American  Wild  Horse  Preservation  Campaign,  1025  Alameda,  #  633,  Belmont,  CA  94002,  contact@wildhorsepreservation.org,  1-­‐877-­‐853-­‐4696  

 

THE FEDERAL WILD HORSE AND BURRO PROGRAM: A PROBLEM OF MISMANAGEMENT

Written Testimony of the American Wild Horse Preservation Campaign By: Suzanne Roy, Executive Director

Oversight Hearing: “Challenges and Potential Solutions for BLM’s Wild Horse & Burro Program” Federal Lands Subcommittee, House Natural Resources Committee

June 22, 2016

“BLM'S decisions on how many wild horses to remove from federal rangelands have not been based on direct evidence that existing wild populations exceed what the range can support.”

- U.S. Government Accountability Office, 19901

“How Appropriate Management Levels (AMLs) are established, monitored, and adjusted is not transparent to stakeholders, supported by scientific information, or amenable to adaptation with new

information and environmental and social change.” – National Academy of Sciences, June 2013

The American Wild Horse Preservation Campaign agrees that a significant problem exists with the Bureau of Land Management (BLM) Wild Horse and Burro Program. However, we believe that the oversight committee is focused on the wrong problem. The problem is not wild horse overpopulation; the problem is BLM mismanagement as affirmed by numerous government and scientific reports, most recently the National Academy of Sciences (NAS) in its 2013 report, “Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward.” The National Academy of Sciences study, which was commissioned by the BLM itself, demonstrates that BLM’s management practices waste taxpayer money, are facilitating high rates of population growth and ignore scientifically proven solutions to reduce herd growth, including the use of the PZP fertility control which has reduced some herds to zero population growth. These are America’s wild horses and burros – protected by a law unanimously passed by Congress – and they live on public lands that belong to all Americans. The will of the American people should prevail, especially when it comes to public lands. Americans have demonstrated time and time again that they overwhelmingly oppose horse slaughter and strongly support protecting wild horses and burros on our federal lands. The Current Facts

• The program is unsustainable: The BLM relies on continual roundup, removal and warehousing of wild horses and burros in government holding facilities at taxpayer expense. In the last seven years alone, the BLM has removed more than 40,000 wild horses from public

                                                                                                               1 http://www.gao.gov/assets/150/149472.pdf

   

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lands.2 The agency now stockpiles nearly as many wild horses in captivity as remain free in the wild.3

• The program is a fiscal train wreck: The BLM’s wild horse and burro budget has doubled since 2009, reaching $80 million in Fiscal Year 2016. Approximately 70% of the BLM’s budget is spent on roundups, removal and confinement, while less than 1% is spent to implement humane and available management programs for wild horses on the range.4

• The program is inhumane. The roundups terrorize wild horses and burros in helicopter stampedes across miles of rugged terrain and deprive these wild animals of the two things most important to them: family and freedom. Recently, 1,800 wild horses were illegally sold by BLM to a kill buyer and the horses likely were slaughtered.5

• The program is unscientific. In 2013, the National Academy of Sciences (NAS) found that the BLM’s “management practices are facilitating high rates of population growth on the range” and that “removals are likely to keep the population at a size that maximizes population growth rates, which in turn maximizes the number of animals that must be removed through holding facilities.” 6

• Adoption is not the solution. The BLM continues to remove wild horses from the range in numbers that far exceed adoption demand. With nearly 50,000 wild horses and burros already stockpiled in holding facilities, the BLM simply cannot adopt its way out of this problem.

• There is a better way. The NAS recommended use of the PZP birth control vaccine as “a more affordable option than continuing to remove horses to long-term holding facilities.” PZP fertility control is used today to successfully manage 30 wild horse populations in the U.S. The BLM has eliminated helicopter roundups in numerous Herd Management Areas (Pryor Mountains, McCullough Peaks, Little Book Cliffs, Spring Creek Basin) by utilizing the PZP vaccine. However, instead of increasing its use, the BLM has actually reduced the use of PZP since 2011.

