These are questions BLM refuses to answer
As wild horse and burro advocates we deal with the many layers of the BLM Wild Horse and Burro Program (and programs within a program). A roundup filled with abuse and neglect can bring more attention to the mismanagement of our wild ones than just about anything else. The journey of the “once wild” into holding fraught with dangers and a death rate of, on average, 12% in the first six-months. The adoption program, or the record-breaking numbers of horses and burros now run through the Sale Program (where Title transfers immediately), land so many into the slaughter pipeline and bring public outrage.
The broken on-range program stands as the catalyst for the more easily seen roundup or wild one in a kill pen.
The nonsense and elusiveness of Appropriate Management Level or AML (the number of wild horses or burros BLM says can be sustained on the range) sits at the center of the broken on-range program.
In all 10 western states combined, fragmented and nonviable populations are the goal (and have been since the late 1970s)
Background
We all know, even BLM knows (and this should not be a subject of debate), that when the 1971 Wild Free-Roaming Horses and Burros Act was passed, BLM was pretty much “caught with their pants down.” BLM had no data about wild horses and burros on public lands as this was really not in their jurisdiction. The only aspect of “wild horses” BLM was involved in was the 1959 “Wild Horse Annie” law that forbade poisoning of water holes and hunting down wild horses with motorized vehicles (ala the Misfits). That law was not being enforced and jurisdictional battles between states (that wanted mustanging) and the BLM saw the law creating more confusion and no protection… and part of the reason the 1971 law was passed in the first place.
When BLM was tasked with setting boundary lines and “numbers allowed,” they had no data to base anything on. In the states where the law was to be implemented by the BLM intense resentment arose.
BLM allowed a “claiming period” which essentially allowed people to “claim” wild horses on the range as private property (without any proof) and mustanging continued for the next 5 years (many areas being wiped out of all horses and burros).
The first official roundup after the passage of the Act brought all of this to a head at Stone Cabin in 1975. BLM just did a roundup of wild horses because the range (where thousands of cattle grazed) was in bad shape. The court allowed the operation to continue, granting BLM jurisdiction and refusing a bid by the State of Nevada to seize the horses and send them to auction. But the court stated BLM could not just keep doing that and needed to follow the data-based and open public processes prescribed by the National Environmental Policy Act (NEPA) that they used for everything else “managed by BLM.”
This left BLM having to craft some kind of document that set a boundary line, set a “number the range could sustain,” at the same time they were dealing with intense blowback from the livestock community (that were most often friends and family of people working for BLM).
In a nutshell, BLM created what they called “interim AML.” These interim numbers were numbers agreed to with permittees on an allotment-by-allotment basis. These numbers were not based in science (neither were the numbers of sheep and cattle that were simply based on a 30% cut to historic use after the Dust Bowl and the 1934 Taylor Grazing Act was passed).
Since then, BLM has simply carried over those numbers with extremely little deviation. “Affirming” those numbers really just means retyping them and claiming a “once in a decade” visit to the range by BLM personnel shows it to be “true.”
Today:
After the Wild Free-Roaming Horses and Burros Act was Codified into law (it took nearly a decade to codify), BLM was supposed to create Herd Management Area Plans (HMAP) that, among other things, disclosed the data and equation used to set AML.
BLM began creating HMAPs for a few herds, including the one where litigation during the first roundup brought the first ruling against the lack of actual analysis at Stone Cabin. The few early HMAPs all note that there is a significant lack of understanding in how wild horses and burros use the range, lack of information to distinguish livestock vs horse/burro use and basically says the AMLs were set in agreements and data needed to be collected to set real ones.
For all of the Herd Areas* BLM only crafted about 30% of the required HMAPs. The last time BLM reported to Congress on HMAPs was in the late 1980s. BLM simply switched to creating long-term roundup plans instead of crafting HMAPs and distinct “gather plans.” *In the beginning, the land where a horse or burro stood was called Herd Area. In the 1980s BLM began carving out Herd Management Areas (HMAs) out of the Herd Areas (HA) and saying they would only manage inside the smaller boundary lines, again without data to justify the move beyond the obvious conflicts with livestock.
The “remove and stockpile” industry was born of an AML based on assertions
No matter how many times someone made a comment on a “gather plan” assessment about AML (how was it set?) BLM said it is outside the scope, ignored the comment and rounded up to get to “AML.” If you commented on a Land Use Plan, you were told it was “outside the scope” as a Land Use Plan was not a landscape level analysis document. Freedom of Information Act (FOIA) requests would simply produce a copy of the Land Use Plan.
Last year we won two lawsuits that both said the same thing: BLM has illegally withheld HMAPs and that a “gather plan” is not a management plan.
In response, BLM is basically crafting gather plans and saying they are HMAPs. Instead of, among other things, disclosing how AML is/was set and evaluated… BLM is simply citing that AML was “affirmed” in land use plans and the purpose of management is to maintain AML…
Breakdown of AML for the HMAs nationwide. Only 3 HMAs in the U.S. have an AML over 500. Only 31 have an AML over 150. These same ranges support thousands of cattle and massive extractive industries. HMAs are isolated pockets throughout 10 western states and does not represent a genetically viable number.
For over 40 years BLM will simply NOT disclose how AML was actually set. BLM will not disclose any data-based decision on forage allocation. BLM will not disclose how they determine forage and what they use to determine an “appropriate allocation” for wild horses, livestock, wildlife, that achieves Thriving Natural Ecological Balance (TNEB). BLM will not disclose any data-based equation of how how forage allocation determines AML.
However, BLM will claim that they have to remove wild horses and burros to reach low AML in order to achieve TNEB. Both AML and how BLM defines TNEB remain vigorously kept secret.
WHE is in federal court challenging BLM’s HMAPs, after litigating to get them to simply do them… and winning. We are now filing plan-by-plan to get them to actually do management plans and not simply retitle gather plans… and fail to disclose and analyze core issues like AML.
What can you do?
Take Action!
The BLM 2020 Plan has been running fully funded and full steam for 5 years. Basically slam populations down as fast as you can and employ stronger and stronger fertility control (without monitoring plans). The entire structure is built on AMLs that have never been disclosed or reviewed.
Wouldn’t the only fiscally responsible step be to “stop” and to commission a science-based review by the National Academy of Sciences (NAS)? The 1971 Act calls for these studies. The last one was done in 2013, 15 years ago, long before the “2020 Plan” and the rapid slide into collapse.
Before throwing more money at a plan that has been running for 5 years, shouldn’t the plan be reviewed to see where the money was spent and the results?
There are many layers to the BLM Wild Horse and Burro Program… and many threats to the welfare and safety of our wild ones.
Right now, there are debates happening as budgets are being slashed that place our wild ones in holding in the target zone. Discussions are underway where many claim our wild ones held captive are a taxpayer burden and sales without limits (slaughter) or killing them should be on the table. (Learn more HERE about the budget debate)
All of our work is only possible with your support.
We thank you for keeping the critical work we do at WHE running for our wild ones.
Categories: Lead
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