Advisory Board June 28-30 (commenting)

By Laura Leigh on June 19, 2023

Are you planing on commenting at the Advisory Board meeting on June 28-30? If you are, there are a few things you should know.

The National Wild Horse and Burro Advisory Board will meet June 28-30, 2023, at the Whitney Peak Hotel located at 255 N Virginia Street, Reno, NV.

If you are speaking in-person, you can sign up at the meeting.

You need to sign-up to comment virtually by the 25th, 3 days before the meeting begins.

Spots to speak will fill up fast.

The agenda for the meeting is up and it does NOT show any distinction between in-person or virtual comment periods, they will run concurrently. There is a one hour public comment slot each day for a total of 3 hours the entire meeting for both virtual and in-person public comment. The 2-hour comment period for the one-day “Motorized Vehicle Hearing” was filled rapidly. If you plan to speak virtually, sign-up before the slots fill up.

3:15-4:15 p.m. on Wednesday, June 28, 2023
1:30-2:30 p.m. on Thursday, June 29, 2023
9:30-10:30 a.m. on Friday, June 30, 2023

The public may also submit written comments to the Advisory Board in addition to, or in lieu of, providing verbal comment. Written comments should be submitted to the Advisory Board at whbadvisoryboard@blm.gov (copy and paste email address). Comments emailed three days prior to the meeting will be provided to the Advisory Board for consideration during the meeting.

We always thought the requirement to submit BEFORE the meeting is a bit odd. You should be allowed to respond to what you hear in your comments. So we suggest that if you submit written comments BEFORE the meeting and it appears the board either did not respond or misunderstood the subjects you covered, write them again… the email is live all year long.

What should you say?

Say what you want to say. You do not get many chances to talk about what you want to. BLM says they want your comments to be relevant to the agenda. But the agenda is so vague you talk about what YOU want to. You are the “public” in “public lands management.” Always remember. that and speak up.

Wild horses and burros are a public resource managed by BLM and USFS. So say what you want to say… they are public horses. The same as the public grass, gold, silver, lithium, etc. they belong to the public just like everything else BLM manages for the “public good.”

If you are new advocacy and have never seen a board meeting, you can watch past meetings that have been posted on YouTube HERE.

Suggestions

Do you know a herd? Talk specifically about that herd and the loss of habitat, what roundups do to band structure, etc. So much of the chatter during these meetings is theoretical and non-specific. Give the board specific talk from your observation.

Have you seen science BLM refuses to recognize? Damage done to western ranges by cattle but blamed on horses. Science related to native status of the horse. How BLM treats burros like horses ignoring even the differences in reproductive rates and diet. All of those are relevant.

You can talk about how BLM has not provided and population surveys for herds they have already placed on the roundup schedule. BLM has recognized that this winter was so hard wildlife species had record die-offs in some areas and BLM even approved the feeding of hay for cows on the range… but it seems they feel wild horse populations simply continued with no impact from a winter that hurt everything else? Where are the population statistics reports and flyover data to justify roundups that begin in a couple of weeks?

What is WHE going to say?

We honestly do not know what we are going to say until we listen to the board. Most often, we craft comments in response to what we hear the board say.

Last year, after complaining about advocates that litigate, the board began complaining that BLM is not doing management plans. It seems the board forgot the name of those plans (Herd Management Area Plans, HMAP) and that is exactly what much of the litigation is about; we want BLM to stop skipping actual management planning.

Comments from WHE last year (we have thought about just playing them this year instead of speaking? What do you think?).

Prior to the meeting last year, 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 also published a piece on numbers in holding that demonstrate just how close the program is to hitting a wall. You can access it HERE.

A report from our WHE CAWP team (welfare) team can be found HERE.

The reports listed above can be used to give you some ideas as you craft your own comments.

REMEMBER… BLM manages public lands for the “public interest.” Profit driven interests are NOT the only voices that matter… your voice matters too.