The Bureau of Land Management (BLM) will be funded through a continuing resolution passed through Congress and was signed by the President. The bill finances the federal government through Dec. 16 and buys lawmakers more time to agree on legislation setting spending levels for the 2023 fiscal year. The bill keeps spending at federal agencies at current levels through mid-December with a few exceptions (like aid to Ukraine).

Both the House and the Senate have adjourned after this bill was signed. The Senate is not expected to return to regular session until after the mid-term elections on November 8. All 435 seats in the House, and 35 of the 100 seats in the Senate, are up for election next month.

Now is a good time to make an appointment with your legislators in their home offices and try to explain to them the changes you want to see in the Wild Horse and Burro program. You can make an attempt to pull the discussion out of population growth suppression (roundups/fertility control) as the cause of the collapse of this system and bring it back into the realm of advocating for program reform, not window dressing or greenwashing that continues the minimization of the wild horse and burro as a part of our public lands.

You can find your House representative and Senator by using the interface on Govtrack HERE

The continuing resolution states that funding agencies will be under the same rates and conditions as the 2022 bill decrees. For the BLM Wild Horse and Burro program this continues the increased funding provided in the last bill. 

As the BLM Advisory Board meets, we felt it appropriate to do a fiscal run down.

Nutshell, BLM Fiscal 2022:

The BLM roundup schedule approved the capture of a record number of wild horses and burros: 24,126. Of that number BLM approved 2,475 for treatment/release after some for of fertility control (various vaccines, I.U.D., sterilization). This comes to about 10.25% of animals captured (a record number for fertility control). Of that number 1,558 have been treated and released to date (about 6.5%).

BLM justified these removals using (primarily) old land use plans and old inventory data. You can look at the 2021 population statistics report and compare to the 2022; much of the actual data was gained from the same survey done as early as 2005. The estimates come from “modeling,” not actual counts. Did horses die in drought, from disease, a bad winter, habitat or water source loss, shot (like in several HMAs)? Those things are not part of the equation; just a broad 20-25% increase (that only actually happens after a large-scale roundup). The average natural growth rate can be as low as 8%.

BLM (finally) began to do welfare evaluations under the Comprehensive Animal Welfare Program (CAWP). These assessments demonstrated inconsistency, inadequacy and favoritism. No recommendations or actual changes to policy have occurred since the policy (program) was formalized in 2015.

BLM has not created a single Herd Management Area Plan (HMAP-EA). Instead, the agency amped up the creation of ten-year “gather and population management” plans; attempting to guarantee that remove/fertility control is all the public will be able to address driving a decade of status-quo (unless litigation pushes it all back).

BLM has approved expansion of the “off-limits to public viewing” processing/holding facilities. These facilities have hamstrung efforts to address welfare issues. BLM added a simple “numbers sheet” to claim transparency. The portal does not include intake from the range, shipping manifests, identification numbers, vet reports, death and render reports.

BLM allowed over 1000 wild horses from the Adoption Incentive Program (AIP) to slip to slaughter. WHE has filed FOIA requests to try to track down how many slipped out through the treacherous “sales” program. BLM has been less than cooperative in releasing those statistics. (The Sales program is where nearly 1800 shipped to kill-buyer Tom Davis). In recent years the AIP (a subsidized adoption) has taken center stage as the sales program continues in the dark. In 2022, BLM promised, once again, to create better oversight. However, they are able to shirk legal responsibility once title transfers to the adopter or purchaser.

BLM began crafting a “preferred partner list” since Ten Years to AML was submitted. In 2022, BLM did not change the invitation list they began using in 2017 to stakeholder meetings and excluded a number of advocates that had been considered stakeholders (and are still actual stakeholders) from participation.

Transparency continued to be an issue: off-limits holding facilities that do not publish any updates (intake, shipping, vet reports, vaccination records, death statistics), FOIA requests going unanswered or “no records found,” multiple issues at roundups including new loopholes to allow discriminatory and selective access, and more.

