Horse News

“Think Tank” pinpoints problems with Dept. of Interior’s resource fees


Report compiled by Lisa LeBlanc

Sometimes, when exploring for the Perfect Morsel with the hope that it that might bring about actual changes in the myriad issues surrounding wild horse and burro policies, we find ourselves in some unexpected places, and discover that even people & organizations of opposing beliefs can have a common ground.

The Cato Institute is portrayed as a “Libertarian think tank,” an organization which was founded in 1974 by, among others, Charles Koch.

The Institute’s website states, “The mission of the Cato Institute is to originate, disseminate, and increase understanding of public policies based on the principles of individual liberty, limited government, free markets, and peace.”  And “…offers guidelines on Federal programs that should be terminated, transferred to states or privatized…”

A few years ago, Chris Edwards, a budget expert and Director of Tax Policy Studies for the Cato Institute and other contributors wrote a book entitled “Downsizing the Federal Government.”

Even with legitimate concerns regarding proposals to grant states management over wild horses and burros, there are other areas upon which we might find ourselves in agreement with the book’s authors.  Specifically, addressing those agencies charged with management of wild horses and burros and other wildlife (although not all are compelled to adhere to the tenets of Public Law 92-195,’The Wild Horse and Burro Act’).

It’s perplexing to wild equine defenders as to why Public opposition to current ‘management’ of wild equines, compelling independent studies – even Congressional inquiry –almost unilaterally fail to make a dent in this Program which administers to wild horses and burros, now long gone off its original course.

Unquestionably, the offshoot of a ponderous and impossibly huge vehicle that consumes resources everywhere it goes and generally, gives very little back.

Keep in mind – this source matter, like the unauthorized works of research for wild horses and burros – was neither commissioned nor paid for by a Federal agency, so it might be considered somewhat… accusatory.

Below are a few excerpts from the book.

(Under ‘Interior: Reforming Federal Land Management’)

The Bureau of Land Management (Allocated $1.2B for FY 2014):

“The fundamental problem in managing these needs today is one of poorly designed incentives. Rather than give the BLM a clear mission that produces rewards when the agency accomplishes the mission, Congress governs the agency with a hodgepodge of laws, funding mechanisms, and expectations.  Rather than trying to price the use of federal resources to encourage efficiency, the BLM often subsidizes resource use.

BLM—and Interior in general—often bases prices for the use of its resources on political, historical, and administrative factors, not on market valuations.  As such, the prices and fees for grazing land, mineral resources, and timber are often set artificially low.”

“BLM’s policies create bad incentives not just for the users of federal lands, but also for BLM managers.  The rules for the share of fees that can be retained by the BLM, for example, are not consistent.  At various times in recent history, the BLM has been allowed to keep 25 percent of timber revenues collected in western Oregon but none elsewhere.  It can keep 50 percent of grazing revenues, but no recreation revenues, except in a few locations where it can keep 100 percent.  The BLM is allowed to charge 100 percent of fair market value for coal, oil, gas, and timber, but the fees it can charge for hardrock minerals (other than coal), grazing, and recreation are regulated by Congress and are usually well below market value.  Following its incentives, the agency tends to focus its attention on resources that produce revenues it is allowed to keep but neglects other resources.

A related problem is that special interest groups have persuaded Congress to give them a share of BLM revenues, and they lobby hard to keep those privileges.  For example, in most places counties receive 5 percent of BLM revenues, but in western Oregon they have historically received 50 percent of BLM timber revenues.  When BLM timber sales declined by nearly 90 percent in the early 1990s (partly in response to the listing of the northern spotted owl as a threatened species), the western Oregon counties persuaded Congress to nonetheless maintain payments at high levels.  The result is that today the BLM collects about $20 million a year from timber sales in western Oregon, but Congress pays about $100 million a year to manage those forests, plus another $100 million a year to the counties in the region.”

The National Park Service (The biggest spender of Interior’s budget- $3.2B for FY 2014):

“Note that user fees collected on a few of the national parks cover all or nearly all of the costs of operating those parks.  But the NPS makes no general effort to cover its costs, and it has no incentive to try.  Instead, the NPS regards user fees solely as a way to augment its budget on top of the taxpayer funding that is appropriated by Congress. “

“An interesting historical episode at the NPS led to the coining of the phrase “Washington Monument strategy.”  The phrase describes the bureaucratic tactic of responding to proposals for budget restraint by cutting the most popular programs first.  It was coined when the NPS shut down the elevator to the Washington Monument in 1969 in a successful effort to persuade Congress to restore budget cuts.”

