We are presenting many concerns about the disastrous proposal titled “The Path Forward for Management of BLM’s Wild Horses & Burros” by HSUS, ASPCA, Return to Freedom and American Mustang Foundation, who have seemingly betrayed the wild horses and burros and have hopped into bed with the National Cattlemen’s Beef Association, among other groups representing livestock grazing interests. The article below is written by Ginger Kathrens.

RACING TO EXTINCTION: NEW MANAGEMENT PLAN WILL DEVASTATE OUR WILD HERDS

By Ginger Kathrens, Exec. Dir. of The Cloud Foundation:

May 16, 2019

Dear Friends,

For the past couple of weeks, we have been in contact with the ASPCA and HSUS, the main drivers behind a new management proposal for America’s wild horses and burros. We learned of their concerns for our wild herds in response to growing impatience on the part of lawmakers, who are eager to find a workable solution. We have also listened to the comments of other wild horse advocates and all of you wild horse lovers. We share your deep concern, especially if this plan moves forward.

In its current form, this “management” plan lacks safeguards, assurances and oversight that would keep our beloved wild herds safe from inappropriate, unscientific and cruel management practices. We have tried to work with the organizations supporting this plan, asking them to add language which mandates that funds be allocated for fertility control and provide for meaningful accountability on the part of BLM.

Sadly, we understand that the proposal will soon be put forward to Congress as-is. This does not end our efforts. We will continue to fight for the protection of America’s wild horses and burros. We are actively working on alternative solutions to this disastrous proposal and we will see the fight through.

We want to thank you all for your support of our mission and our work, and for loving our wild herds as much as we do. Transparency is at the core of meaningful communication and that is why we’d like to explain our concerns about this proposed plan, so you can decide for yourself whether or not it seems right to you.

Our wild horses will need your voice in the coming months, and being informed is the first step in taking effective action. I have learned in my 25 years of advocacy that one passionate voice can make a difference, but an army of informed, passionate voices can create lasting change.

Thank you for standing with us and with our wild ones.

Ginger Kathrens

Founder and Executive Director

The Cloud Foundation

ACCOUNTABILITY

The proposal in its current form provides for no measurable or meaningful accountability on the part of the BLM to carry out their responsibilities. I can tell you from years of discussions and partnerships with the BLM, a mechanism for oversight is essential and needs to be specifically outlined. This includes:

Annual accountability to an oversight committee. It’s important that the American people know where their money is going and how it’s being spent.

A reporting mechanism. To our knowledge BLM has not made an HA status report to Congress since 1995, resulting in an appalling lack of transparency. This last report made 24 years ago listed every western wild horse and burro herd, the population estimate, the appropriate management level, the date of the last census and whether BLM and the Forest Service planned to continue to manage wild horses and burros in the HA.

An outline of allocation of funds. A percentage of the budget must be earmarked for humane, reversible fertility control programs and BLM must be held accountable each year to show they are following through on this responsibility.

A mandate that funds be spent on what they are allocated for, and not diverted to other uses. Money earmarked for fertility control programs must not be used to fund removals, for example.

If removals absolutely must take place, Congress must allocate funds to care for these horses for the rest of their natural lives, unless adopted. We cannot take the chance that a lapse in appropriations down the road could result in thousands of American mustangs being sent to slaughter.

APPLICATION OF SCIENCE

Appropriate Management Level (AML)

Despite over four decades of “managing” our wild horses and burros, BLM has never been able to explain the science behind the calculation of AML. This plan seems to take BLM’s word for it that AML is, in fact, “appropriate”, a very large leap of faith.

As far as we know, AML has never been subjected to peer review, scientific inquiry or validation. In fact, the National Academy of Sciences stated in their 2013 report, “How Appropriate Management Levels are established, monitored, and adjusted is not transparent to stakeholders, supported by scientific information, or amenable to adaptation with new information and environmental and social change.”(emphasis added)

Since the future of our wild herds depends on the ability of this government agency to get it right, BLM needs to justify their AML projections. The 1971 Wild and Free-Roaming Horses and Burros Act mandates that the herds “be managed as self-sustaining populations of healthy animals.” Healthy herds cannot be maintained without each herd meeting the minimum standards for genetic variability (150-200 individuals, per equine geneticist Dr. Gus Cothran). The BLM’s arbitrary AML figures as currently set fail to take these scientific facts into consideration.