• Humane management = cost effective management: The cost savings of humane

management utilizing the PZP vaccine are well documented in the scientific literature. One economic model demonstrated that BLM could save $8 million over 12 years by using PZP in one HMA alone. Multiply that by 179 HMAs and the cost-savings reach the hundreds of millions.7

                                                                                                               2 http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html 3http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/statistics_and_maps/holding__adoption.Par.53188.File.dat/WOFacRpt052016_web.pdf 4http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/advisory_board_10_2011.Par.57112.File.dat/Budget Presentation 9 2015.pdf 5 http://www.latimes.com/nation/la-na-wild-horse-slaughter-20151029-story.html 6 http://www.nap.edu/catalog/13511/using-science-to-improve-the-blm-wild-horse-and-burro-program 7 http://zoowildlifejournal.com/doi/abs/10.1638/1042-7260-44.4S.S34

   

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BLM 2017 Budget: Heading in the Wrong Direction Instead of following the NAS recommendations, the BLM’s 2017 Budget calls for sterilization of wild horses on the range, and opens the door to slaughter, something that is strongly opposed by the American public.

• Sterilization will take the wild out of wild horses. Unlike humane PZP fertility control, which is non-invasive and does not affect natural behaviors, surgical sterilization of wild horses on the range poses grave safety risks and will inalterably destroy their natural behaviors8 – the very essence of what makes these animals wild and distinguishes them from their domestic counterparts.

• Creating a slaughter loophole. The proposed Section 110 budget language to amend the Wild Horse Act to allow the BLM to strip captured wild horses of their protected legal status before turning them over to local and state governments, ostensibly for use as “work animals,” opens the door for slaughter. Currently Congress prohibits the sale of captured wild horses and burros for slaughter, but this requested provision would be an end run around this prohibition. Even suggested language to make this provision less harmful, is not sufficient to protect wild horses from slaughter because it would strip wild horses of their protected status, not prohibit non-commercial slaughter and contains no enforcement mechanism to ensure that wild horses are not sold for commercial slaughter.

The Myth of Wild Horse “Overpopulation” The BLM bases its claim of wild horse and burro overpopulation on its inequitable and unfair Appropriate Management Level (AML) system. However:

• AMLs are not based on science. The NAS stated that it “could not identify a science-based rationale” behind the BLM’s AMLs, finding “how Appropriate Management Levels (AMLs) are established, monitored, and adjusted is not transparent to stakeholders, supported by scientific information, or amenable to adaptation with new information and environmental and social change.” 9

• National AMLs are based on “fast disappearing” population levels. By setting a national AML of just 16,300 – 27,00010 for all wild horses and burros under BLM management, the BLM seeks to drive the wild horse and burro populations back to the number (25,000) that existed in 1971, when Congress determined these iconic animals were “fast disappearing.” At that time, Congress indicated that increased numbers of wild horses and burros were desired and that wild horses and burros “should be considered as components of the public lands coequal with wildlife and domestic livestock.” (Sept. 15, 1971 Interior and Insular Affairs report)

                                                                                                               8 http://www.wildhorsepreservation.org/media/kirkpatrick-declaration-sterilization 9 http://www.nap.edu/catalog/13511/using-science-to-improve-the-blm-wild-horse-and-burro-program 10 http://www.blm.gov/wo/st/en/prog/whbprogram/history_and_facts/quick_facts.html

   

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• Habitat has been reduced by almost half. Since Congress unanimously passed the Wild Free Roaming Horses and Burros Act in 1971, the BLM has reduced habitat for wild horses and burros by 40%.11

• Wild horses comprise a tiny fraction of grazing animals on public lands. Today, wild horses and burros are present on just 12% of federal rangelands.12 Over 75% of forage resources within wild horse and burro HMAs to privately-owned livestock.13 Wild horses & burros are outnumbered 47-1 on public lands.

BLM  Grazing  in  States  with  Wild  Horses  State   BLM  Acres  Grazed  

by  Livestock  BLM  Acres  Wild  Horse  and  Burro  HMAs    

%  of  BLM  rangelands  occupied  by  wild  horses  &  burros  

Arizona   11.5  million   1.5  million   13  California   7  million   2  million   28  Colorado   7.8  million   365,000   5  Idaho   11.5  million   383,000   .03  Montana   8.2  million*   27,094   .003  Nevada   43  million   14  million   33  New  Mexico   13  million   24,500   .001  Oregon   14  million     2.7  million   19  Utah   22  million   2.1  million   10  Wyoming   17.4  million   3.6  million   21  *includes  Dakotas  

• Wild horses & burros are not the problem. Only a tiny fraction of western forage on federal grazing lands is consumed by an estimated 67,000 wild horses and burros, which live on just 26.9 million acres of public land14. That’s roughly one animal per over 400 acres of land -- certainly not an overpopulation problem.

Public Lands, Public Animals, Public Support

• Polls document the public’s strong support of wild horses and burros on public lands. Three out of four Americans favor protecting wild horses and burros15, while 80% oppose horse slaughter16.