“In his 1987 book, Playing God in Yellowstone, Alston Chase described how park rangers were effectively police officers, not scientists or naturalists.  The training that allowed employees to advance most rapidly within the agency was police science, not history or natural sciences.  The agency’s police culture has manifested itself in many incidents:

  • In 1992 the NPS wanted to acquire land for a California park from an unwilling seller, so it fabricated charges that the property owner was growing marijuana in order to obtain the land through asset forfeiture.  A SWAT team invasion led to the property owner’s death, but no illegal drugs were found.
  • In 2004 the NPS wanted to shut down an Indian trader who operated in the Hubbell Trading Post National Historic Site, so it accused him of a long list of crimes.  A detailed investigation found that most, if not all, of the charges were fabricated.
  • In 2011 the NPS wanted to shut down an oyster grower who operated near Point Reyes National Seashore in California, so it misused data to claim that the oyster farmer was polluting the water.
  • Also in 2011 the NPS generated controversy by arresting people at the Thomas Jefferson Memorial in Washington for dancing, which was deemed “inappropriate.”

Fish and Wildlife Service ($2.9B in FY 2014):

“The FWS’s most controversial program is enforcement of the Endangered Species Act.  This law has a noble goal but an ill-considered methodology that puts most of the cost of endangered species recovery on the owners of the land the species happens to live on.  The FWS lists more than 1,300 domestic species as threatened or endangered, but its endangered species budget of less than $200 million is barely enough to monitor these populations.  A substantial share of that amount is dedicated to “recovery,” which really means writing recovery plans, not actually doing anything to recover species.  Actual recovery efforts are left to other entities, which the FWS calls “partners and stakeholders.”  But many of the “partners” are unwilling private landowners and unenthusiastic public land managers.”

“The FWS’s wildlife refuges are less controversial.  Most of those located in the lower 48 states are marshes and other habitats for migratory bird species.  The agency could do much more to generate revenues to make these refuges financially self-sufficient, but it has little incentive to do so since Congress gives it taxpayer funds to run them.”

(Under “The Department of Agriculture”)

The Forest Service ($6.5B in FY 2014):

(Note: In conjunction with the Bureau of Land Management, the Forest Service manages 37 wild horse and burro ‘territories’;  according to listings on the FS website, some populations are extremely small or non-existent. Information is spotty and poorly represented.  The web pages on wild horses and burros have not been updated in over a year.

Often, BLM Environmental Assessments to remove wild equines will include some mention regarding ‘wild fires’ as an adjunct – an enhancement – in documents issued for wild equine removals.)

“Downsizing the Federal Government” outlines why the Forest Service should be reformed, though the author’s rationale targets the Timber Program and the intense focus on ‘fire activities’:

“…in 2000, when a fire burned more than a billion dollars’ worth of homes in Los Alamos, New Mexico, Congress responded by giving the Forest Service a whopping 38 percent increase in its 2001 budget…”

Fire expenditures have grown from about 10 percent of the Forest Service budget in the early 1990s to more than 40 percent today.”

“…much of the spending on fire activities is as questionable as the Forest Service’s earlier timber programs.  National forest fire problems are not as bad as the Forest Service claims; hazardous fuels are only a major issue on about 15 percent of federal lands in the West. “

(Emphasis above added)

Based on the points outlined, we might consider – what “incentives” drive the management of wild horses and burros?  Could a reasonable allocation of funds applied to thoroughly monitoring these animals on the ground bring the soaring cost of the Program back to Earth?  Could in-house resource use – for example, hay grown by BLM for short term holding facilities or the use of BLM helicopters/pilots – mitigate contractor costs and allow field offices to become more self-sufficient?  Are plans for beneficial changes in wild equine management held in abeyance to remain perpetually in the “planning stages?”

And perhaps, most important – is the Wild Horse and Burro Program truly in jeopardy or simply a casualty of “… political, historical, and administrative factors…?”


The eBook can be read or downloaded here:


List of Forest Service Wild Horse and Burro Territories:

34 replies »

  1. THANK YOU, Lisa, Precisely the same conclusions drawn by our Think Tank here.
    A perfect example is the Categorical Exclusion (if all else fails, use the Categorical Exclusion)

    BLM’s Use of Section 390 Categorical Exclusions for Oil and Gas Development
    GAO-11-941T: Published: Publicly Released: Sep 9, 2011.

    GAO reported that BLM’s use of section 390 categorical exclusions through fiscal year 2008 often did not comply with either the law or BLM’s guidance.
    First, GAO found several types of violations of the law, including approving projects inconsistent with the law’s criteria and drilling a new well after mandated time frames had lapsed. Second, GAO found numerous examples where officials did not correctly follow agency guidance, most often by failing to adequately justify the use of a categorical exclusion.

