none of the “advocate groups” ever litigated or legally challenged inhumane treatment at roundups. To date WHE is the only organization to ever do that. As a matter of record HSUS has a “humane spaying” trial run on deer

BLM sites inclusion of  the “Summit of the Wild Horse”


… and it sites inclusion with HSUS, ASPCA, Return to Freedom


PLEASE remember that all of this occurred as some of the “advocate” orgs listed were using objections to BLM stating they are removing to “AML,” or near AML, as fundraising platforms even after this document was created (and during creation that began in earnest in 2016).

Just because you see it in a mailer or a meme on social media, it does not mean that is what they are advocating for in private meetings. Please note that “reaching the national AML of less than 27,000 wild horses” is the first, second and final objective of all of the participants listed, in any draft or final document.

However the report gives us important information to stop it

The BLM will need changes to legal authorities. Some of the authorities require that the Act be amended through the Appropriations process (ala Conrad Burns).


If you read the changes to “authority” you can see that the $1,00 a horse subsidy to adopters really is a fast track slaughter subsidy. BLM wants to change title transfer on adoptions to 6 months (turning the wild horse into a domestic under law). up the limits someone can adopt, send wild horses out of the country. 

It also asks for direct authority to create entirely non-reproducing herds. This was a central theme in the article we recently wrote about Idaho. In addition this allows permittees that have public land grazing allotments to have all the wild horses in the HMA taken, sterilized and then called an “eco-sanctuary” and get paid each year by the tax-payer (sound familiar?). 

One of the Biggest Danger Zones is actually not associated with the “slaughter word”

BLM has no real data on wild horses in any plan for managing a herd to protect and preserve the wild horses and the resources they need. The BLM handbook states each herd is to have a “Herd Management Area Plan,” or HMAP. We have only a handful of these in the entire country. The concept behind the HMAP is that the herd would have concentrated data with management objectives (including forage, water, preservation for the herd). Then a roundup EA would tier to the HMAP. This would make a roundup EA fast and efficient to complete.

BLM, as usual, created paper that had no meaning and no follow through. BLM should be mandated to create preservation plans, HMAPs. Instead they are asking to shirk their entire responsibility to the intention of law, the 1971 Act.

Now BLM wants to skirt the NEPA process. Essentially they want to be able to tier a roundup EA to an AML in a land use plan. The number of horses rises above the AML and they can simply create a Categorical Exclusion, sign it and begin. (This is typical of how lazy and whiny BLM becomes when they actually need to do work.)

This is part of a larger effort by BLM under Brian Steed, former Chief of Staff of Chris Stewart (R-Ut), the Deputy Director of BLM with authority given to him by Ryan Zinke of Director (a likely illegal move).

 This is what the opposition wants at the heart of all public land issues; a closed door system where they control public resources; fast authority to decide anything without much more than three pages and a signature. For wild horses that means any roundup, sterilized herds, or to kill them. (BLM has always been a rancher coopted agency. However, beginning in 2014, they were under intense intimidation and threat. They like this easy card in the political poker game to satisfy the table; wild horses have always been a weak link in land management and it has always “quelled the fire.” READ HERE)

Three of the Department of Interior (DOI) thugs leading this move are: Brian Steed, Zinke (and Bernhardt), John Ruhs (a “must read”)


Attacking your right to be involved, and their responsibility to analyze and justify their actions, is at the heart of all they are proposing. 

The BLM left YOU out. These “organizations” lied and left YOU in the dark on their meetings and negotiations. 

WE HOPE you understand what all of this means. Reality will look like this: A BLM manager will get a call from a permittee or the state office. They will chat about “too many horses.” They will decide that more than half the horses need sterilization (we will see gelding first) or more than two thirds removed and a third “euthanized” because they deem them “unadoptable.” Paper will be drafted, signed and they will begin.

No more “comments on a roundup EA,” because there wont be one. It will tier directly to a land use plan. The court wont rule in the favor of a “horse voice” because Congress will have decided the action is the legal process and amended the Act itself.

Are you understanding now? Too often “wild horse advocate organization heads” come from the world of domestic horses or multi species rights groups. They do not know public land management or law. So often we see outrage or protests over an EA. Then after the protest they tell you what the EA said in the first place; made the public look “ill-informed,” ignored land use planning, and the public gets cut out of the process…. and the process itself is gutted.

We can fight back!

The new report will hit in about 30 days. It will incorporate a document that has Farm Bureau, Cattlemen’s Association, HSUS, ASPCA, Return to Freedom, American Mustang Foundation (whoever they are?) as collaborators. The document noted in the press releases, sent by the named entities, interestingly does not name all of the organizations on their respective press releases. If they are so proud of the relationship, why are they not “hand holding” in public?

This “unholy alliance” is perhaps the largest threat to the intention of the 1971 Act in history. 

You can sign up below to make sure you receive our action item when the new BLM report drops. A report from private entities is not exactly “legally actionable” in this case. But activities by federal employees are. The BLM report can be a launch pad for multiple actions. 

If you want to make a call now? Take the action we have listed at the bottom of the context article (HERE)

Read, learn and be careful what you support in these very dangerous times.


We are up against a very well funded machine. Can you help us continue to fight back? 


Categories: Wild Horse Education