Wild Horse Education

Haaland Confirmed and Action: The Next Level

With a vote of  51-40 as the Senate adjourned, Debra Haaland has become the first native American to serve as the Secretary of Interior of the United States. Haaland is a strong voice for the environment and committed to the agenda to bring science based management decisions and conserve our American public lands. 
With her confirmation completed, we will work hard to create an understanding that the deep reform needed in the Department of Interior includes reform to protect our wild horses and burros.
There will be a real hard road with a Congress so divided on environmental issues.
Our wild horses can not get left behind.

We have a fast “click and send” letter HERE to help push for transparency and a hearing on the Wild Horse and Burro program. 

Your legislators get thousands of click and send letters and have a tendency to simply categorize them, instead of really reading each point you address. The click and send can help show interest in an issue that we can then use as we interact to educate lawmakers.

Taking the time to print and send a letter, or craft an individual email, can help you begin to create a more personal relationship with your lawmakers to better educate them. 

Below we have added parts of letters WHE volunteers have written to their lawmakers. We present them as reference for you if you do not know how to start your own letter. You can take a paragraph or two and start your own! 

You can find your representatives and their contact info here: http://govtrack.us

You can also use the letter to begin to pen one to the new Secretary of Interior (address HERE).

This wonderful young wild stallion has just gotten himself his first mares. He lives on a range where there is no management plan and the land he stands on is being given away to industry fast.

These letters may seem long, but this is your chance to speak to your reps. Your reps are supposed to represent you. When you write to them, it is your chance to speak your preference and educate your legislators. 

If you have gotten a reply from one of your reps after a “click and send” that implies support, but vague, you can send a follow up. This volunteer followed their letter with a request for a meeting. You can do that as well. 

An example below:

Dear Senator,

Thanks for your reply regarding the protection of wild horses and burros.  I am encouraged by your recognition that these animals are “an iconic part of the Western landscape,” an important observation.  As we move forward with the 117 Congress, I ask that you consider the following points as you work to ensure “environmental protections based on the best science available are in place to protect and responsibly manage wild horse and burros.”  Also, please note that I am willing and able to support any statement I make in the following summary with fact and hard data — at your request.

Your support for “legislation to reform BLM’s management of wild horses and burros to ensure that their range provides abundant forage and water for all wildlife” must certainly acknowledge the need for systematic data-driven planning, something that the BLM has consistently failed to do, presenting reports to Congress such as their most current plan (the BLM Report) of May 8, 2020, that is most certainly not based on rigorous scientific planning. Of the 177 HMAs currently designated for wild horses and burros, only 7 have a fully developed HMAP, the robust planning document required by BLM’s own handbook to manage these herds and assess the carrying capacity of each specific HMA (I should mention that BLM often represents a “gather EA” as an HMAP, a misleading tactic that aims to substitute a much more narrowly-scoped document for the more comprehensive HMAP).  Instead you are presented with a document that is a collection of claims and assertions, unsupported, as near as I can tell, by any recognizable scientific data and intended to create the appearance of a planning document.  Perhaps the BLM is hoping, as they did with the national monuments report, Congress simply won’t ask any hard questions.  It is my hope you will scrutinize the May 8, 2020 document with the same rigor and enthusiasm with which you examined the misleading, falsehood-ridden national monuments document presented to the Energy and Natural Resources Committee. The May 8th report was, as I’m sure you know, created in the same timeframe by the same people that created the national monuments report and is of similar character.

AML is the keystone of the May 8 report.  And yet, what is the analytical basis for an AML of 27,000?  This is exactly the position that the NAS report noted time and again, stating in the 2013 findings, “On the basis of the information provided to the committee, the statistics on the national population size cannot be considered scientifically rigorous” and again, “Input parameters used in the WinEquus model are not transparent, and it is unclear whether or how results are used in management decisions.”  In typical BLM fashion, we are asked to accept a number that appears to be little more than a swag — how they arrived at the number is anyone’s guess.   And, Senator , without a rigorous HMAP planning process, how can these numbers be accurate?