    A lack of clear guidance and oversight contributed to the violations and noncompliance.

    Many instances of noncompliance were technical in nature, whereas others were more significant and may have thwarted NEPA’s twin aims of ensuring that BLM and the public are fully informed of the environmental consequences of BLM’s actions.

    GAO’s analysis of BLM field office data showed that section 390 categorical exclusions were used to approve almost 6,900 oil-and-gas-related activities from fiscal year 2006 through fiscal year 2008. Nearly 6,100 of these categorical exclusions were used for drilling permits and the rest for other nondrilling activities. Most BLM officials GAO spoke with said that section 390 categorical exclusions increased the efficiency of certain field office operations, but it was not possible to quantify these benefits. GAO reported that BLM’s use of section 390 categorical exclusions through fiscal year 2008 often did not comply with either the law or BLM’s guidance. First, GAO found several types of violations of the law, including approving projects inconsistent with the law’s criteria and drilling a new well after mandated time frames had lapsed. Second, GAO found numerous examples where officials did not correctly follow agency guidance, most often by failing to adequately justify the use of a categorical exclusion. A lack of clear guidance and oversight contributed to the violations and noncompliance. Many instances of noncompliance were technical in nature, whereas others were more significant and may have thwarted NEPA’s twin aims of ensuring that BLM and the public are fully informed of the environmental consequences of BLM’s actions.


  2. Thanks for compiling this information, Lisa! I notice there aren’t any comments yet. These discoveries aren’t as sensational as other topics, but indicate the DOI/BLM/NPS and USDA/FS history of multiple fails and their culture of secrecy. The BIA is equally rotten. Sounds like the OIG can be as well. MAJOR inter-agency butt-covering! I live next to the Navajo reservation, so the Hubbell Trading Post case is of particular interest. I found a link to info on the case from the fearless folks at PEER. Btw, in one of NPS articles I read on about Hubbell, a couple of people mentioned the cessation of mule rides at the Grand Canyon should be investigated as well.


  3. And once again, the Categorical Exclusion is being used to wipe out what’s left of America’s few remaining Wild Horses in Wyoming:
    According to the BLM’s tentative gather schedule and its CATEGORICAL EXCLUSION for the roundup, the agency will remove between 800 and 946 wild horses from the Adobe Town, Salt Wells and Divide Basin HMAs, a move that will leave two of the three areas well below the AMLs established by the BLM’s land use management plans. For example, the Divide Basin HMA would be left with just 224 horses after the roundup, far below the area’s established AML of 415-600 wild horses. AWHPC maintains that the BLM cannot bring the area below AML without changing the Resource Management Plan for the area, something the agency proposed in a scoping notice, but has not moved forward with. Additionally, the agency has failed to analyze the impacts of the proposed action, as required by the National Environmental Policy Act, through an Environmental Assessment. Rather it is proceeding with the removal of nearly 1,000 horses on the basis of a categorical exclusion, something that precludes public input and comment on the action.


  4. One note of caution on this report.
    It’s doubtful that our FEDERALLY PROTECTED Wild Horses and Burros, Wildlife or Resources would be any safer if Public Lands were under state or private control.


  5. They sure wouldn’t be any better off under state control in Utah.
    Begining July 28, 2014

    Goal of Roundup:
    The BLM plans to gather and remove an estimated 140 wild horses from the Blawn Wash Herd Management Area (HMA), one of four HMAs that make up the Bible Spring Complex. Gather operations will also extend to the adjacent Highway 21 area, where wild horses are causing traffic hazards. It is estimated that an additional10-30 horses could be removed from public lands along Highway 21 for safety reasons. Animals removed from the Blawn Wash HMA and Highway 21 will be available for adoption through the BLM Wild Horse and Burro Adoption Program. Those that are not adopted will be cared for in long-term pastures, where they retain their “wild” status and protection under the 1971 Wild Free-Roaming Horses and Burros Act.

    Details of the Roundup:
    Members of the public are welcome to view the daily gather operations once they begin, so long as the safety of the animals, staff and observers are not jeopardized and operations are not disrupted. During the gather, interested public may participate in an escorted tour by meeting at the KB Express Convenience Store/Subway at 238 South Main in Milford, Utah and must be ready to leave at 5 A.M. sharp. The dates and departure times are subject to change depending upon weather and gather operations. The public is strongly encouraged to check the gather hotline nightly at 435-865-3030 for changes in schedule. Participants must provide their own transportation, water and lunches. The BLM recommends that the public dress for harsh field conditions. Binoculars and four-wheel drive, high clearance vehicles are strongly recommended.
    Latest News:

    For BLM news releases and statements issued about the Blawn Wash Gather, check our Newsroom.
    The four Herd Management Areas that make up the Bible Spring Complex—Bible Spring, Blawn Wash, Tilly Creek and Four Mile—are located in western Iron and Beaver counties, approximately 30 miles west of Minersville, Utah in the Wah Wah and Indian Peak mountain ranges. The Bible Spring Complex is approximately 222,929 acres of public, private and state lands.