Again, the National Academy of Sciences 2013 report, Using Science to Improve the BLM Wild Horse and Burro Program – A Way Forward,stated, “The Cothran studies are excellent tools for BLM to use in managing herds to reduce the incidence of inbreeding…” And yet, the AML of most Herd Management Areas (HMAs) is set well below what is considered to be a Minimum Viable Population (MVP). Reducing some herds to these low numbers endangers the herd, exposing it to biological concerns, illness, birth defects, infertility, and stagnating growth rate, as a result of potential inbreeding.

The proposal cites the NAS report to support its argument that the current BLM practice of large-scale removals has stimulated reproductive rates in wild horse herds but neglects to reference the report’s other valuable recommendations on scientifically managing the growth of these herds in a safe and ethical way. I have to question why, and if this information was excluded because it doesn’t support some of the contributors’ objective of removing tens of thousands of wild horses from our western ranges?

I also question if the genetic viability and diversity of our herds was considered in the construction of this plan? Given the BLM’s mandate to manage our horses in “self-sustaining, healthy herds”, they would be in violation of the law if they did not consider the potential for these unique herds to decline and eventually die out if maintained at current, unsubstantiated low AML numbers. No herd should be managed below the minimum viable population for genetic sustainability. If there is a scientific basis to show that the land cannot support large grazers in these numbers, then an alternative solution for both horses and livestock must be considered—i.e. range expansion to HA boundaries, introduction of wild horses from another similar herd, wildlife corridors to connect small populations, etc.

Protections for herds at or near AML and/or MVP

As written, this plan doesn’t exclude from the proposed massive roundups HMAs that are at or near AML or MVP and/or which have an active fertility control program. HMAs such as the Pryor Mountain WHR, McCullough Peaks, etc. should be exempt from inclusion in this plan. These HMAs are examples of what can be accomplished with a willing BLM team and a committed group of volunteers and should be recognized as such. We could not support any plan that did not include explicit language to exclude these HMAs from the suggested removals.

Forage Allocation

While we understand that BLM has a multiple-use mandate for many of its managed lands, we have to question why the majority of the forage is allocated to privately-owned livestock rather than to the federally-protected wild horses and burros? It seems ludicrous for the American taxpayers to pay millions of dollars for wild animals to be removed from the range, to pay further millions to feed and care for them in holding pens when they were living at no cost to us on the range, and then also to pay to subsidize private ranching on public lands. Whom does this serve? Only one group of stakeholders benefits from this arrangement, and we don’t need a peer-reviewed study to see who it is. So, a discussion of forage allocation is long overdue!

Maintaining Healthy Rangelands

It would be impossible not to acknowledge the diminished quality of rangelands due to climate change, human disruption of fragile ecosystems, and usage by multiple stakeholders, including energy development and large grazing animals – privately-owned livestock included. In some cases, wild horses and burros have been marginalized on lands that are not fit for cattle, sheep or horses. That being said, the way in which horses use the land differs greatly from the way cattle do, and thus their impact is very different.

Contrary to what private interests and BLM would have us believe; science supports the fact that horses do not have the same detrimental impact on our rangelands. This is true despite their grazing not being “managed” in timing or intensity, because horses are constantly on the move.

Cattle, as ruminants, hang out near water, congregating in one area for hours at a time. Theirs is a sedentary lifestyle. They are not upland grazers; they stay near a water source, defecate in the water and pollute it for all other species. Due to their lack of movement, they erode and denude the soil surrounding water sources and leave piles of feces concentrated in these areas. By contrast, the digestive system of the horse requires it to move. Typically, horses trail in to water, drink their fill, and move on. In 25 years of wild horse documentation, I have seen only one horse defecate in water and this was a tiny foal.

Interestingly, a rancher recently told me that his father used to let a few horses out with their cattle herd to help keep them moving, indicating that horses can act to the benefit of an ecosystem and even help mitigate the impact cattle have on the land. Horse droppings are also biodegradable and enrich the soil, whereas cattle droppings have high concentrations of methane and have detrimental effects on both soil and air quality.

As a life-long advocate for our public lands and all wildlife, I was dismayed to find that this “management plan” does not once mention livestock, a major player in range degradation. If we are truly looking for a viable solution to create healthy open range ecosystems, all factors must be considered. All sides must compromise. What, I ask, are the private ranching interests compromising on in this plan?

