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Let’s Talk (NAS Review, BLM Report)

As the debate begins for reform of federal agencies, and how programs are funded, there are two documents that it will be important to keep in mind for the wild horse and burro advocate: The 2020 BLM Report to Congress and the 2013 National Academy of Sciences Review.

2020 BLM Report to Congress 

2103 National Academy of Sciences Review

Let’s Talk About Reform, The Inbox: Editorial by WHE founder Laura Leigh

Today I am toggling 3 of our active legal actions and pushing to get approved plans suspended and reviewed (certain livestock grazing decisions, spaying and roundups) that were approved under the directives of William Perry Pendley, the former BLM acting “chief” that left office after court order finally found his tenure illegal.

We also need to get the Office of the Inspector General (OIG) to review complaints that were simply handed to the person the complaint referenced to determine if they were relevant. The backlog of Freedom of Information Act (FOIA) requests must also be addressed and we are being told to refile. The avalanche of conglomerate grazing decisions, that were written under a directive to follow policy change that had not been approved yet, continue to flood the mailbox.

There is a lot to do. We are very busy.

However, people keep asking us for information on how to address their representatives and how to fight back against “Ten Years to AML,” (later retitled “Path Forward”).

Admittedly, I have written this rather rapidly.

First, Ten Years to AML is not a bill. It does not get “voted on.” It was a corporate lobby document moved through back channels just like the move to gut National Monuments. Telling your rep to “vote against Ten Years to AML or Path Forward” is going to confuse an aide you might speak to. There is no vote on it.

The corporate lobby plan (aimed at generating new subsidies for all involved) was incorporated into the BLM Reports to Congress in both 2018 and 2020.

The BLM Report to Congress of 2020 is what the Appropriations (funding) debate hinges off of. Discussing the flaws of this report, and the backdoor channels and corporate lobbyist involvement, is appropriate. By helping to discredit (and perhaps investigate) the report itself, you are shooting down “Ten Years to AML.”

If you do not have a lot of time and are looking for a “click and send?” WHE has an article describing some of the obvious flaws, and dirty deals, in the Report. We are asking you to take action to gain a hearing into the Report. (WHE is also using this information and the directives from Pendley, to get many of the misdirected EA suspended and reviewed, like the ones to sterilize wild horses). You can read more, and take action, by clicking this text. 

If you are making an appointment to have an in-depth discussion with your legislator? read on…

BLM will fence off areas where wild horses need water, fail to replace that water, add more sheep and cows and then blame wild horses for degraded waters. Even when wild horses may only be able to access a single water in an area because of mismanagement, BLM still blames the horse.

As you address the current administration “Build Back Better” is a tagline that implies reform. In order to reform something you need to identify the issues that require reform.

The National Academy of Sciences (NAS) is one of the key documents to illustrate the areas the BLM needs to reform in the Wild Horse and Burro program and is, perhaps, the easiest to understand.

The NAS has essentially been saying the same things about the core flaws in the agency since 1982. The 2013 Review is the latest iteration (at a cost of over a million dollars) that does include a few paragraphs that cover new technology (fertility control and monitoring devices), yet the core flaws remain the same. (Of note: the NAS was limited to review of only 13 points of the program and were not given latitude to review the entire program.)

There are many that are cherry picking from the NAS to highlight only the sections that forward whatever agenda they will benefit from. I have been absolutely stunned by the number of Congressional aides I have spoken to that tell me we are the only org talking about flaws in the framework of management and the NAS Review.

If we are going to achieve the desperately needed reform our wild ones need, we can not simply pull from the report to fund products, create subsidies and continue the hamster wheel. We must address the historic core flaws first, or the program will remain in collapse with just a more expensive price tag.

Release of PZP treated wild horses at Owyhee in 2016. In 2018 BLM pushed the population down to around 534 wild horses. In 2021 BLM targets 1129 for capture and the release of 173. If you use “BLM fuzzy math” that means they target every possible wild horse living in the 1.5 million acre complex for capture. Yes, BLM is using a temporary fertility control substance many are pushing for. But is it justified through the reality of the range and through the NEPA process?

There are findings in the NAS review that reference possible management tools. Those finding do not address the core flaws that cause this program to remain broken, you need to look at all the findings.

Highlighting that the NAS likes temporary fertility control as a potential tool for population suppression is correct. However, this does not fix the program, nor fix the flaws that would justify the use of any population suppression method. Yes, the NAS confirms using large scale helicopter roundups increases birth rates (BLM compounding problems for 50 years), is against surgical spaying in wild populations, likes temporary fertility control; these all address a category of population suppression. But that is not where management actually begins to create a framework where any method of population suppression becomes a compounding failure.

