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January 12, 2015

BLM Southeast Oregon Resource Advisory Councilco BLM La!evie" #istrict O$ce1%01 S & StreetLa!evie", Oregon '()%0

*ia +ail- vanne@blm.gov

#ear RAC Me.ers-

/hese coents to the Bureau o Land Manageent BLM SoutheastOregon Resource Advisory Council RAC are su.itted on .ehal o theAerican 3ild 4orse reservation Ca6aign A34C and endorsed .y 77 oour su66orters8

A34C is dedicated to 6reserving the Aerican "ild horse in via.le ree9roaing herds or generations to coe, as 6art o our national heritage8 Ourgrassroots e:orts are su66orted .y a coalition o over ;ty horse advocacy,anial "elare and conservation organie" ?or! to Michigan to Mississi66i toOregon = and they care dee6ly a.out Aerica@s 6u.lic lands and our "ildhorses and .urros8 /hese lands and the "ild horses that inha.it the .elongto all Americansand all Americans should have a say in their anageent8

>ational 6olls deonstrate that "hile (2 o Aericans su66ort6reserving

"ild horses on our 6u.lic lands, less than one9third o the 6u.lic"ants those

sae lands used or livestoc! gra

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horses are a signi;cant 6art o Oregon@s history and culture8 But there aren@tany o these 6roud icons let8

The Numbers

Ranchers across the 3est = including those in Oregon = are .ecoingincreasingly vocal a.out a so9called "ild horse Fover6o6ulationG 6ro.le8

4o"ever, their rhetoric a.out daage caused to the range .y ustangs

si6ly is not su66orted .y the acts8

Hn reality, the "ild horses in Oregon are vastly outnu.ered .y livestoc!-

Just over %,000 "ild horses reain on BLM land in the state, a density

o one horse 6er '00 acres8

Mustangs roa on ust 28( illion acres o BLM land in Oregon versuslivestoc!, "hich gra

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+6loyees or +nvironental Res6onsi.ility analysis that revealed, Fthemethod used by the U.S. Bureau of Land Management to assess rangeconditions is seriously skewed toward minimizing impacts from domesticlivestock and magnifying those from wild horses and burros8G /hat analysiscan .e ound at this lin!- htt6-"""86eer8orgne"sne"s9

releases2010'1).l9"eighs9"ild9horse9i6act9uch9ore9heavily9than9cattle

A Way Forward

Hn June 201%, the >ational Acadey o Sciences issued a re6ort

coissioned .y the BLM on the agency@s "ild horse and .urro 6rogra

;nding that Fcontinuation o .usiness as usual 6ractices "ill .e e76ensive

and un6roductive or the BLM and the 6u.lic it serves8G Aong the re6ort@s

!ey ;ndings are-

Manageent 6ractices are ueling high 6o6ulation gro"th rates8

4o" A66ro6riate Manageent Levels AMLs are esta.lished,

onitored, and adusted is not trans6arent to sta!eholders, su66orted.y scienti;c inoration, or aena.le to ada6tation "ith ne"inoration and environental and social change

BLM anageent 6ractices should .e res6onsive to 6u.lic attitudes

and 6reerences8

/ools Kincluding ertility control already e7ist or BLM to addressany challenges8

Although everyone agrees that the BLM 6rogra is .ro!en and in need oreor, change is slo" to coe8 /he agency is continuing to reove horsesro the range des6ite the acts that- a ',000 "ild horses and .urros arealready stoc!6iled in governent holding acilitiesN and . these reovalsare ueling high 6o6ulation gro"th, according to the >AS8 urther, the agencyis 6ursuing destructive easures, such as the s6aying o ares and geldingo stallions, that "ere s6eci;cally recoended against .y the >AS in are6ort that the BLM coissioned and unded "ith nearly P2 illion ota76ayer unds8