  6. Inetrsting prospective on the fire monies being allocated. We have a fire in our county. The new vehicles, and heavily equipped fire boys far out weigh the dangers. And let me add here, that the smoke jumpers and the men shoveling the fire breaks from my day were a bit more adept at moving quickly and bravely then the present day muscle bound pretty boys sitting in the high seats of the decked out heavy duty vehicles. Sure, they got a bigger budget – MUCH bigger.

    Thanks for the additional thinking material Lisa.


    From PEER (Public Employees for Environmental Responsibility)

    After Years, Fish & Wildlife Service Still Unprepared to Propose Specific Safeguards
    Posted on Apr 24, 2014
    Washington, DC — Despite admitting “significant damages” from oil and gas operations on national wildlife refuge lands, there are still no safeguards against spills, leaks and other preventable contamination of these preserves. The responsible agency is still on the ground floor of adopting protective rules years after announcing that it would, according to Public Employees for Environmental Responsibility (PEER).

    The U.S. Fish & Wildlife Service (FWS), which operates the network of 562 wildlife refuges, estimates oil or gas deposits exist on nearly half of all refuges; more than 200 refuges contain oil infrastructure with more than 100 active drilling operations, including 1,700 active wells and 1,300 miles of pipeline. Altogether, drilling on refuges accounts for approximately 1% of domestic production.

    Unlike other federal land agencies, FWS has no rules governing basic safeguards such as spill prevention, reclamation bonds or requirements that best management practices be employed. In April 2011, PEER filed a formal rulemaking petition urging FWS to adopt rules modeled on enhanced rules then proposed by the National Park Service. More than a year later in June 2012, FWS announced that in response to the PEER petition it would begin “promulgating regulations for administering private minerals on refuge lands” and would “conduct a thorough… analysis of the proposed regulations, most likely resulting in an Environmental Impact Statement (EIS).”
    For months, there was no public activity until a Federal Register notice of February 24, 2014 in which FWS issued an advance notice of proposed rulemaking and notice of intent to prepare an EIS, declaring:

    “The Refuge System has sustained significant damages to refuge resources from leaks and spills, inadequate plugging, abandonment and reclamation.”


    • You must be a speed reader. This article reminds me another that reviewed BLM’s activity in closing wells on federal land which were found to be leaking contaminants, sometimes chemicals, into groundwater. The report revealed BLM was not even aware of what defined a well that was dangerous. They have a long way to go and we know they have not gotten to any level of credibility managing the wild horses and burros. Although they are very good at spending the money Congress throws at them.

      Sent via BlackBerry by AT&T


    Effects on Resources

    Oil and gas exploration and production activities can cause both direct and indirect effects on refuge resources.
     Leaks and spills of oil, brine, or other contaminants are a key concern. Soils, vegetation, water quality, fish and wildlife, and air quality can all be harmed by the release of contaminants.
     Fish and Wildlife Habitat can be altered, fragmented, or eliminated. Oil and gas activities can disturb and displace wildlife, cause physiological stress, and can even result in wildlife deaths.
     Introduction of invasive species, especially along road and pipeline routes, can alter habitat. Disturbance caused by oil and gas activities can result in fundamental changes in ecological functions and processes, and lead to increased predation of declining species, reduced reproduction, and increased susceptibility to disease.
     Public use of refuge areas may be restricted or prohibited. Although the areal extent of oil and gas exploration and production may be limited, the cumulative effects may extend to a much larger area.



    Here is the link to the notice posted on the Federal Register

    Fish and Wildlife Service/Department of Interior
    Monday June 9, 2014

    Click to access 2014-13303.pdf

    Non-Federal Oil and Gas Development Within the National Wildlife Refuge System
    Pages 32903 – 32903 [FR DOC # 2014-13303] PDF | Text | More


  10. so if and or are so corrupt why is the round up still going to take place ? without the house of represenatives overseeing all of their actions ? so much history has not gotten anyones attention so now how are we suppose to know who’s rules we are supposed to follow or who to even go to because i have found in texas nobody listens and now with the influx of illegals even less so , so now how do we continue this make this go in favor of the wild horses ,burros for a winning postition for them . they should have been winning this fight all along from the beginning of this fiasco.



