by Charlotte Roe

Black Mountain Herd – photo by Marjorie Farabee

The Deportation Playbook

The Wild Free-Roaming Horses and Burros Act (WFRHBA) of 1971 directs federal agencies to preserve wild burros and horses as an “integral part” of the public lands on which they roamed in 1971 in order to halt their precipitous decline. DOI’s first census in 1974 found only 15,000 wild burros roaming public rangelands. Today, stating the same number of wild burros remain, the BLM plans to reduce them to an “appropriate management level” (AML) of 2700. There is no justification for eradicating burros from their federally designated lands. None. At all.

The National Academy of Sciences 2013 report on the BLM’s Wild Horse and Burro Program found BLM removals were dangerous for wild burros, whose populations were already small, fragmented, and at risk of inbreeding. The NAS warned, “removing burros permanently from the range could jeopardize the genetic health of the total population.” Its study found no science-based rationale for the BLM’s AMLs allocating forage. Leading equine geneticist Gus Cothran recommends a minimum AML of 150-200 wild equids to maintain genetic variability. Of the 29 Herd Management Areas (HMAs) with wild burros, only 3 comply with this standard.

The Bureau claims that overpopulation of burros endangers its goal of a “thriving natural ecological balance.” There is no evidence that burros reproduce to excess or destroy fragile habitat. Yet the myth persists, because of ignorance, greed, and land-grabbing narratives fostered by Big Ag, Big Extraction, and Big Game permittees. Ranchers whose subsidized livestock grazing degrades public lands seek a scapegoat. Mining, oil and gas interests pushing for further encroachment on federal lands view protected burros as obstacles, or as potentially dead witnesses to toxic leeching.

Public Employees for Environmental Responsibility (PEER), Western Watersheds Project and GAO have consistently pointed out that the BLM unfairly targets scattered wild horse and burro herds, while intentionally ignoring the impacts of millions of cattle and sheep permitted to graze on public lands. In a 2021 survey, PEER found that three-fourths of BLM staff do not believe their agency prioritizes resource protection or uses best available science in making decisions.

Wild Burros Belong on the Western Ranges

BLM Prisoner, photo by Terry Fitch of Wild Horse Freedom Federation

The BLM’s derision is matched by the US Forest Service and the National Park Service.  NPS, in campaigns to rid the Grand Canyon and Death Valley of wild burros that were part of the lands for hundreds of years, claimed they were alien to the desert ecosystem.  Nothing could be further from the truth or the law.

Burros are vital links in the delicate desert ecology.  Their presence and behavior benefit a multitude of wildlife. They browse on coarse vegetation, keeping fire-prone bushes and invasive grasses in check. They have what researcher Dan Rubenstein calls a “facilitative relationship” with other life forms, since they do not fully digest seeds, but spread them. In Western deserts, biologist Erick Lundgren discovered burros digging wells a meter or two deep that enable dozens of vertebrate species to access scare water resources.  Lundgren notes that these equid wells, often the only water in drought-stricken lands, become “vegetation nurseries” that help counter aridification.  The results of his research mapping equid ”water engineering” in the Mojave and Sonoran deserts was just featured in Science magazine.

Numbers Games in Black Mountain

The largest free-roaming burro population inhabits Arizona’s Black Mountains herd area of over 1 million acres, of which the BLM manages 574,000 acres. It is the most genetically intact burro herd. The BLM reports this burro population has reached 2200, a claim based on a faulty helicopter survey in 2014 that photographed 72 burros. No safeguards were taken to ensure that burros were not double or triple counted while being chased by copter from one quadrant to another. Yet BLM “counted” 1675.

The BLM now claims over 2000 burros in the Black Mountain, based on an assumption that the population grows by 25 percent a year and has “no natural predators.” But the UK’s Donkey Sanctuary points out that burros reproduce slowly: “a donkey mare carries their foal for a year and they’re very slow to reach maturity.” Mountain lions, donkeys’ chief wildlife adversary, are routinely exterminated to protect private livestock. The Humane Society’s 3-year fertility control study, the first extensive PZP project for wild burros, is not yet finished, but the BLM chose to jump the gun.

The Black Mountain AML is 382-478 animals, or roughly one burro per 1200 to 1500 acres. In August 2020, BLM announced it would remove 1000 burros, half of the estimated — and most likely 75 percent of the actual — population. The 2020 roundup captured 503 burros. The rest are targeted for this summer. BLM’s environmental assessment ignored impacts of the expanding Moss gold/silver mine, an open pit operation set to occupy 496 acres of burro habitat. And it recently renewed grazing leases for thousands of range-destroying cattle and sheep.

Local officials say the drought is driving burros to Bullhead City, endangering traffic. Common sense mitigation would call for reflecting lights to scare wildlife from approaching roadways; fencing along highways and urban areas; construction of wildlife overpasses; public education to discourage people from feeding burros in towns and along roads; and restoration of water sources so the animals can utilize the whole HMA. But BLM and county commissioners aren’t interested in solutions.

Dark Sales or Worse?

The BLM’s Kingman Arizona field office publicly stated that unadopted Black Mountain burros will be maintained in off-range pastures to “retain their wild status.” Yet BLM’s 2020 Report to Congress clearly stated “there are no off-range facilities” for captive burros. Throughout the southwest, BLM-branded burros, now abandoned or resold for slaughter, are found in kill pens. Something even more nefarious may be happening with sales. In early 2020, 470 burros disappeared from holding; the majority of those unaccounted for are missing from the Florence facility, where captive Black Mountain burros are held, and the Axtell holding pen. The BLM has not answered repeated FOIA requests to unearth the truth.

The BLM Wipeout Continues

In its 2021 environmental assessment, the BLM unveiled plans to zero out all of the last large remaining wild burro herds in the Centennial and neighboring herd areas of California.  The agency’s most recent EA aims to capture and remove over 500 wild burros in the Lake Meade Complex in

photo by Terry Fitch of Wild Horse Freedom Federation

southern Nevada, eliminating two major herd areas.  The fact that the BLM lacks legal authority to eradicate wild equid rangelands has not yet stopped it from taking millions of acres out from under federally designated habitat since the 1971 WFRHBA was passed.

Chinese skin trade brokers eagerly await the end of this pipeline. Rising prices for ejiao, a traditional medicine derived from donkey hide, is decimating donkey populations worldwide. Donkey Sanctuary Research Director Faith Burden says “the welfare infringements are absolutely horrendous in some of the places that donkeys are slaughtered for this trade.”

Time to Speak Up

This is Burro Awareness Month. Let’s tell every official with a say on public lands to halt wild horse and burro roundups and support a serious Congressional investigation of the BLM’s broken, corrupt management practices. The 1971 Wild Horse and Burro Act mandates federal land agencies to manage wild equids humanely, not to torment them with roundups and dubious adoptions, shrink their habitat and eject them from their designated homes. The Black Mountain HMA should be designated as a Wild Burro Range, retiring livestock and allowing the land to replenish. This would fulfill a key goal of the Administration’s 30×30 climate plan.

We can’t allow burros’ plaintive brays in the desert to fade to nothing. They deserve an astronomical voice raised for respect, rule of law, and change.