Pancake, forage (the fight lives on, part 2)

When we talk about wild horses and burros on public lands one of the key subjects that arises is “availability of forage.”

One of the big questions that arises is “How can horses be starving on the same range that allocates more than 6 times the amount of forage allowed for horses/burros to domestic cows and sheep?” The ensuing debate is riddled with layers of missing data, misrepresented data and inaccurate assertions used for decades by the Bureau of Land Management (BLM) to maintain relationship with permittees.

The wild horses that live in the Pancake Complex represent an example of the mess the vast majority of wild horses in the U.S. are struggling to exist within. We present this series of articles on Pancake so you can get to know the area better as the court case moves forward and so that you can learn more about the layers of bureaucracy that lead to habitat loss, fragmentation and the scapegoating of wild horses and burros.

The first article remembers the death of the colt on the first day of the Pancake roundup, 1-year ago, and looks at how BLM record keeping is missing and manipulated… even when it comes to recording deaths during removals. (click HERE) The first article is important because of the subject matter (deaths) and because it points to the way the BLM documents, discloses and appears to manipulate information to suit an agenda. (We are working on a piece that shows how mining impacts the area without any thought to how they impact wild horses.)

This might seem like a long article, but it is worth the time to read. When talking about private livestock on public lands always keep in mind that only about 3% of meat utilized in industry comes from all of public lands livestock and that the number of people actually employed in these industries is low (example: one casino in Vegas can employ more people than the entire agriculture industry in the state of Nevada).

Trespass livestock camped out at one of the only waters available to wild horses in August in Pancake.

In a nutshell: BLM rarely does any actual rangeland health assessments, uses outdated measurements for AUM, fences wild horses and burros off of large tracts of land inside the HMAs and then obfuscates any existing information. In the vast majority of HMAs BLM allots 85% of any asserted availability of forage to domestic livestock and the leftovers are where wild horses/burros and wildlife supposedly can exist in “thriving natural ecological balance.” 

The first acronym you need to become familiar with is the term “AUM.” 

The Federal Land Policy & Management Act (FLPMA) [Sec. 4100.0-5] defines an AUM as “the amount of forage necessary for the sustenance of one cow or its equivalent for a period of 1 month.” FLPMA [Sec. 4230.8- 1(c)] states that “For purposes of calculating the fee, an animal unit month is defined as a month’s use and occupancy of range by 1 cow, bull, steer, heifer, horse, burro, mule, 5 sheep, or 5 goats over that age of 6 months at the time of entering the public lands or other lands administered by the Bureau of Land Management, by any such weaned animals regardless of age; and by such animals that will become 12 months of age during the authorized period of use. No charge shall be made for animals under 6 months of age at the time of entering the public lands or other lands administered by the Bureau of Land Management; that are the natural progeny of animals upon which fees are paid, provided they will not become 12 months of age during the authorized period of use, nor for progeny born during that period.”

Chart from report, 2008, John Carter et. al. showing the weight change of cattle. (weight has continued to rise in the 2o years since this chart was made, but the AUM allocation has not changed.

In practice, the “AUM” has slightly different definitions that all contain conflicting and/or vague definitions. The AUM system needs clarification and revision to include the increase in body weight (increased food consumption) of domestic livestock occupying the range today. (Resource: updating the Animal Unit Month, WWP,  Revised 2008, John G. Carter, PhD) An interesting observation of wild horse populations (using archival information beginning around the turn of the last century) is that the average weight of wild horses on the range has decreased. Early mustangers used to note that the “big ones” (with draft horse like characteristics) were easier to catch and were sought after for sale. That trend has seemed to continue over the last 14 years through visual observation (BLM keeps no weight data). In other words, the weight of the average cow has risen while the weight of the average mustang has dropped.

Basically, AUM translates as an outdated measure BLM uses for (monthly) forage allocation on public lands.

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The charts above represent AUMs (forage) allocated to domestic livestock in the Pancake Complex. 

When BLM releases a Gather-EA (the document they use to approve removal of wild horses or burros) they are supposed to disclose permitted uses in the same area and how removing wild horses is necessary to minimize impacts to whatever private profit uses are on the range. A Gather-EA is supposed to represent an approved action to maintain a “thriving natural ecological balance” within the “multiple use” mission of the agency. (A Gather-EA is NOT a management plan that addresses how to care for a herd, preserve enough range to ensure survival of the herd, etc. That plan would be a Herd Management Area Plan approved through an HMAP-EA; BLM has skipped this plan for the vast majority of our herds, including omitting this critical document for the HMAs of the Pancake Complex).