    Federally Protected Wild Horses and being captured and removed, BUT
    Oil and Gas Drilling is allowed?

    “Federal law states that no recreational or commercial use shall be permitted on these lands unless the Secretary of the Interior determines that these activities are compatible with the primary purposes for which Refuges are established.”

    Part [E7] Grazing Laws National (US) Wildlife Refuges

    National Wildlife Refuges (NWRs), administered by the US Fish & Wildlife Service, are the only federal lands in the US where wildlife has officially been given higher priority than recreational and commercial activities.

    Federal law states that no recreational or commercial use shall be permitted on these lands unless the Secretary of the Interior determines that these activities are compatible with the primary purposes for which Refuges are established.

    As of 1991, 156 of the 368 NWRs in the 17 Western states and Pacific Islands allowed commercial livestock grazing and/or haying ((91J1) p. 470).


  12. Found this tonight… interesting that a large annual deer migration through the Red Desert evidently remained virtually unknown until 2012. What else don’t they know about the ecosytem there???


    • Icy – amazing! Imagine these animals going 150 miles with all the hazards & fences. And this migration is pretty much unknown. Wow! Seems there is still much to be learned about our ecosystem. Hopefully, it wont be completely destroyed by the cattlemen, BLM, AND politicians! Wouldn’t you think humans would have learned something after the Dust Bowl in the 30s?


      • Maggie, agreed! I take hope, however, in the innate wisdom of nature as shown here… the creatures who share our world are not two-dimensional and (like we hopefully are) continually evolve and speciate in response to their environs.


  13. This just in, from ‘Howling for Justice’: This is exactly what we – and all those who advocate for wild things – are up against…
    “Dan Ashe, the director of the USFWS, recently stated… “that he sees a “giant clash” between those who favor conservation and those who favor economic development…”
    “… he believes that conservationists “must accept a world with fewer wolves, salmon, and spotted owls.
    ”The Director of the very agency most responsible for protecting the nation’s biodiversity went on to say that, in the name of compromise, we must accept “a world with less biodiversity.”
    Bull. Sh*t.


    • Oh he does NOT get it. These guys are so in love with themselves, they do NOT get it. We need to dump these workers and put in their place citizens.

      The difference? One understands stewardship, the other grew up in a garbage dump.
      Sent via BlackBerry by AT&T


  14. Thank you, Lisa … and everyone who continue to think and speak up. One problem is that most of these supposed stewards of our land and resources do get it … but what they “get” is only the money part of the issue and that is their only interest and priority and that is how and why they got and keep their jobs and are promoted to positions of power.

    How long do you think Sally Jewell (for example) would keep her job if she spoke out for PROTECTING the wild horses and wild burros and other wildlife and our other publicly owned resources?
    Why do you think that Ginger Kathrens and R.T. Fitch and Craig Downer were not chosen to be on the Wild Horse and Burro Advisory Board?
    Why do you suppose that thousands of our WH&B have been removed from their legal land – and “disappeared”?
    Why do you suppose that hundreds and hundreds of our captured WH&B still stand in BLM’s inhumane conditions this very minute?
    Why do you suppose that the many investigations into illegal “trafficking” and killing of our WH&B are being covered up?
    Why do you suppose that BLM & USFS continue to remove our WH&B from their land when we know there are no excess WH&B on their legally authorized land?

    Money – Money – Money … BIG MONEY!


    • GG, what if we could get Pres. Obama to tour the HMAs? He and Joe Biden are on record as being anti-slaughter and neither has any exposure I am aware of to wild horses. The President could weigh in and make major changes without an act of Congress… because WE ALREADY HAVE AN ACT OF CONGRESS protecting WHBs! It seems he could perhaps return us all to the original letter and intent of the law, or amend the pernicious amendments which have and continue to make a mockery of the original law. Since Obama won’t run again he has nothing to lose really, and is not beholden to ag interests much (I am supposing) since he self-identifies as an urban community organizer.


  15. A visit to a nursing is a good dose of reality. Money and power mean nothing at the very end….NOTHING. The only thing that remains are memories of the time spent on this Earth and the other lives that have been touched by your life.
    All the outer layers have been removed by the time one reaches old age.
    Those that have misused their time and energy will have to live with what they have done…there is no escaping self.
    There is a very good reason for doing the right thing.
    Peace of Mind does not come with a price tag.


    • All very true, Louie. I just hope those of us who have tried to do the right thing can manage to stop those with money and power from misusing our whole ecosystem. Its getting pretty scary having to watch what’s being done to OUR animals and the world we live in.


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