A post by request: Fast note from the road about the 2022 BLM stats report

It is unfortunate that when Congress, public and media hear a statement about the “2022 population statistics report” they don’t actually look at the report.

The report is dated 2022, but most of the stats noted in the Bureau of Land Management (BLM) report are not 2022 stats. It is a misconception to believe those numbers represent an accurate portrayal of “now.”

Take a fast look at the BLM 2022 Population Statistics report (download here). Many people just see numbers and context is hard to visualize.

We took a fast walk through the report when it was first released and did a paper (including historical context) of what you see on their basic spreadsheet. (You can see our paper HERE that we published in May as a reference for you as you navigate your own interaction with your legislators.)

One of the first things you see is the total acreage of Herd Areas (no longer managed, but designated for use) and the Herd Management Areas (where wild horses and burros are currently managed). You can compare acreage on a state-by-state basis, we did in our paper.

Population breakdown and the myth of “82,384” on the range in 2022.

When you look at population count the month and number in the column is not a “month and day,” it represents the month and year. The data can be as old as 2006 on the population survey (count) and “date of AML” does not mean “analyzed in a herd management plan” on that date. Date of AML 99.9% of the time simply means “reaffirmed,” or carried over, in the land use plan of a district that sets goals for things like mining and livestock (then mining and livestock get their own individual management plan; wild horses get removal plans). (AML: Appropriate Management Level, or the number BLM says the land can sustain, usually set in the late 1970s or 1980s and carried forward.)

Many of the areas have had removals since the last population survey.

How can that number be considered “accurate” to base funding requests for more removals on? How can any journalist worth their salt continually use that number as a central question for debate, without first looking at what the number actually represents?

There is no appendix that shows how the agency calculated the estimated “82,384” wild horses and burros that the media simply obediently repeats without any caveat that states “the agency asserts” there are this many. Congress as well… just parrot the number without asking how they arrived at that number and fund another year of excessive removals.

We were asked by one of our readers to bullet point one section in our paper into an article for fast reference:

Important points to note about the FY 2022 Statistics Report:

• Some of the population survey data used to compile BLM FY2022 estimates includes HMAs where the last population count was done as early as 2005 and 2010.
• Several of these areas have experienced removal operations since the last population count.
• 4 HMAs have an AML of “0.”
• 44 HMAs have an AML of 25 animals or less. 146 HMAs have AML set lower than 150. Only 30 HMAs have an AML set at over 150 wild horses, burros, or a combination of the two.
• Only 3 HMAs allow for a large population of over 500; the largest being 612. Calculations being used by the BLM to continue the increase of funding to facilitate the continuing escalation of removals cite a percentage measure representing a nationwide overpopulation.
• These assertions using percentages are severely skewed by inclusion of HMAs that have an existing horse population, yet have an AML of zero (0). Example: GOLDFIELD NV is listed with an AML of 0, and 246 horses estimated to exist in the area creating a 24600% over AML stat that is included in the national estimate denoting a percentage of wild horses and burros “over AML.”
• The manner in which AML was set, the number of times oversight reports have determined the severely flawed methodology for determining AML, and the lack of actual management planning (HMAP), should exclude AML from being the impetus for increases in funding to drive toward that figure.

In fiscal 2022 the removal target is 20,523; capture target is 23,141. The release target is 2,299 of wild mares given two doses of GonaCon in a 30-45 day period (a dose with a high probability of permanent sterilization, particularly in the “over ten” preferred mare).

Please remember: fiscal 2022 ends October 1. The numbers we are talking about mean “by October 1.”

BLM is still using the numbers from the May 2022 report to ask Congress for funding… without ever providing site-by-site management plans to provide transparent stakeholder engagement on forage allocations, stocking levels, range improvement; essentially any real management goal is simply set by a number agreed to in the 70s and 80s without any actual equation being made public (or real public engagement).

The agency is mandated to manage, not remove. AML (or the number BLM says the land can sustain) is not justification for removal; affirmed by the courts and even argued in briefs written by DoJ attorneys in defense of BLM. “AML” is not a reason for removal. Multiple factors must exist before a determination of excess can be made. However, when the agency gives Congress a report, it is usually just a few pages long focused on numbers… and Congress “writes a new check.” No wonder there is so little accountability to the taxpayer.

So… if you are at a trap and the media shows up (and asks about the 82,000 horses on public lands) remember to tell them to actually look at the statistics report and note the dates? They need to start saying “The BLM asserts” and stop treating what BLM says as current “science.”

The program has been understaffed since inception and is the most data-poor program on public lands. This program was a political ball-o-fire since the day the Act passed… and everyone has been more than happy to pass the problem to the next generation instead of rocking the boat to fix it.

Our teams are running roundups, range reports and legal briefings. Back to work.

Help keep us in the fight.