BLM provided Congress with about 16 pages that contain any actual specific discussion on the programs the agency runs for wild horses and burros to base funding requests upon in the 2020 report. The report does not address how they intend to use funding to repair the program and, in fact, calls much of what they do a rip-roaring success (as the program runs full steam into collapse).

Compare with:

The NAS review is over 400 pages. Even though they were limited to only analyzing 13 points, the NAS review is actually a report on the program. The NAS does more than simply advise BLM to use temporary fertility control agents and oppose surgical sterilization. (WHE was the first to file against the “spay plan” at Confusion prior to the deadline expiring on October 28. We oppose spaying. However, the process that includes spaying includes so many damning factors.)

These are the two documents Congress needs to compare as “government funded and official.” The BLM must create a report that outlines how they are going to address the flaws in the program as outlined in the NAS review. We are actually hitting the mark where another NAS review will be commissioned by the BLM, another million dollar plus bill to the taxpayer, where the NAS will repeat the same key flaws of BLM and essentially label BLM a failure on fiscal responsibility and responsibility to protect the public resource (wild horses and burros).

Orphan pen after the 2018 Owyhee roundup. Many of them did not make it. Another roundup is planned in 2021 after massive livestock deals have been made based primarily on policies that were never approved, just directives from the revolving door of Deputy Directors that ran the range over the last 4 years (John Ruhs, Brian Steed, Pendley).

Each key finding can be delved into in depth. The NAS has been addressing these key findings in one manner or another for 40 years. A list of the key findings of the 2013 NAS review are listed at the bottom of this page.

There may be a finding that makes you uncomfortable. Instead of dismissing the finding, it is important to understand why that was derived at. Often, the NAS will note insufficient or obscure data and then base a “finding” on what BLM provided them to review, noting the limitations.

Those limitations are key to any method, mode or plan that claims to be created to reform the program. The limitations are largely tied to the fact that BLM controls the scope of any “hard look” at the program and that actual data looks more like justification, not science.

A good place to start for those of you wanting to take a deep dive with your reps? Remember to be specific about what you are addressing and what you are asking for. Try to keep calls limited to a specific part of process. (understanding action items, 3 branches of government)

When you chat with your legislators about Appropriations bills, where BLM is asking for funding, comparing the BLM Report of 2020 and the litany of NAS Reviews is a good place to establish your credibility as you address your feelings of being betrayed by an agency that holds your public lands, and wild horses in trust for all Americans. When you express your disgust that the agency bases decisions more on local political pressure than science, use the NAS to back you up. You can then use the comparison to the BLM 2020 Report and the fact that it is simply used to to ask for funding of a political agenda and is essentially devoid of substance.

When we are talking about full reform we are talking about more than a funding bill. The funding bill is one avenue the public can to help “put the breaks on.” Full reform includes more than funding the wild horse and burro program (that is used primarily as a political placation tool).

When we are talking about reform we have to begin by addressing the flaws in the Federal Land Policy and Management Act (FLPMA), and other underlying factors, that keep the BLM an agency that is vulnerable to political highjack. Prioritizing industry and repeatedly failing to address protections for all of our public resources (wild horses and burros are a public resource) is actually built into the agency.

When we talk reform, we also need to address accountability and the failures of oversight. We must have complete and transparent review of actions by the Office of the Inspector General that simply handed investigations to the agency and failed to hold individuals accountable. Decisions made through backdoor deals are causing, and will cause more, irreversible damage to public trust and the environment. Decisions (like spaying) must be suspended and reviewed.

Reform requires many avenues, a lot of work, yet is vital for all of our wild places and wild things.

However, we must make it clear to Congress that we refuse to throw more money at the BLM wild horse and burro program until we have some accountability and an actual plan to ensure we are not simply continuing to foot the bill for a status quo program that has failed every aspect of its mandate.

We have two click and send actions:

One that begins to address the upcoming spending debate HERE.

This action asks for a hearing HERE.


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As you review the findings of the NAS review, remember to look for context in the full report. (You can download the review here)

Here is the complete list of what the NAS titled “Key Findings.” You may see other notes labelled on social media as “findings.” What those usually represent is a sentence pulled from one of the categories, not what the NAS labelled a “key finding.”

We added a sentence within parentheses is either contained in NAS review, listed under each key finding, or a paraphrase of multiple sentences.

