Below are Wild Horse Educations comments submitted to the Advisory Board and sent to Congressional Representatives.
Comments Respectfully submitted to the BLM Wild Horse and Burro Advisory Board, BLM and Congress.
1. We are alarmed at the conflicts of interest that exist on the BLM Wild Horse and Burro Advisory Board. Until such time as members on the Board represent no other interest in public land management, any recommendations from this Board are suspect. An advisory board for an issue should be proposing best practices to that interest and only in a secondary capacity creating recommendations to balance other uses. Recommendations for best practices should be a primary concern only.
2. Recommendations from the BLM Board continue to be suspect when procedures that are hazardous even for domestic equines in a hospital setting, such as hysterectomies, are even considered as appropriate to perform on wild equines in a field situation. Furthermore, precedent has been set against gelding wild horses on the range. So why are we continuing to talk about this? Why are we even having this discussion? Does BLM want litigation on this issue? Does the Board advise BLM to take a course that they know will lead to litigation? With the current precedent to gelding the Board should include a cost study to the legal ramifications of moving forward with hysterectomies.
3. The recent BLM memoranda created on humane care handling and observational protocol of wild horses and burros are woefully inadequate. These memoranda were created at significant expense to the taxpayer but represent nothing more than an outline of a supposed policy that has been asserted to exist for years. Everything in these extensive memoranda boils down to one thing: all decisions are left up to the opinion of the BLM person on the ground (i.e., the contracting operations representative or COR) . This is nothing new, it is what we have had all along, and public observers are still consistently blocked from documenting what happens to horses, while a helicopter hits a horse, while babies are run to exhaustion, while hot shot use is random and excessive, and while babies are run in temperature extremes within days of birth and court actions result in restraining orders and preliminary injunctions. The BLM should be admonished for spending tax payer money to simply reiterate existing useless operational protocol. The Board should recommend that a policy that includes specific protocol that must be followed and an outline for violations to that protocol.
4. No proposed holding facility or resort should be allowed to impact ANY currently protected population of wild horses on a Herd Management Area (HMA). All holding facilities and resorts, including the proposed resort for Madeleine Pickens, must only be approved on private property. (Wild horses and burros have sanctuary under law, it is called a Herd Management Area).
5. No decision, policy or protocol should be created until the following basic data is established for each Herd Management Area: migratory patterns, genetic viability, actual foaling season dates. In addition for each HMA there should be a re-evaluation of the determination of boundary lines and the appropriate management levels (AMLs). In many instances both boundaries and AMLs may have been established as a result of improper political influence or cronyism and will have to be corrected.
6. Before asserting that an AML is appropriate the Board MUST recommend that the AML be re-evaluated, and this must be done HMA by HMA. AMLs have been what stands in the way of actual appropriate protection of genetic viability and protection of resources that are legally mandated for use by wild horses and burros.
7. The Board utilizes restrictions that are NOT present under law. As an example: repopulation of Herd Areas (HAs) is NOT restricted to non-reproductive herds, yet the Board is only allowing for repopulation by utillizing herds that are non-reprodcutive. It was asserted by committee members that pressure from the livestock industry is a factor in the committee’s protocol. That factor invalidates any recommendation on restrictions to repopulate HMAs due to bias, prejudice, and conflict of interest.
8. The Board must recommend that investigations into the sale of wild horses to slaughter by BLM continue until appropriate reprimand and consequence are faced. This practice is a bold disregard for the parameters set by Congress for funding the wild horse and burro program and a violation of basic public trust.
9. In terms of dealing with issues of drought and decreasing habitat due to over-grazing by private livestock, the Board MUST recommend that the viability of wild horses and burros be a priority in any drought management plans. Other public land users have vast stretches of public land available for their use and wild horses and burros are limited only to about 10% of public land. The survival of wild horses and burros in the wild depends on their protection on the range as demonstrated by language in the Wild Horse and Burro Act.
10. A full cost recovery system on public land would solve significant issues. The Board tends to focus on the costs of holding wild horses and burros as a “shock factor” to justify the need to continue to recommend inappropriate actions that compound current issues. IF HMAs were actually managed by charging users a real market rate for the use (appropriately compensating the public for public resource) the funds would be available to create databases that are currently woefully absent. As one example: A current AUM (Animal Unit Month) is charged at the rate of about $1.35. The real market rate for a month of feed for a cow/calf pair is currently between $15-$20. In effect the public is losing the difference of about $14 to $19 per AMU (multiply that by the number of cows on public land). Financial issues and costs are always laid at the feet of the wild horses and burros, but if BLM charged a fair prices for public land grazing the would recoup more than the entire annual costs for wild horses and burros. The Board should recommend that the actual cost to the public of other uses within HMAs be revealed and addressed appropriately.
The laws state that wild horses and burros are to be managed as a viable use within the parameters of multiple use on public land. Currently wild horses and burros are not being managed as a viable use, as mandated by law. The Board should sternly warn BLM about operating in violation of the law that creates additional expense to tax payers when litigation must be filed to correct the situation.
These comments touch on many of the areas where we have concern about the management of wild horses and burros by the BLM, but are not inclusive of all concerns. Our comments address our concerns about the way in which the Board itself creates recommendations.