But, as in the case of the Pancake Gather-EA, most often they do not give you the AUMs for wild horses, but list the Appropriate Management Level (AML). This makes it difficult for you to do a fast side-by-side.  In order to get the AUM allocation for wild horses we need a bit of fast math.

Allocated wild horse AUMs: Low AML 4,332 AUMs, high AML 7,656 AUMs.

AUMs for livestock in the complex is 59,427. 

It should be noted that BLM does not give you a cumulative “available AUM” for any given range. By adding up AUMs allotted, you get the whole… not the whole number of AUMs, the year that number was determined and then a breakdown.The calculation for determining AML for wild horses is usually not disclosed in any LUP. BLM just states they “evaluated and determined.”

(note: You can use this Pancake example and apply to any wild horse Gather-EA.)

When livestock is out on the range gates are closed to keep cows inside the grazing pasture. Often, even when cows are not out, gates remain closed and wild horses cannot move throughout acreage designated for their use. (picture: Pancake, where this fence cuts off access to one of the only water sources available during the hottest months of the year… where BLM has approved a mine that will eventually dry up that source.

The Pancake Gather-EA includes a paragraph BLM copies and pastes into most gather plans: 

Furthermore, simply re-allocating livestock Animal Unit Months (AUMs) to increase the wild horse AMLs would not achieve a thriving natural ecological balance. Wild horses are unlike livestock which can be confined to specific pastures, limited to specific periods of use, and specific seasons-of-use so as to minimize impacts to vegetation during the critical growing season and to riparian zones during the summer months. Wild horses are present year-round and their impacts to rangeland resources cannot be controlled through establishment of a grazing system, such as for livestock. Thus, impacts from wild horses can only be addressed by limiting their numbers to a level that does not adversely impact rangeland resources and other multiple use.

When you read the paragraph (above) the absurdity of it is simply jaw-dropping if you spend any time at all on public lands. 

HMAs are made up of a series of fenced grazing pastures for livestock where the gates are closed when livestock is out (and are often closed even when livestock isn’t out). This not only limits the movement of livestock (the reason for the fences and gates), it fragments the range and leaves wild horses either caught inside or caught outside. Often these gates inhibit access to limited waters throughout an HMA (as is the case in Pancake, including during the hottest months of the year) creating artificial use patterns by wild horses by cutting off critical habitat. If the fences were gone and there were no gates, wild horses could actually disperse throughout their HMA and not impact the only waters they are left access to as heavily.

The intensive livestock grazing is not limited to a few months. Of the 59,427 AUMs allocated to livestock in the Pancake complex, 40,955 of them belong to year-round permits. Another 13,232 livestock AUMs add additional pressure during the hottest months of the year. 

Note: If cattle and sheep did not go through our public lands like locusts, there would be available forage for wild horses/burros and wildlife all year. (If predators were not killed for livestock, herds of grazing animals would not grow as fast. But that is another subject, for another day, demonstrating how public land management revolves around livestock.)


One of the next claims will be “non-use.” BLM will make a claim that for a decade (or longer) one or more permittees may not be using all of their AUMs. Usually this claim will be reflective of long periods of drought (but blamed on wild horses). If AUMs need to be cut in prolonged drought, then the calculation of livestock AUM is inaccurate and should be addressed under existing law as not representative of average available forage (if BLM does not calculate drought in states where 4 of 10 years is historically drought plagued). BLM has the authority to allow additional grazing in odd years where there is more actual available forage that is not represented in average years. Does BLM keep the AUMs high to help perpetuate the propped up federally guaranteed bank loans that can be taken out on AUMs?

If climate change or other factors impact availability of forage where a permitted use of public lands is no longer viable, BLM is supposed to limit or stop that impact to natural resources. It should come to no one’s surprise that at a certain point the viability of an industry (subsidized western public lands grazing) that places large numbers of non-native domestic livestock on the range reliant on the growth of grass in the most arid states in the nation, would become environmentally unsustainable in many areas at some juncture.

The Code of Federal Regulations even states that livestock use can be stopped to create habitat to maintain wild horse herds.

(a) If necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury, the authorized officer may close appropriate areas of the public lands to grazing use by all or a particular kind of livestock.

Yet, in wild horse Gather-EAs BLM will claim (in a copy/paste used in all of them):

Eliminating or reducing grazing in order to shift forage use to wild horses would not be in conformance with the existing Land Use Plans (LUP) and is contrary to the BLM’s multiple-use mission as outlined in FLPMA and would be inconsistent with the WFRHBA and PRIA…. 

