DANGEROUS, SIMPLISTIC, UNREALISTIC
A REBUTTAL TO A PROPOSAL TO CONGRESS BY INEXPERIENCED AND UNKNOWLEDGEABLE NON-PROFIT GROUPS AND RANCHERS
by Bonnie Kohleriter
AUTHORS OF THIS PROPOSAL:
The ASPCA, HSUS, Return to Freedom (RTF), American Mustang Foundation (AMF) as well as ranching groups are authors of this proposal. It is known the public land ranchers want as few horses as possible on our public lands because of the competition for forage, but the ASPCA and HSUS are well known animal rights groups, supposedly supportive of wild horses.*
However, the ASPCA has been mainly involved with cats, dogs, and domestic horses with no experience in BLM wild horse corrals and pasture operations, no experience with on the ground PZP programs, no experience with on the ground adoption-purchase transactions, and no experience in operating sanctuaries.
Likewise, the HSUS is comparatively the same in no experience as the ASPCA though they have participated in two failed large herd sized PZP delivery operations… the Sand Wash herd and the Cedar Mtn. herd…and they have two sanctuaries holding various animals, not exclusively mustangs.
Return to Freedom is just one of the nation’s horse sanctuaries in Lompoc, California, is full, doesn’t have room for one California wild horse or burro, and operates in the red according to Guidestar. The American Mustang Foundation is a new organization supposedly a lobbying organization about whose activities little is known to date and shows no known experience in housing wild horses.
In spite of their lack of any or of any successful experience with the solutions proposed for the wild horses and burros, these groups want to speak with authority as to what should be done economic, humane and feasible wise after quickly removing 50,000 animals from 27 M acres of our public lands. There’s no cost analysis in this report, humane is dubious for both those left on the range and those off the range, and feasible, providing no substantive evidence of proof and with providing already failed trials, presents an invalidation of much of the usefulness of this report as a way forward.
OBJECTIVES OF THIS PROPOSAL
The objectives of this proposal are to develop an economically viable, humane, and feasible long-term management plan for the BLMs wild horse and burro program.
PRESENCE OF WILD HORSES AND BURROS ON OUR PUBLIC LANDS
This report appears to accept the following:
- 27,000 wild horses and burros are only able to be on 27 M acres of our public lands called AML or Appropriate Management Levels.
- 87,885 animals are currently on those public lands as of 2018. (updated from 2017)
- To return to 27,000, a three or ten year plan of removals is endorsed…3 years of 20,000 and 5 years of 12,000.
The 27,000 number is an arbitrary number. The 1971 law did not specify an allowable number. No recorded evidence of 27,000 wild horses and burros allowed is recorded around 1971. The BLM says it uses “scientific principles of rangeland management” to determine the population of wild horses and burros that the habitat can sustain.
In chapter 7, Using Science to Improve the BLM Wild Horse and Burro Program, the National Research Council of the National Academy of Sciences debunks the idea scientific principles are used to determine populations and suggests it has more to do with values and politics.
The BLM claims it has 177 HMAs or Herd Management Areas. A closer look reveals some HMAs have no horses or burros in them, some are double counted, some have been combined, and some are not managed by the BLM. The BLM actually appears to have only 160 HMAs. (See addendum)
Dr. Gus Cothran of Texas A & M, the retained geneticist for the BLM, has said 150-200 wild horses with 50 effective breeding animals need to be in a herd for genetic variance and diversity and for viability over some time. (See BLM Handbook) Some herds have only horses or burros in them and others have both.
138 horse herds exist with only with only “38” of them having AMLs above 150 and 30 burro herds exist with only “3” of them having AMLs above 150. (See Addendum 2) So if the numbers are brought down to 27,000, 78% of the horse herds and 90% of the burro herds will be at risk for loss of fecundity, at risk for anomalies or deformities, and at risk of ultimate extirpation.
Add to the removals the use of suggested PZP on all the mares, sterilization of some of the mares and sex ratioing of 70% stallions to 30% mares. That will lower even more the number of breeding animals heightening even more the threat of the continuance of the herds. Is this acceptance of numbers on the range and the use of PZP on all of the mares, sterilization and sex ratioing “humane” knowing the risk to extirpation as a herd or extinction as a group of herds. A loss of 78% and 90% and more isn’t feasible long term management. It is devastation of the herds.
For the moment accept 50,000 wild animals are already removed and 50,000 more will be removed within 3-5 years. It cost $6M to gather 11 thousand last year so it may cost $6-$12 M a year to gather on the 3-5 year plan. It cost $50-$60 M to house 50,000 last year so it may cost $100 M to house 100,000. Then we have the costs of PZP, of adoptions, and of administration and management as well as the other $30 M costs a year. What is the cost of this plan? Is it realistic?
PZP OR FERTILITY CONTROL TREATMENT
This plan proposes to gather 91 % of each herd. That hasn’t been done to date as the animals are elusive. This plan seeks to PZP “all mares” which is not to the health of the horse or the genetic health of the herd as it does not allow for replacement or recruitment. The feasibility of this plan has never been accomplished with any large herd. Using sterilization won’t allow for replacement either threatening the genetics of the herd. Cost considerations have not been determined. It is not only the cost of the vaccine but also the cost for movement of the horses, for repeated vaccinations, and for manpower.