As the >AS clearly concluded, solutions to the "ild horse anageent issueare availa.le, .ut the 6olitical "ill to i6leent the is lac!ing8 H "e are to6ut the decades9long controversy over "ild horse 6rotection to rest, "e ustall roll u6 our sleeves and "or! together on i6leenting these solutions8

http://www.peer.org/news/news-releases/2014/09/16/blm-weighs-wild-horse-impact-much-more-heavily-than-cattle/http://www.peer.org/news/news-releases/2014/09/16/blm-weighs-wild-horse-impact-much-more-heavily-than-cattle/http://www.peer.org/news/news-releases/2014/09/16/blm-weighs-wild-horse-impact-much-more-heavily-than-cattle/http://www.peer.org/news/news-releases/2014/09/16/blm-weighs-wild-horse-impact-much-more-heavily-than-cattle/http://www.peer.org/news/news-releases/2014/09/16/blm-weighs-wild-horse-impact-much-more-heavily-than-cattle/http://www.peer.org/news/news-releases/2014/09/16/blm-weighs-wild-horse-impact-much-more-heavily-than-cattle/

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Since "ild horses are 6resent on ust 20 6ercent o BLM land in Oregon thatis availa.le or livestoc! graAS, as outlined a.ove8 A34Csu66orts the "ides6read use o to sta.ili

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Hn contrast "ith other ertility control drugs, has the least i6act onnatural "ild horse and herd .ehavior8 /o reduce the inherent stressassociated "ith roundu6 or gather o6erations, "e su66ort thei6leentation o a 6olicy that "ould give 6reerence to conducting Ca6ture9

/reat9Release C/R a66lication o6erations in a anner that aintains"ild horse social structures and aily .ands8 reerence to "ater and .aittra66ing o6tions should al"ays .e given .eore resorting to helico6ter driveo6erations8

/he BLM reoves thousands o "ild horses ro 6u.lic lands each year onlyto "arehouse the vast aority in governent holding acilities8 Hn 2001,there "ere a66ro7iately 5,000 "ild horses in governent holding acilities8/oday, nearly 50,000 "ild horses are stoc!6iled in governent holdingacilities, a nu.er that, at iniu, eIuals, i not e7ceeds the 6o6ulationreaining on the range8

3hile co6lete reor o the BLM@s 3ild 4orse and Burro rogra is needed,the "ides6read use o as a 6riary eans o anaging "ild horse herdsis an iediate ;rst ste6 that ust .e ta!en in order to reduce the nu.erso horses reoved ro the range8 H the o6tion is not ully i6leented,the BLM "ill li!ely continue the endless and unsustaina.le cycle o roundingu6, reoving and stoc!6iling "ild horses = that coes at a great cost to the"ild horses and the Aerican ta76ayers8

Hn Oregon, an e7cellent 6lace to start a 6rogra is in the Beatys Butte4MA, "here a ediation grou6 o ranchers, conservationists and "ild horse

advocates has laid the ground"or! or "hat could .e a 6u.lic6rivate6artnershi6 or the huane anageent o the "ild horse 6o6ulation there8Ht is ar .etter to address anageent 6ro9actively, cost9e:ectively andhuanely than to do nothing, "hich is the current BLM a66roach8

3e urge this RAC to ollo" the lead o the BLM >ortheastern &reat Basin RACin >evada, "hich in August 201 issued recoendations endorsing thisa66roach to "ild horse anageent8

Fnal Thoughts

or the 77 citi

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/he >AS concluded that these concerns are i6ortant- F4orse and .urro

anageent and control strategies cannot .e .ased on .iological or cost

considerations alone' anageent should engage interested and a:ected

6arties and alsobe res#ons$e to #ublc atttudes and #references8G

/he recoendations outlined a.ove a!e good ;scal sense and are in line

"ith the 6u.lic@s su66ort or 6rotection o "ild horses and .urros on our

3estern 6u.lic lands8

/han! you or your consideration8

Sincerely,

Su