EFFECTIVE, HUMANE POPULATION CONTROL PROGRAMS

Helicopter Round-ups

The Cloud Foundation does not support helicopter round-ups in any HMA, and I don’t believe you would either, if you had the chance to observe one in person from a nearby vantage point . Helicopters harass terrified horses, driving them for miles across rough terrain. Horses injure themselvesin their panic, tiny foals fall behind. Many horses die after the fact as a direct result of the exertion, and pregnant mares can abort their foals. The bodily and psychological trauma is appalling. Their family structure is shattered, the very fabric of wild horse society is destroyed.

Round-ups are not just a financial burden to the American taxpayer, they are an unconscionable misappropriation of tax dollars. They are an intentional money funnel – directly into the pockets of government contractors and lobbyists. Follow the funds – it is cronyism at its worst. It is an industry governed by greed, not by conscience or even policy. Contractors are paid by the number of horses they can catch, which ensures they do everything in their power to drive the horses into those traps, regardless of the cost to the animals, resulting in some of the most horrific examples of animal abuse I’ve ever witnessed.

Public opinion is strongly with the wild horse advocate community on this issue. The vast majority of Americans are staunchly opposed to having their mustangs stampeded, traumatized, injured and killed. This is the reality of a helicopter round-up: dead foals and injured horses, mares spontaneously aborting, stillborn foals, and inaccurate reporting of “previous existing conditions” such as broken backs (a direct result of the roundup) resulting in euthanasia of previously healthy horses.

There is also a degree of sadism I have observed with certain individuals in these roundup crews—i.e. deriving pleasure from being cruel by hot-shotting burros in the face and genitals, hot-shotting horses when they are already moving in the desired direction, and kicking animals that are flailing on the ground. BLM must take responsibility to ensure the safety of these animals, and independent supervision with real consequences for any cruelty to the animals is imperative.

Humane Population Suppression

BLM has historically demonstrated an unwillingness to try humane fertility control measures that are acceptable to the American people in the majority of HMAs. Advocate groups have a legitimate concern that without strict accountability mechanisms and congressional oversight, BLM will take the additional funding and spend it all on round-ups, funneling tens of thousands more horses into an already unsustainable holding system.

We cannot stress enough that the HMAs that have already successfully implemented humane measures of fertility control should be exempt from the provisions of this plan. They should be used as exemplars for how to start, organize and implement darting programs for fertility control. These programs should be initiated through the HMAs.

To ensure that BLM fulfills its duty to implement fertility control, a percentage of the additional funding must be specifically earmarked for these programs, and clear language must be included to identify the acceptable methods of humane, reversible fertility control: (Zonastat H darting, PZP 22, and GonaCon).

These programs require meaningful observation and documentation of herds over time. Genetic variability must be thoughtfully considered, giving all mares the opportunity to contribute to the gene pool, ensuring a self-sustaining, healthy herd. There must be specific consequences if the BLM fails to carry out all the necessary steps to set-up and implement successful darting programs.

Natural Predation

This plan surprisingly makes no mention of natural population controls (i.e. natural predation). Over the years, wildlife services has killed or caused to be killed many of the horses’ natural predators. In the Pryors, mountain lions did an extremely effective job of keeping the herd at zero population growth. There were years in which nearly all the foals were killed by predators, until BLM encouraged the killing of the mountain lions, necessitating a return to human control of wild animal reproduction.

If our goal is a naturally balanced ecosystem, the plan should include support for the predator-prey relationship.

Forging a New Path

What is our vision of what our public lands might look like decades from now? The goal for our wild horses is the same as it should be for all wildlife populations: whenever and where possible–let nature call the shots. We would support a collaboration in which creative plans and intelligent, out-of-the box thinking is invited. Further dialogue on this very complex issue is necessary and all stakeholders should have a seat at the table.

We know that we can count on you to lend your voice, as needed, to champion our wild families, who cannot speak for themselves. We encourage you to contact your representatives and senators and urge them not to support this proposal as-is.

Our hope is that through collaboration we can craft a plan that protects the future our wild herds, the health of our public lands, and holds BLM accountable for implementing humane, reversible fertility control programs moving forward.