Advisory Board Written Comments due Sept 9

The BLM Wild Horse and Burro Advisory Board will meet (virtually) September 23-24. Registration to speak is now closed, but you can still write to them.

Some background and a few questions answered, here.

If you are submitting written comments the board wants them 2 weeks prior to the meeting; before you hear the board speak. This would make written comments due this week, Sept. 9.

From BLM Press Release:”Speakers and those who cannot attend the virtual meeting can also submit a written copy of their comments to whbadvisoryboard@blm.gov at least two weeks prior to the meeting. Please include “Advisory Board Comment” in the subject line of the e-mail.”

 As with any board, they ask that comments stay relevant to the agenda (HERE). The agenda is rather broad and vague. It includes the BLM report to Congress making just about any subject you want to discuss a relevant one.

If you write comments you can amend them, after actually hearing the board, by sending a second email noting the date of your first comment letter.

We have been getting requests for a sample letter.

A WHE volunteer created a bit of a boilerplate letter that you can use. You can pick one or two subjects and expand on them, or you can copy and paste what you like. Send them to: whbadvisoryboard@blm.gov

Members of the Advisory Board,

I support a multi-use public lands policy that is driven by science, not special interests, one that is actually based on rigorous management practice, and truly recognizes the right of wild horses and burros to occupy their fair share of our public land along with other special interests.  

Please recommend that the BLM:

Require robust Herd Management Area Plan (HMAP) development for all HMAs that lack such a plan, to be completed by this time next year.  Any HMA without a rigorous data-driven HMAP should be barred from implementing any additional removals, fertility control programs or sterilization regimes.  BLM needs an incentive to abide by the basic mandate of actual management. Management is not possible without a site-by-site plan. The public has essentially been held to only commenting on pre-determined population control (roundups, fertility control) and any comments that address any factor prior to those proposed actions is considered “not appropriate.” This lack of basic planning increases on-range issues and contention. Without a basic HMAP even retreatment of fertility control will be random, at best.

NOTE: This fundamental step is woefully lacking and is the prime reason that the National Academy of Sciences has, since roughly 1982 faulted the BLM for ad hoc, unscientific management practice where wild horses and burro management is concerned. Crafting HMAPs would begin to rectify core issues, instead of a continuation of the status quo that throws vast sums of money addressing (and hiding) the symptoms of the decades long neglect addressing  core issues. 

Many areas that the public has expressed extreme frustration with are all subjects BLM avoids addressing through HMAP creation; including, but not limited to: 

The unscientific  Appropriate Management Levels (AML) for wild horses that the National Academy of Sciences (NAS) has stated are not representative of anything resembling science. Having a “national AML” is an absurdity that demonstrates the politics of the 70’s, not science. The number represents nearly the same number found “fast disappearing” that spurred the passage of the 1971 Act; any other species, if the number was actually set by lawmakers influenced by integrity and not politics, we would have a recovery number of 3-4 times the number that spurred an act of Congress. A rigorous HMAP would begin to address this deficit.

Evaluate options for reduced (or non-use) of grazing permits in Herd Management Areas (HMA). CFR 4710.5, which allows BLM to reduce or eliminate livestock grazing in order to provide habitat and protection for wild horses and burros, is a subject that must be addressed area by area through the HMAP and LUP process (Land Use Plan). Currently the majority of standing LUPs are way past an expiration date, and the HMAPs do not exist to rectify that deficit, denying any actual appropriate public process.

The standing excuse for the low AMLs is a “lack of feed and water.” The forage allocation, in truth, is not represented in any underlying mathematical equation for AML (again, noted by the NAS since the 1980’s). Only about 12% of public lands were set aside for use by wild horses and burros; inside that area wild horses and burros are allocated a marginal average of 14%. This is not representative of an allocation intended to preserve a public resource. Our wild horses and burros are a public resource, not a permitted private profit use, and the law demands protection of that public resource. A rigorous HMAP would begin to address this deficit. 

Fire fuels reduction has become a subject of interest. Grazing schemes are being developed for domestic livestock, yet any adjustments to AML for wild horses related to fire fuels remains unaddressed in HMAs, increasing contention. A rigorous HMAP would address this deficit. 

Repatriation of wild horses and burros to Herd Areas (HA) that have been “zeroed out,” reducing holding costs. BLM has always had the authority to achieve this simple, and logical, goal. Many areas were “zeroed out” that never had an HMAP that would set a trigger for evaluation for repatriation. Requiring BLM to include HAs in the HMAP process would address this deficit. 

Drop all plans to surgically sterilize wild mares and/or stallions, either as a management tool or in connection with a research project due to the inhumane nature of such procedures. Not only are these actions (on paper) unjustified without a rigorous HMAP, BLM has never analyzed and incorporated such actions into the Comprehensive Animal Welfare Policy (CAWP). The entire review and revision process for CAWP has been neglected. 

Please recommend BLM begin to publish annual reviews of the CAWP policy to allow appropriate public participation to gain compliance with this basic mandate. The BLM has failed to appropriately review the CAWP policy itself since the inclusion of the policy into roundup contracts in 2015. It took 5 years of relentless litigation by Wild Horse Education (WHE) to get the policy included into underlying NEPA documents. In the 5 years since the inclusion: BLM has failed to publish annual reviews, failed to appropriately train COR, issue citations, update the policy based on review, etc. It is an absurdity that it appears BLM is saying to WHE that you need to litigate again to obtain compliance. 

Suspend and terminate the ill-conceived Adoption Incentive Program (AIP).  Not only is this program a fiscally irresponsible use of taxpayer dollars since it diverts funds from core issues such as range monitoring, habitat preservation, and stopping domestic livestock trespass, but also, as originally predicted, a rapidly increasing number of newly titled BLM  mustangs have been observed arriving in kill pens within weeks of title transfer and the second BLM ‘reward payment.”  It is not a pathway forward, but proving to be a pathway to slaughter. If the goal is to protect wild horses, not just clear pens to run a massive roundup machine without concern for the fate of the wild horse, BLM should be required to use the funding to increase compliance checks and begin a program to establish compliance with the “I wont sell to slaughter” condition of the sale program. 

The Advisory Board should focus their attention on recommendations that address the BLM failures to carry out the basic mandates of humane management. Humane management is not just about helicopter roundups, it begins with actual on-range planning, the HMAP.

BLM has multiple “tools in the toolbox” to accomplish the mandate. The most critical tool, management planning, is repeatedly overlooked to satisfy multiple special interest groups and fuel sensationalism. If we do not do whatever some profit driven interest wants, we will need to kill horses. This type of thinking is sensationalistic, a political agenda and a bully tactic. We urge the board to begin to reject this (childish) manipulation tactic and move the BLM toward efficient and responsible management according to the mandate of law. 

The American public overwhelmingly supports humane and sustainable on-range management for our iconic wild horse and burro populations on public land — this has been the case consistently since the 1971 act was unanimously passed by the U.S. Congress.  It is high-time the people’s will, as embodied in this milestone legislation, is truly recognized and, further, that the BLM’s multi-use charter is ethically and scientifically managed.  Only then will the public’s long-standing desire to affirm and recognize the intrinsic value of these noble animals and the critical role they played in building our nation be realized .  These thoughts ought to drive each and every recommendation of the National Advisory Board.


your name and contact.


WHE has been offered a match to help us continue our fight! All contributions will be matched up to 3K until September 16th! You can double up the fuel for our fight and we will send you an advance copy of WHE Wild Words (our digital magazine) in both a link to view as a digital magazine and a printable/viewable pdf file.