MOVEMENT OF ANIMALS FROM CORRALS TO PASTURES TO SAVE COSTS
The cost per day for pastures is $1.80-$2.50 compared to the cost per day for corrals of $4-$7. Corrals need to be available for processing animals with shots, dewormers, and foot care, for birthing purposes, for mare-foal maintenance, for training, for adoptions. All horses can’t go from the ranges to pastures. Currently 13,000 animals are in some 23 corrals. The question is what numbers need to be in corrals for the purposes they serve and could the numbers be lower? Simply saying corral animals should be moved to pastures for cost savings is simplistic and unrealistic.
Currently the BLM is adopting some 3000+ animals a year. The ASPCA, HSUS, RTF, and AMF are committed to increasing adoptions by having parallel adoption services committed to marketing, and to providing mentoring and training services. These groups have determined the greatest market is on the East Coast. This group has provided no evidence of numbers of applicants on the East Coast. Does this group think it can increase adoptions from 3000 to 9000 a year, if 12,000 horses are removed a year or to 17,000 if 20,000 horses are removed a year? From experience, many people will tell you they want a horse, but they have no experience with wild horses, no means to support them, no set up, and no determination to stick with them. They want them but they don’t want to keep them. Then wild horses are in competition with domestic horses who also need places to go when they are unwanted which makes it even more difficult to home the wild horse. Currently the BLM adoption program does not seem to be run efficiently with opportunities lost for placements for the horses, but with change, can 20,000 vs 3000 yearly be realistically added?
LARGE SCALE PRIVATE PASTURE OR SANCTUARY FACILTIES
The AMF or American Mustang Foundation proposes providing pastures for 50,000 wild horses and burros in addition to the 50,000 already in corrals and pastures. The taxpayer is already paying $60 M a year to appease public land ranchers with off range housing for its wild horses and burros. Does the AMF want the taxpayer to pay $60 M more? The taxpayer should pay for the animals off of our public lands while the ranchers can pay a mere $1.35 per cow-calf for their livestock on our public lands? The ranchers are on our public lands by privilege, not by right. They pay a mere $1.35 per cow-calf while private ranchers pay upwards of $22.00 per cow-calf. The public land ranchers provide less than ½ of 1 % of our meat in areas where the wild horses should be moved to taxpayer funded pastures while the wild horses and burros remain on our public lands on the 27 M acres to attract tourism.
RTF suggests wild horses be moved to sanctuaries or rescues. Sanctuaries and rescues are scarce across the United States, are overbooked and are expensive to run. Neda DeMayo of RTF in Lompoc, California, has done a lot for wild horses, but as previously stated, she does not have room for one California horse in her sanctuary and is in the red according to Guidestar. Non-profit funds are not easy to come by. Older horses are particularly in need of sanctuaries but the placements just aren’t there. Many rescues are not well run…are not suitable for horses. Rescues are constantly starting up and collapsing. Start up rescues are popping up now as fronts for kill buyers. Wild horses and burros are in competition with domestic horses for the spaces that are available in sanctuaries and rescues. The domestic horse appears preferred as they are already gentled and trained. The idea of sanctuaries or rescues taking in an additional 50,000 wild horses or burros over a 3-5 year period is not a realistic solution for the number that will have to be accommodated.
In short, this proposal presents danger to the health of wild horses and burros on the range and to the continuance of the herds on the range. This proposal also lacks cost analysis for its solutions, lacks realistic proposals for its solutions, and lacks trials, evidence, and substance that speaks to the numbers of the animals and the cost for managing the wild horses and burros. The authors of this document may have experience with animals, but they don’t appear to have experience in managing, within economic limits, our wild horses and burros both on and off of our public lands.
This proposal is presented by:
The ASPCA- American Society for the Prevention of Cruelty to Anima
The HSUS and HSUS Legislative Fund- Humane Society of the United States
The AMF-American Mustang Foundation (a new lobbying group)
The RTF-Return to Freedom (a sanctuary in Southern California)
The American Farm Bureau Federation
The Society for Range Management
The Public Lands Council
The National Horse and Burro Rangeland Management Coalition
Eureka County NV County Commission Office
National Cattlemen’s Beef Association
Beaver County Utah County Commission Office
Utah Governor’s Office
We have only to look at the presenters of this proposal to know who will benefit if Congress were to accept this proposal and it won’t be America’s Wild Horses and Burros.
I have been a wild horse and burro advocate for over 10 years now participating in meetings and in researching various aspects of the wild horse and burro program. Recently I have worked as a volunteer team member with the US Forest Service in the placement of wild horses following a gather of 220 horses in 2016 and now in the gather of 932 horses in 2018. I,with other volunteers team members, have worked on marketing, placement, transport, and donations toward providing safe, long term homes for 255 horses and their foals across the country. Finding safe places especially for the older horses13 and up in age across the nation has been a real challenge and that is only for 255 horses not 17,000 horses. I have not approached the ASPCA for help with placements as that isn’t what they do. I have approached the HSUS and RTF multiple times for help with placements, but they have been of almost no help. With 20-40 hours of work weekly for 6 months contacting placement possibilities across the nation I challenge these groups to show me safe, long term placements on the East Coast where they say there is the market for 12,000 to 20,000 horses and burros.
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