BLM announced more grant funding. “This is the second year that the BLM has invited proposals for wild horse and burro projects through a new streamlined and centralized funding opportunity. Grant sizes will range from $1,000 to $7,500,000.” These grants are for holding facilities, adoption assistance, fertility control. Even though BLM says these grants include “monitoring and range improvements,” WHE has submitted (and attempted to submit) multiple proposals on a volunteer (non-paid) basis to do drought monitoring and range improvements and were rejected every time. The response usually included that they were looking for “darting” or help with population growth suppression only. If you want any additional action besides “assisting with darting,” BLM denies your application. We find all of this odd; they even drag their feet on the “darting only.”

BLM leadership continues to assure stakeholders in industry (livestock, mining, energy) that they are committed to the 2020 plan and will continue to remove wild horses and burros.

At the beginning of fiscal 2022 there were many claiming some type of “victory” and the word “reform” was used in a flurry of press releases. From our view, we stated no reform was in the package at all.

This is BLM’s published 2022 overview statement Click HERE for pdf.

Essentially you can see much of what we stated in their document, but they use different phrasing.

An example is the “access policy change” to facilitate “safety.” What we have seen on the ground is that the “safety” issue and parameters are not applied equally and those on BLMs “preferred partner” list are treated differently.

Another example: “The BLM has also released a grant opportunity to attract new public and private partners who can help expand treatments, which closes January 31, 2023.” It should be noted that WHE has been attempting to do “monitoring and range improvements” partnership with BLM through volunteerism (not grant funded) each year and are refused. BLM does not want “new partners,” they want a larger pool that will not criticize any aspect of the program that deals with range resources (you can criticize that removals are not fast enough or the AIP, nothing else)… they want partners that will go along with “remove/fertility control” only. If you want additional actions, you won’t make that stakeholder list.

General observers could see horses only after they came over a ridge and then down into a draw where the trap was located. BLM allowed another observer to see what was down in the trap; a preferred partner.

We are publishing this fast overview of fiscal 2022 as BLM runs the Wild Horse and Burro Advisory Board meeting. It should be noted that BLM picks those that will sit on that board and advocate applications are tossed aside each year. We know of several highly-qualified individuals, that have even held positions in federal land management, that have been tossed aside.

Every year we are blown away by the lack of specific understanding of the program by board members and listening to them speak; it always sounds like an extended comment period from a special interest member of the public. We hear more complaints about AUMs available for cows than we hear about any preservation of habitat for horses. In fact, you never hear about habitat fragmentation or loss in these meetings at all. This board has never represented anything but a “lower AML” and “get the horses off” board.

BLM should require an exam on law and policy, not just an application by a “buddy-system” member, before approving a seat on the board.

How many of the board members do you hear complaining that there is no long-term management plan on a site specific basis? But you hear no one even say Herd Management Area Plan (HMAP). The planning document that should be done long before a gather-EA. Why? because it might just give you, the public, a voice in management. (We have 2 federal court actions and 5 legal appeals addressing this matter. Why is the board complaining about litigation? We are just trying to get transparent site-specific planning. You don’t complain when counties or livestock permittees litigate BLM… so why complain about advocates?)

We will be publishing more info about our work in fiscal 2022 and what is ahead from BLM in fiscal 2023 soon. 

For brevity sake, we will end this by reminding you that you can download the meeting materials and presentations provided by BLM on the Advisory Board page HERE.

Note to the board: We have seen constant disrespect of the public interest in this meeting so far. At least none of you have said “it is because women got the right to vote,” as we have heard in meetings a decade ago. You have replaced that phrase with: “people east of the Mississippi.” Please… just stop. Many advocates have lived their entire lives in the West or have spent over a decade traveling HMA by HMA. Many have even undergone physical threats by your buddies. So, unless you open public comment to address you personally, STOP denigrating the advocate through the microphone afforded to you by a taxpayer funded agency.

Additional info:

We published two pieces that focus on the frame on-range, the “in the wild” part of wild horses and burros. A bit of history, the formation of the framework of advocacy for wild horses on our public lands.  You can access part 1 HERE. Part 2 focuses on regulation and policy, where we need to advocate to “keep wild horses wild” and part of why that breaks down. You can access part 2 HERE.

We did a fast foray into the BLM facility numbers HERE.

Keep us in the fight.