The image above is a dirt road out in the nowhere that was widened for two mines deep inside a Herd Management Area (HMA). Mining takes up significant surface area, creates a water table drawdown. It also creates traffic in wild places where wild horses are considered a “safety hazard” as they travel inside territory designated for their use. Habitat loss and fragmentation drive hardship and removals.

“Open range” is as much of an oxymoron as “Jumbo Shrimp.” Public lands are a series of fenced livestock grazing allotments, mining pits and leach ponds, energy transmission lines and roads and more roads widening every single day to withstand the big rig traffic.

Habitat Loss and Fragmentation 

What is the official definition? Habitat destruction and fragmentation is a process that describes the emergences of discontinuities (fragmentation) or the loss (destruction) of the environment inhabited by an organism.

The three main types of habitat loss are habitat destruction, habitat degradation and habitat fragmentation. The effects of habitat loss echo up the food chain and disrupt the entire ecosystem.

Map showing biodiversity loss driven by habitat loss and fragmentation

The map above is from a New York Times article about biodiversity loss in the United States. The article s worth a read HERE,

Wild Horses and Burros

When federal agencies like the BLM and many wildlife organizations address wild horses and burros you would think that someone would have the common sense (or decency) to recognize on the habitat loss front wild horses and burros have always gotten the short end… but could be a barrier to protect habitat loss on the mere 12% of public lands designated for their use.

Wild horses once roamed freely throughout the western U.S. However, debates in Congress to pass the 1971 Act included limiting their territory to designated areas only. (This piece on that debate is worth reading for all advocates HERE)

Areas were carved out and given the name “Herd Area” or HA. These Herd Areas caused more contention and political theatre at the local level.

Wild horses and burros then lost nearly half of that territory when BLM then carved “Herd Management Areas” (or HMAs) out of the HAs.

Below: This map gives you an idea of the loss of territory designated for use by wild horses and burros. You can see the entire collection of maps HERE.

This extremely limited territory our wild horses and burros legally occupy is important to understand. Not only were the original boundaries politically motivated, when horses and burros were documented standing on land and it was designated for their use, the local political stage took over and more territory was lost.

Many more acres were removed from “active management” as herds were zeroed out (totally removed) in the local political poker game BLM calls “Land Use Planning.” More herds were “zeroed out” and their HMAs reverted to HA status: designated for use, but not managed for use by wild horses and/or burros.

Within HMAs

Did you know that BLM is supposed to do Herd Management Area Plans (HMAP)? BLM is supposed to create HMAPs to determine things like a public equation for forage allocation and stocking levels (what BLM calls “Appropriate Management Level” or AML) of horses and/or burros. Not only was territory they were legally allowed to occupy determined by politics in the 70s and 80s, so were things like forage allocations and AML.

BLM may say they “affirmed AMLs” in Land Use Plans (LUP) after the dates they were set. But that does not mean they ever created a valid “what the land can sustain” equation inside the HMAs. It means they retyped the numbers of “horses and cows,” not that they evaluated it.

When you look at allotted forage and AMLs, there is not even any equation that correlated AML to forage. Within any given HMA, wild horses receive about 12-20% of forage. In some areas (like Bordo) there is not even a designated allocation.

HMAs are a series of fenced livestock pastures, mining pits, roads and on and on. When you just look at surface area for “free-roaming” wild horses and burros, habitat fragmentation is causing issues without any notion of sustainable management and it is creating areas of artificially high impacts.

Did you know there are HMA boundary lines where BLM cut off any year-round waters? Water haul in Snowstorm due to horses leaving HMA, into the HA area, to get water. The water just off HMA was being fenced off by a mine. BLM then had to haul water, blamed horses and removed them.

BLM has never identified critical grazing habitat or critical water sources for sustainable management of wild horses and burros. In fact, just using the term “critical habitat” in relation to wild horses can make any federal land manager’s head spin. If habitat is deemed “critical” for the survival of any species, industry (livestock and mining) might need to be limited.

One example of habitat loss in play right now is the Juniper Project: the expansion of the Bald Mountain mine. Not only are wild horses currently considered a “safety risk” and removed for the existing mining traffic, the mine is expanding. The expansion will directly take away a significant portion of the HMA and indirectly draw down the water table and create more roads and intense traffic. (More HERE)

Just like any other species that relies on public lands to survive, wild horses and burros are being hit by rapid habitat loss and fragmentation threatening their viability. 

Why isn’t habitat protected for wild horses and burros? 

The law is clear: wild horses and burros are to be managed humanely and herds and “ranges” be preserved for future generations.