The laws BLM lists are all codified stating that livestock use can be stopped. A codified regulation does not cease to exist because an (often decades old) LUP does not specifically mention a regulation. Simplistically, that would be like saying you can steal from your neighbor because the Homeowners Association failed to mention a law.

The rest of that paragraph from the Gather-EA reads:

... Therefore, the BLM is required to manage wild horses and burros in a manner designed to achieve a thriving natural ecological balance between wild horse and burro populations, wildlife, domestic livestock, vegetation and other uses.

The two maps above are from a PEER interactive map that recorded BLM data to create a picture. Left: the yellow are HMAs and the white lines are western BLM grazing allotments. Right: indicate where BLM data found failing rangeland health. It is important to remember that gray means “no available data” and that many of these assessment records are over 10 years old (pre-drought). The picture above does not include Forest Service (USFS) data for lands bordering many BLM allotments where USFS also issued grazing permits and standards are not being met.   What you can see is that rangeland health standards are not being met, according to BLM, even where there are no wild horses. 

What the PEER report found, using BLM data: “Once compiled, the assessments indicated that livestock were responsible for roughly 72% of that degradation, while a combination of livestock and wild horses caused about 13%. Less than 1% resulted from wild horses alone.”

The big blank spots are USFS land. This “snapshot” of rangeland health data from Pancake is from 2009.

In 2011 BLM approved a Gather-EA for the Pancake Complex. In 2012 BLM began removing wild horses under that plan. They captured around 1500 wild horses during the life of the document.

What BLM did not do? They did not do any assessment to demonstrate that removing wild horses created any change or progress toward attaining a “thriving natural ecological balance.”

The 2021 Gather-EA uses the exact same rangeland health data that the 2011 EA used.

They have approved additional habitat loss and fragmentation inside the HMA and crafted a new plan to remove more wild horses. Although the same livestock AUMs are still active, BLM approved plans to extend livestock reach into the HMA through a water pipeline. In addition, BLM has approved mining and more fences.

In other words: BLM asserts that removal of a certain number of wild horses/burros will achieve a “thriving natural ecological balance” at the exact same time they create impacts far greater than those created by wild horses by expanding livestock reach and approving mines. 

Pancake wild horse after a struggle with barbed wire simply to get a drink at one of the only available sources for miles and miles.

Barbed wire is an obvious visual example of habitat fragmentation. 

The Wildlife Society published a study (Harrington & Conover, 2006) of mule deer and elk mortality along an 600 miles of road that had barbed wire  fencing  in Utah and Colorado. When you break down the math: one dead antelope every year per 5.6 miles, one dead mule deer every year per 7.8 miles, one dead elk every year per 10.3 miles of fenceline. They noted the animals tangled and dead, but also those that died next to the fence; a dead animal tangled every 2.5 miles of fence, as well as a dead animal next to a fence every 1.2 miles (90% were fawns).

How many wild horses or burros die each year from barbed wire? there are no statistics. Barbed wire keeps wild horses from access to water, again and again. How many die of dehydration? no official statistics to cite. How many die because they cannot access all of the grazing land in an HMA because of barbed wire? no official statistics.

BLM has done no evaluation since the 2011 Gather-EA to show that removing any wild horse helps achieve “thriving natural ecological balance” and just continued to approve more projects that will negatively affect rangeland health. 

Instead, BLM simply approved another roundup plan. 

No management plan for wild horses has ever been created for Pancake (an HMAP-EA where we could address impacts to wild horses and loss of habitat, y’know… an actual management plan). 

The situation our Pancake wild horses face mirrors the same situation the vast majority of our wild horses and burros face. 

Active litigation at Pancake is crucial to help protect this amazing herd as well as take steps to create a precedent to change the way so many of our other herds are being shortchanged. 

Video below: a fast outing before the Triple B roundup of 2022. Triple B is across a highway from Pancake.

On top of the “game of AUM” our wild ones face extraction, energy pipelines and more. We will cover how BLM ignores impacts from mining and fails to mitigate any damage done as they continue to create a reality that is not even remotely related to “thriving natural ecological balance.” 

Our next installment on Pancake will address mining. 

We hope you take the time to get to know Pancake and see a real-world example of how BLM ignores their responsibility to protect our wild horses.

Help keep us in the fight.

Through February 20th, all contributions will be matched up to $10,000. to help us fuel the fight into 2023.

Categories: Lead, Wild Horse Education