                                                                                                               11 http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/statistics_and_maps/hma_and_ha_stats_all.Par.50867.File.dat/2016_HAHMA_Stats_0316_for%20web.pdf 12  http://www.blm.gov/wo/st/en/prog/whbprogram/history_and_facts/quick_facts.html 13 http://www.wildhorsepreservation.org/media/zach-reichold-email-re-aums 14 http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html 15 http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html 16 http://www.prnewswire.com/news-­‐releases/aspca-­‐research-­‐confirms-­‐americans-­‐strongly-­‐oppose-­‐slaughter-­‐of-­‐horses-­‐for-­‐human-­‐consumption-­‐138494089.html

   

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• Overwhelming support for preservation. The public outcry over the U.S. Forest Service plans to remove the Salt River wild horses in Arizona was notable. In less than a week, 300,000 citizens signed a petition calling on the Forest Service to abandon removal plans, and 97 percent of respondents to an ABC television poll supported protection of these horses. The entire Arizona Congressional delegation and Arizona Governor Doug Ducey responded by calling for protection of these horses.

Win-Win Solutions To date, the BLM has failed to follow recommendations made by the NAS which are strong supported by the American public including to:

• Use the proven PZP fertility control vaccine, which has been safely and effectively used to manage wild horse populations for decades, to reduce population growth rates.

• Create public-private partnerships to implement humane management programs. The AWHPC is currently working through a Cooperative Agreement with the State of Nevada to humanely manage an estimated 2,000 wild horses on over 300,000 acres of habitat under state jurisdiction in northern Nevada’s Virginia Range.

• Adjust the artificially low and unscientific AMLs to accommodate current population levels and allow for the preservation of wild horses and burros in genetically viable herds.

• Develop mechanisms to allow for voluntary retirement of grazing permits in wild horse and burro Herd Management Areas and financial compensation (public or private) to ranchers for grazing permit retirement or non-use of grazing allotments. Compensating ranchers will be far more cost efficient than continuing to roundup, remove and stockpile wild horses in holding facilities.

Conclusion The BLM Wild Horse and Burro Program is profoundly broken and in need of reform. But in order to fix the problem, the Congress must adequately diagnose it. A Congressional inquiry into a so-called “excess” wild horse problem that focuses only on wild horse numbers, without evaluating the program’s unscientific and fiscally wasteful underpinnings will serve only to perpetuate the current system. That system benefits a handful of special interests at the expense of the American taxpayers and our iconic wild horses and burros. In summary, there is a serious problem with the wild horse program, but the problem is rooted in agency mismanagement, not horse populations. The National Academy of Sciences study, which the BLM itself commissioned and for which the agency sent set the scope, shows BLM’s management practices waste taxpayer money, cause population increases and ignore scientifically proven solutions to reduce her growth, including the use of PZP which has reduced some herds to zero population growth. The myth of overpopulation is based on the misleading notion of "appropriate" management level. By setting a national AML of just 16,300 – 27,000, the BLM seeks to drive the wild horse population back to the number (25,000) that existed in 1971, when Congress determined these iconic animals were “fast disappearing.” This is counter to the intent of Congress to protect these iconic animals by allowing their numbers to increase and treating them equitably with livestock and other wildlife species.

   

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BLM mismanagement also leads to inhumane treatment of the horses, including brutal helicopter roundups and warehousing, destruction of herd family units, and horse slaughter, such as the recent slaughter of 1,800 healthy horses, for which the Inspector General found BLM failed to follow its own policies and ensure protection of the horses.

Wild horses are present on just 12 % of federal range lands. Wild horses are not overrunning the West or destroying the range. Since we are talking about a small piece of the overall federal lands grazing pie, this problem can be resolved, but it will take leadership from Congress and a commitment within the agency for true reform.

Slaughter is not a solution. Not only is it overwhelmingly opposed by the American people, but also having slaughter as an outlet for “disposing” of “excess” wild horses would perpetuate the unsustainable cycle of roundups and removals that are causing wild horse populations to increase at higher than normal rates. By continuing removals, BLM is creating the very problem it seeks to resolve.

There is overwhelming public support for wild horses on public lands and the will of American people should prevail, especially on public lands. The current standard of treatment of these living symbols of American freedom is far below what Americans expect and demand.

We can do better and the American people deserve better, and fortunately there are inexpensive and effective solutions, including the use of PZP

Over the last decade, Congress has stood firm against slaughtering America's iconic mustangs and it should continue to do so.

Thank you for your consideration.

Attachments to AWHPC Testimony, Submitted for the Record − Key Findings of the National Academy of Sciences 2013 Report