The law was codified (turned into regulations) that would guide practices. The regulations state BLM shall create herd management area plans; not “maybe create,” but “shall create.”

BLM does not deny they are mandated to create these plans. In court, right now, BLM is literally arguing that the law does not state “when.” We are serious. For over 45 years, since the Act was codified into law, BLM has been kicking this critical step down the road. (Edited to add: The court has ruled BLM has unduly delayed crafting HMAPs. We are continuing to expand these cases in the courts.)

In practice, BLM does Gather Environmental Assessments (EA) and has passed these off to the public, media and Congress, as management plans. Many of these Gather-EAs have turned into documents that are over a hundred(s) pages long. They mention everything from grazing to water. But they don’t let you give input on any of those subjects. The decision being approved is “population growth suppression” (remove/fertility control)… and that is it. The decision is being made to “comply” with planning BLM has done for mining, livestock, sage grouse, etc. Even BLM will tell you any comment outside the scope of removal is off-limits. They put all the rest of that stuff in there to try to confuddle a courtroom and the media into thinking it is a well thought-out management plan.

Below: A simple illustration of how little consideration wild horses are given could be seen at Robert’s Mountain in almost an absurd tragic comedy. Not only did BLM allow the spraying of weed killer from a plane in the same draw wild horses were actively being driven through by helicopter, but BLM allowed heavy equipment for mining to be offloaded nearly on top of the trap. Observers with cameras were, of course, kept far away due to “safety concerns” that they would spook wild horses.

How do advocates fight back?

We can fight grazing EA by grazing EA. We can fight mining EIS by mining EIS. We have and we do. But our ability to stop the rapidly shrinking resources available to wild horses and burros is limited by the lack of Herd Management Area Plans (HMAP) or any other equivalent document that defines what each herd is and what they need to survive into the future (things like critical resources).

Only with an HMAP can we begin actual management as the law originally intended; to protect and preserve our herds. An HMAP is supposed to stand the same way a plan for sage grouse, a mine, a livestock permittee sets a “protection” for that interest in practice. Right now, horses and burros are removed and kept at non data-based numbers to suit planning for every other interest on public lands. An HMAP would allow the public to have input (and to litigate) if BLM fails to address things beyond removals. An HMAP would only be as good as public engagement, but it is the doorway we need to open, fast.

Our team is carrying multiple federal court cases that address the sheer lack of data-based transparent management planning. These cases are moving through the court system now. 

What can you do?

Help us get designated funding for HMAPs and begin to demand that every single herd actually has a management plan that creates an actual monitoring and management plan and discloses data used to create AML, forage allocation, designates critical habitat, defines herd viability through determination of necessary breeding adults (without any fertility control) to maintain health and the unique makeup of each herd. 

We cannot allow Congress to keep the focus on new ways to perpetuate the status quo of claiming “population growth suppression” is the number one issue. We need to get lawmakers to understand that the actual lack of data-based management plans is at the root of all the problems and constant escalating drama. Removal and fertility control should ONLY come AFTER BLM creates actual management plans that show specifically: if, how and when.

Last year, many of you took the 4-step action item for the budget bill. The letter and actions included all of the things you told us were important to you. However, there is one simple message from livestock and mining groups:  Get horses and burros off the range and find a way to keep those population numbers as low as possible. We must counter their simple messaging with pointed and timely messaging of our own

Action Item Expired

Your actions will support our teams in field, in the courts and as we work to educate lawmakers. 

As we begin to review the direction of public lands challenges in 2023 for our wild horses and burros we begin to plan our strategies for 2024. Our wild ones have been minimized and overlooked in actual land use planning for far too long. Habitat loss and fragmentation is the number one threat to all wild things. The only way to gain a voice in the process is to force BLM to comply with existing law and create HMAPs that address the issues of habitat loss, climate change and more impacting our herds as industry rapidly takes over their territory.

HMAPs will be high on our priority list in 2024.

As we move toward the end-of-year we will bring you reviews of the year, our work and a full priority list for 2024. Thank you for keeping us in this fight!

End-of-year funding is critical to all nonprofits to keep programs running into the new year. WHE is no exception. Without you, none of our work is possible.

Thank you for keeping us in the fight!

Our wild ones should live free on the range with the families they hold dear. Our wild ones should also live without abuse. WHE carries ongoing litigation to push BLM into open public process to create an enforceable welfare standard for our treasured wild ones. Something they said they would do years ago. 

There are many ways to support the work of WHE from direct contribution, stock donations and even while you shop. More HERE.