Wild horses and burros are routinely scapegoated for habitat destruction, — in spite of the fact that only about 12% of public lands were set aside for wild horses and burros and, inside that area, they are allocated a marginal average of 14%, — in spite of the fact that on about 251 million acres of public land, there are over 2 million cattle as compared to about 57,000 wild horses, — in spite of the fact that when “researchers and conservation groups study overgrazing, rangeland health, and climate change, they study the impact of cattle, not wild horses and burros” who are only mentioned among other wildlife, in a relatively minor way.

The Adoption Incentive Program (AIP) implemented by BLM in 2019 to reduce the number of wild mustangs in holding, even as BLM ramps up removals in accordance with its 10 year “plan” has, in fact, resulted in an aid to “kill buyers” who profit from a slaughter pipeline that is not supported by the majority of Americans. 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 domestic livestock trespass (the kinds of issues that might be addressed in a real HMAP), but, as originally predicted, an increasing number of newly titled BLM mustangs turn up in kill pens within weeks of title transfer, after slaughter profiteers take title, collect the second $500 for a total of $1000 dollars for a phony adoption, and layer-on the going price-per-pound at auction. 

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 lawful right of wild horses and burros to occupy their fair share of our public land along with other interests such as extraction, animal agriculture, and hunting.  But in my judgement, we are a long way from that desirable circumstance, and are instead, stuck in a dishonest and interminable shell game for power over public lands.  Meanwhile, the animals and the habitat suffer.

I implore you, in your effort to “support legislation that strengthens the nation’s economy, while ensuring environmental protections based on the best science available are in place to protect and responsibly manage wild horses and burros” to pursue the truth in the face of powerful lobbies and personal interests, because, in the end, as honest stewards, we owe it to the animals and the environment to do the right thing based on the facts, based on the science.  Senator, I don’t expect anyone to feel the same way I do about wild horses and burros, but I do expect rigorous and fair management based on the rule of law and, where the Wild Horse and Burro Program is concerned I believe, regardless of political party, that is true for the majority of Americans.

Swasey, 2020

Another volunteer, Pam Chandler, simply began her process with a personal letter and then the request for a meeting. The letter goes to both Senate and House. We think she did a great job.

This year, the year of the 50th Anniversary of the Wild Free-Roaming Horses and Burros Act, the Bureau of Land Management (BLM) continues to implement the Wild Horse and Burro program that is fiscally irresponsible to the taxpayer and morally bankrupt to the public interest they serve. The BLM program continues to operate without actual management planning for each wild herd, as evident in their 2020 Report to Congress, and without true oversight or accountability.

I urge you to request a full hearing in the House Natural Resources Committee on the validity of the 2020 BLM Report to Congress prior to funding being determined for fiscal year 2022 for the Wild Horse and Burro program. Additional funding to the BLM program must be held until a new report is crafted. Funding for “gathers” need to be restricted to areas that have the required Herd Management Area Plans that are less than 10 years old and where the data reflects current conditions and management tool. The new BLM report must also ensure the principles identified in President Biden’s Memorandum on Restoring Scientific Integrity and Evidence-Based Policymaking of January 27, 2021 (The Presidential Memorandum) will be carried out.

In 1971 the Wild Free Roaming Horses and Burros Act (WFRH&B Act) was passed unanimously by Congress. “It is the policy of Congress that wild free-roaming horses and burros are shall be protected from capture, branding, harassment, or death; and to accomplish this they are to be considered in the area where presently found as, as an integral part of the natural system of the public lands.” 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 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. The deep flaws in the Wild Horse and Burro program must be addressed and rectified. The 2020 BLM report to Congress does nothing to restore public confidence and trust in the BLM program.

Our wild horse and burros are part of the system of public land. They are to be managed as a public lands resource governed under public lands law to be preserved and protected for future generations. That is the law. The American public expects fair and balanced management where wild horses and burros are considered comparable with other users of public lands. Where does the BLM report to Congress show this? The fair share of resources must be allotted within each herd area to sustain the viability of the user (wild horses & burros) under law. Where in the BLM report is this explained in detail, that includes the taking of pubic lands in Herd Management Areas with no compensation for wild horses, by livestock and extractive industries?

