Comments by Charlotte Roe to BLM Wild Horse & Burro Advisory Board

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A BLM T-shirt I wear commemorating my first mustang adoption calls wild horses “uniquely American.”  The label celebrates wild horses as a uniquely native, uniquely valuable species. But the Agency’s actions and policies tell another story.
 
The BLM’s website erroneously calls them non-native, when today the scientific consensus considers wild horses to be a returned native species. The Wild Free-Roaming Horse and Burros Act lauds wild equids as “an integral part of the natural system of the public lands” and important to achieve a “thriving natural ecological balance,” while federal land managers act as though their lives have little to no value. This is not OK. The living deserve our respect and understanding.
 
The BLM justifies spending taxpayer monies to harass and remove them from their rightful lands by saying they overpopulate, starve and hurt the “thriving natural ecological balance” on the range. These are unsubstantiated and absurdly contradictory allegations.  The Agency is well aware that culling herds by helicopter causes populations to increase, yet it relentlessly proceeds to round up, remove and imprison wild horses and burros. The recent Checkerboard roundup is a case in point.
 
Are wild horses and burros responsible for rangeland degradation? Let’s be real. The BLM has never accounted for the impacts of livestock grazing, which by the early 1900s had depleted nearly 700 million acres west of the Mississippi and continues to destroy fragile habitat to this day. It has scapegoated wild equines to covert up the continuing degradation and over-exploitation of public lands.  Not once has the BLM acknowledged the beneficial contribution of wild horses and burros to the environment. They graze on fire-prone vegetation and underbrush that is inaccessible to cows and sheep. They spread seeds. They break ice and dig water holes, increasing access to scarce resources for other wildlife species. They restore balance. Can they overgraze? Any species including elk and cows can over stress forage resources. But how wild equines adapt to,and impact the landscape, is quite different from ruminants.  And reducing wild horse numbers, as the BLM proposes to do on the Silver King herd in Nevada, to one horse per 10,000 acres is beyond belief.
 
Do mustangs and burros overpopulate the West?  When the WFRHBA was passed in 1971, no one had a good count, but their numbers (at around 17,000, close to the BLM’s low AML for all herds) were considered to be dangerously depleted.  When the first rough census was taken several years later, the wild equine population was just about what the BLM counts today. And today, the majority of remaining herds are seriously underpopulated, thanks to AMLs which the National Academy of Sciences has termed arbitrary, unnecessarily rigid and unscientific. 
 
Now, the Department of Interior proposes to drive wild equines all the way to extinction by killing “unadoptable” healthy horses and burros in captivity, by unlimited sales of those in holding and by destroying those deemed “excess” on the range. This proposal would not only destroy a monumental part of American history and the rangeland ecology. It is totally unsustainable. It would put the federal government squarely in the middle of the nefarious horse slaughter industry. How can the anyone justify pouring taxpayer monies into this cockeyed, pernicious scheme?
 
BLM leaders maintain that wild horses and burros are costing an arm and a leg and that the “free lunch” has to end. Let’s examine that concept.  We know the federal grazing program runs at a huge loss, costing taxpayers 200 million a year by conservative estimates.  Add to that the cost of DOI’s Wildlife Services program, for which we taxpayers pay 125 million a year for exterminating predators at the bequest of the livestock industry. That’s a whopper of a free lunch.  It dwarfs many times over what the BLM Wild Horse & Burro Program spent in 2016. 
 
Free lunch is the 22 million acres BLM has removed from the herd areas lawfully designated for wild horses and burros, at the bequest of the livestock industry, well-heeled politicians and commercial lobbyists.  
 
Free lunch is stockpiling captive wild equines and claiming there are 46,000 in holding, when the Agency can only account for half that number at best, and a recent independent investigation found that payments for long-term holding operations are being made for apartment buildings!
 
Free lunch is paying a few contractors millions per year to harass, terrify, and harm protected wild horses and burros.
 
Keeping mustangs and burros free on the range costs taxpayers next to nothing. The BLM has never recognized their restorative role in the rangeland ecology. The Agency has many practical, more cost-effective options for managing them, but has instead relied on those which cost taxpayers the most and harms these federally protected species while benefiting private interests.
 
That failed approach must change.  Consider a humane, common sense approach:
 
-Create a ten year plan to reduce and stabilize wild horse populations where needed, using native PZP, PZP-22, and/or Gonacon. All of these methods work. 
 
-Immediately reallocate BLM funds from the negative loop of roundup and removal to the administration of fertility control for mares beginning late winter-spring 2018. 
Make monies available to pay volunteer expenses in the field as well as darting
certification class expenses. 
 
-Return geldings and older mares to zeroed out HAs and HMAs.  Let them live out their lives in the peace they deserve and cut the holding budget by over half.
 
-Permanently remove only adoption-age horses (1-5 years) equal to the number
that are likely to be adopted yearly.  Expand training programs for horses 
removed to ensure and increase adoptions.  
 
-Fund research to focus on a multi-year, remotely deliverable, safe and reversible birth control vaccine. Do NOT focus resources on permanent, inhumane and dangerous operations such as ovariectomies and gelding (which does nothing to reduce births).
 
-Fund research to study the ecological impacts of livestock grazing, oil and gas drilling and mining to develop meaningful context for the “thriving natural ecological balance” so often cited, but never examined in environmental assessments.
 
-Begin the planning process to raise AMLs with initial focus on the herds that are not genetically viable. The vast majority of herds have AMLs under the 150 adults required to maintain variability and long term health. In particular, the NAS warned in 2013 that the small, fragmented burro populations were already genetically threatened.
 
-Revise Resource Management Plans to ensure that wild horse and burro herds have at least 51% of forage allocated to them. Keep in mind, wild horses and burros live on only 11% of BLM lands and on average are allocated no more than 18% of the forage in relationship to livestock. The ranges are historically designated as “principally but not exclusively” for wild horses and burros, yet the wild equines are now relegated to a fraction of BLM lands, while livestock are on the vast majority.
 
-Set aside ranges that are livestock free (like the Pryor Mountain Wild Horse Range) for burros within the Black Mountain HMA in Arizona, and for wild horses within the Red Desert Complex in Wyoming. Do not allow hunting of predators in these ranges so that a natural balance might be attained. Halt the killing of mountain lions in all HMAs. Taxpayer dollars should not be used to kill effective wild horse predators.
 
-Revise the BLM website and literature to remove denigrating, uninformed terms like “non-native,” “feral” and “invasive.” Words matter. The 1971 Act defines wild horses and burros as “free-roaming” wildlife species that play an key role in the rangeland ecology and in our cultural heritage. Respect these sentient beings. Stop the scapegoating. Focus on management tools that work. Choose solutions and coexistence, not slaughter. We’re here to work with you for those humane, sensible goals.
 
Submitted by:
Charlotte Roe
Director, Wild Horse and Burro Project
In Defense of Animals
Grand Junction, Colorado
October 18, 2017

AUTHOR: Jerry Finch
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