Compiled by Grandma Gregg
* Issuance of a moratorium of roundups in all situations while the entire Bureau of Land Management Wild Horse & Burro Program undergoes objective and scientific audit and review – i.e. a Congressional Investigation. The 1971 law clearly states they are not to be captured.
* All biological and physical interference (medical and pharmaceutical procedures such as sterilization and PZP and castration) must be stopped. The 1971 law clearly states they are not to be harassed.
* Over the past 46 years, tens of thousands of wild horses and burros have been removed from western rangelands based on claims of “excess”. The BLM has little to no credible data to justify its management actions. Require absolute accountability and transparency for Congress and the tax-paying public including proof of the BLM’s on the range and off the range census – both current and past. The BLM needs population estimates to determine whether and where excess wild horses and burros exist, and, if there is an excess, how many animals need to be removed from any public rangelands.
Population estimates also guide the BLM in applying fertility control to mares and adjusting herd sex ratios in favor of stallions or geldings to reduce on-the-range births. “‘Excess’ refers to that number of large herbivores exceeding the number that (a) allows a range ecosystem to exist at some condition approaching its potential productivity, or prevents it from becoming as productive as feasible” (NAS 1982) “Conclusion: The management of wild horses and burros would substantially benefit from improved accuracy in estimating population sizes and trends.
This should be a priority for the BLM and its collaborators, given the importance of accurate population estimates to all aspects of wild horse and burro management.” (NAS 1991) Accurate determination of the annual rate of increase depends on the ability to accurately count wild horses and burros or estimate their population size. BLM is engaged in management actions that are not based on a credible, accurate count of wild horses and burros; many of its current counts are inaccurate due to deficiencies in its census methodologies.
* An increase in the range of these wild horses and burros back to the areas they roamed in 1971 including all original herd area lands; “where found” when the law was passed. All estimated 53 million acres (42 million, BLM managed) of original designated Herd Area land is completely suitable for the long term “management” of wild horses and burros although nature is more than qualified to “manage” these wild animals without BLM or any human management. This legal wild horse and burro land could easily and naturally support about 250,000 wild horses and burros.
* Return all WH&B from long and short term holding back to their legal herd area land for the reason that they were captured and removed from their Congressionally designated lands illegally because the populations statistics used to justify the removals were and are not scientifically supportable and are not scientifically defensible and therefore not credible.
BLM field managers and wild horse and burro specialists must base management decisions on accurate and credible population estimates and refusal to do this makes all BLM’s capture/removal actions illegal.
* Almost every management issue concerning wild horses and burros depends on accurate population estimates. Reliable, science-based estimates are needed for maintaining everything from herd health to habitat carrying capacity to genetic diversity. Scientifically supportable and defensible population estimates of wild horse and burro populations are not accomplished by BLM. Because population estimates drive nearly all management decisions pertaining to wild horses and burros, accuracy is vital. “The BLM clearly recognizes that its census methodologies may not be providing accurate estimates.” (1991 NAS)
“The accuracy and precision of current wild horse survey methods have not been rigorously tested.” (2013 NAS) “At present, the accuracy of the majority of BLM’s population estimates is suspect.” The BLM’s aerial and ground surveys are not scientifically supportable and not defensible and therefore not credible. (tools such as Go-Pro on all census flights and photographing/filming of all wild horses and burros found during on the ground censes taking).
Wild Horse Freedom Federation White Paper, “…BLM’s growth estimates and population increases on specific HMAs is biologically impossible and scientifically absurd. The BLM has reported, on more than one occasion, statistics that would establish a 750 to 1250 percent increase in population over the course of a year.”
* Remove all Appropriate Management Levels (AML) for wild horses and burros on rangelands designated for them and replace it with nature’s true ecological balance of the lands. Allow for ecological balance through acknowledgment of the thousands of years that nature “managed” these lands and incorporate true ecological methods and the removal of private/corporate for-profit domestic livestock.
Achieving justice for our wild horses and burros depends on BLM officials exercising their authority to legally reduce private, usually corporate, domestic livestock grazing in the wild horse and burros’ legal areas, whether on BLM or USFS lands. Such exercise would be legally covered under 43 Code of Federal Regulations (C.F.R.) 4710.3-2 and 43 C.F.R 4710.5(a). In particular, 43 C.F.R. 4710.5 clearly states that the Bureau of Land Management can legally reduce livestock grazing in order “to provide habitat for wild horses or burros.”
- 4710.5 Closure to livestock grazing.
- If necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury, the authorized officer may close appropriate areas of the public lands to grazing use by all or a particular kind of livestock.
* By law, wild horses and burros are subject to roundups when there are “excess” animals on the range and when the excess animals are preventing achievement of a “thriving natural ecological balance” (TNEB) and/or when they are on private lands outside of existing Herd Management Area (HMA) boundaries. There are a number of scientific issues that ostensibly contribute to the decision to conduct a roundup.
The BLM considers wild horses and burros to be excess when their population size is above the high Appropriate Management Level (AML) set for the HMA and yet many HMAs and all HAs have already been zeroed out. When determining excess, the BLM is required, by law, to look beyond mere AML (many of which are outdated or of questionable veracity) and population estimates (which are also often inaccurate) to consider rangeland condition as a litmus test for evaluating whether a TNEB exists.
Yet few BLM roundup analyses contain more than speculative assertions over what impacts are attributable to wild horses and burros, without site-specific evidence that such impacts are real. Consequently, to legitimately determine if an excess exists, the relevant scientific factors must include an accurate population estimate of wild horses and burros.
Let’s face it … the only persons that have worked for 46 plus years for the extinction of wild horses and burros are those with a financial interest. This has been and continues to be unacceptable, illegal and the American citizens are disgusted at the “sell-out” of our lands and resources by the USFS and the BLM agencies that are responsible to PROTECT them.
“Overview of the Management of Wild Horses and Burros” A report presented to the National Academy of Sciences Committee to Review the Management of Wild Horses and Burros Prepared by: Animal Welfare Institute October 2012 https://awionline.org/sites/default/files/uploads/documents/FinalWildHorseandBurroReportWithStateMaps10-26-12.pdf
Cornell Law School 43 CFR 4710.5 – Closure to livestock grazing.
Wild Horse Freedom Federation White Paper (page 35)
Report: WILD HORSE POPULATION GROWTH by Gregg, LeBlanc & Johnston