The report’s “analysis” speaks of harm to western landscapes, disturbing impacts to lands throughout the west and the need to reverse declining rangeland conditions on portions of 25 million acres of public land occupied by wild horses and burros. WHERE is the analysis of, according to the BLM web site, the livestock grazing on 155 million acres of public lands. In Nevada alone the public lands authorized for grazing in, according to the BLM, is 43 million acres. WHERE is the analysis of the damage done by livestock including trepass livestock.

The determination of Appropriate Management Levels (AML) should take place as part of comprehensive planning (Herd Management Area Plans) based on monitoring and evaluation yet the BLM states in their report that resource monitoring expenditures within the program are relatively small. The BLM report goes on to state that accurate and repeatable population surveys are vital to inform the BLM of herd size and to evaluate the outcomes of management actions and attempts to survey each HMA every 3 years, but this is not always possible. How can the BLM evaluate the outcome of management actions without following an actual management plan? If the BLM must start with accurate and current population estimates, as stated in their report, and which is a part of a HMAP that they have not done how can justify any removals? Where are their HMAP documents and data to justify their decisions of AMLs? Very few HMAPs had been completed, why?

All BLM data on the Wild Horse and Burro program should be readily available to the public for transparency and to improve public trust without the necessity of completing a FOIA request as is often the case. Will data that has been deleted, or stricken from public records, be restored?

Order NO 3397 on March 3, 2021 by Scott A. de la Vega Acting Secretary of the Interior stated; This Order seeks to ensure that the Department remains a leader in scientific integrity, but the BLM report does not lie in any effort to create a scientific, data rich, report to Congress. It is not comprehensive and does not supply justifications for its demands or build on the sound scientific recommendations of the National Academy of Science. This is not a programmatic report that provides a basis for a “plan.” Accountability to falsehoods and omissions 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.

The 2020 BLM report is a shoddy document with mathematical errors and misleading photos that fail to link to any actual range assessment to justify the claims. What is presented is a barebones report an expansion of cost breakdowns for the options listed in the old report (contracts for gelding and spaying, contracts for holding facilities, rebates for adoptions that create a greater risk of wild horses going to slaughter or landing in bad situations as seen at Sheldon USFWS) and not research into the framework of the program and how, step by step, to fix it. They list their “strategies” in the order in which BLM has continually prioritized them in the Wild Horse and Burro program. Roundups are always BLM’s first line and the framework; the required Herd Management Area Plans (HMAP) is last or ignored. BLM is not mandated to remove; they are mandated to manage. Removal, when justified, should be the last tool of management. Objectives for management, and all methods for that management, are supposed to be outlined in an HMAP and a “gather plan” is supposed to tier off a HMAP.

I beseech you to hold the agency accountable, just as Congress held the agency accountable on National Monuments with a hearing and investigation into egregious errors in the report the agency handed to Congress. Wild horses and burros in the US, and the public interest, deserve no less from our lawmakers. The Wild Horse and Burro Program has been the most neglected and maligned, and has been easily corrupted. This injustice must be remedied if the program is going to serve the intention of law and stop being a fiscal black hole for the taxpayer.

Again, I urge you to request a full hearing in the House Natural Resources Committee on the validity of the 2020 BLM Report to Congress prior to funding being determined for fiscal year 2022 for the Wild Horse and Burro program. Additional funding to the BLM program must be held until a new report is crafted. Funding for “gathers” need to be restricted to areas that have the required Herd Management Area Plans that are less than 10 years old and where the data reflects current conditions and management tool. The new BLM report must also ensure the principles identified in President Biden’s Memorandum on Restoring Scientific Integrity and Evidence-Based Policymaking of January 27, 2021 (The Presidential Memorandum) will be carried out.

You can find your representatives and their contact info here: http://govtrack.us
Time to write! Send a personal email or send a letter in the mail with a stamp.

Article with a fast “click and send” option: https://wildhorseeducation.org/2021/02/03/the-report-2022-funding-debate-and-a-request-for-hearing/

The BLM Report is where “Path Forward,” the lobby document, sits. We now have a chance to use a directive to return to science to get the old plan ditched and one based on science put in place: https://wildhorseeducation.org/2021/03/02/lets-talk-nas-reviewblm-report/

Deep reform, will it carry wild horses? https://wildhorseeducation.org/2021/03/08/will-momentum-for-reform-carry-wild-horses/


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Categories: Wild Horse Education