FINDING: Management of free-ranging horses and burros is not based on rigorous population-monitoring procedures. (The committee concluded that many methodological flaws identified in previous reviews of the program have persisted.)

FINDING: On the basis of the information provided to the committee, the statistics on the national population size cannot be considered scientifically rigorous. (The links between the statistics on the national population size and actual population surveys, which are the foundational data of all estimates, are obscure.)

FINDING: Horse populations are (probably) growing at 15-20 percent a year (not 25% percent and based on the flawed data BLM provided).

FINDING: Management practices are facilitating high horse population growth rates. (Free-ranging horse populations are growing at high rates because their numbers are held below levels affected by food limitation and density dependence. In other words, AML is not based on “what the land can sustain.”)

FINDING: The primary way that equid populations self-limit is through increased competition for forage at higher densities, which results in smaller quantities of forage available per animal, poorer body condition, and decreased natality and survival. (Density dependence, due to food limitation, will reduce population growth rates in equids and other large herbivores through reduced fecundity and survival.)

FINDING: Predation will not typically control population growth rates of free-ranging horses (because of an absence of a thriving population of predators as they are killed off regularly).

FINDING: The most promising fertility-control methods for application to free-ranging horses or burros are porcine zona pellucida (PZP) vaccines, GonaCon™ vaccine, and chemical vasectomy. (No method that does not affect physiology or behavior has been developed. The most appropriate comparison in assessing the effects of any fertility-control method is with gathering. That is, to what extent does the prospective method affect health, herd structure, and the expression of natural behaviors compared with the effects of gathering?)

FINDING: Management of equids as a metapopulation is necessary for the long-term genetic health of horses and burros at the HMA or HMA-complex level. (The committee also recommends that BLM consider at least some animals on different HMAs as a single population and use the principles of metapopulation theory to direct management activities that attain and maintain the level of genetic diversity needed for continued survival, reproduction, and adaptation to changing environmental conditions.)

FINDING: Phenotypic data have not been recorded and integrated into genetic management of free-ranging populations. Recording the occurrence of diseases and clinical signs and the ages and sexes of the affected animals would allow BLM to monitor the distribution and prevalence of genetic conditions that have direct effects on population health. (Basically BLM is devoid of useful data that could be used to protect the herd. At Fish Creek there was a plan to address the deficits in genetic analysis but BLM has essentially destroyed that framework primarily at the behest of livestock.)

FINDING: Input parameters used in the WinEquus model are not transparent, and it is unclear whether or how results are used in management decisions. (…. it was difficult to determine whether results were used to make management decisions or were offered as justification for management decisions that were made independently of modeling results. )

FINDING: A more comprehensive model or suite of models could help BLM to address and adapt to challenges related to management of horses and burros on the range, management of animals in holding facilities, and program costs. (Such a framework would simulate life history, social behavior, mating system, genetics, forage limitation, use of habitat, climate variation, and effects of alternative management actions throughout horse or burro life spans.)

FINDING: The Wild Horses and Burros Management Handbook lacks the specificity necessary to guide managers adequately in establishing and adjusting appropriate management levels. (The handbook lacks clear protocols for evaluating habitat components other than forage availability. Without clear protocols specific enough to ensure repeatability, the monitoring organization cannot determine whether observed change is due to changes in condition or to changes in methods.)

FINDING: The handbook does not clarify the vague legal definitions related to implementing and assessing management strategies for free-ranging equids. (. The approach would involve the development of a conceptual model for ecosystem functioning relative to management objectives and of indicators to measure the degree of departure from a scientifically informed conceptual model of an “appropriately” functioning free-ranging equid ecosystem.)

FINDING: How AMLs are established, monitored, and adjusted is not transparent to stakeholders, supported by scientific information, or amenable to adaptation with new information and environmental and social change. (Maximizing long-term knowledge of the system and thereby improving management hinge on several fundamental tenets of research and monitoring design, including the use of controls and replication and controlling for variability over time. Uncertainty should be explicitly incorporated into estimated measures (such as herd size or utilization rate on an HMA).

FINDING: Resolving conflicts with polarized values and opinions regarding land management rests on the principles of transparency and community-based public participation and engagement in decision-making. Decisions of scientific content will have greater support if they are reached through collaborative, broadly based, integrated, and iterative analytic-deliberative processes that involve both the agency and the public

FINDING: Tools already exist for BLM to use in addressing challenges faced by its Wild Horse and Burro Program. (The continuation of “business-as-usual” practices will be expensive and unproductive for BLM.)

 

 

 

 

 

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