TCF Comments At BLM WH&B Advisory Board Meeting
TCF Founder and Executive Director Ginger Kathrens once held the Humane Advocate Chair on BLM’s Wild Horse and Burro Advisory Board. As sometimes the sole voice of dissent in a cadre of people who seemed bent on cruel management practices, she spoke for America’s wild mustangs and burros. Ginger was replaced after just a single term. To advocates, who have seen the writing on the wall for years, it came as no surprise.
Ginger, and the staff of The Cloud Foundation, continue to speak on behalf of our wild herds - and our public lands. Recently, the WHB Advisory Board met again, this time virtually, and we all turned out to give pubic comments. As Americans, we can only make our government work for us if we summon the will to participate in it. We have the right to make our voices heard. And we must use those voices to speak up for what we believe in. Read on to see what we said.
Ginger Kathrens, Founder and Director of The Cloud Foundation.
Public comments to the BLM Wild Horse & Burro Advisory Board, Sept. 24, 2020
Thanks for the opportunity to speak with you today. For decades wild horses and burros have been treated unfairly and managed irresponsibly.
Some of the most egregious attacks have been made in just the past several years. Sadly, the program seems to be regressing.
Massive roundups are on the rise. Archaic, unscientific sterilization procedures are being proposed which would take the wild out of wild horses by destroying that which makes them wild. This is not opinion but fact according to the National Academies of Science in their 2013 review of the BLM Wild Horse and Burro program.
Through the millennia, wild horses have survived. In contemporary times, they’ve been pushed into more and more inhospitable places as humans claimed their lands. Regardless, wild horses survived, primarily due to the strength of their society. They live in social bands--- a stallion, his mares and their offspring. Like wolves, each family member has a role in maintaining the safety of the band, in finding food and water, and in successfully raising their young.
Gruesome and dangerous tactics proposed by the advisory board would destroy this essential band structure. Castrating stallions is done in domestic settings to control behavior. But geldings have no role to play in the wild. Ripping the ovaries out of mares and rendering them sterile leaves them with no role either---assuming mares survive the horrors of the procedure itself. Wild horse society is shattered by these brutalizing management techniques. Taking the “wild” out of our wild horse herds is unnatural and cruel.
I implore you to change course. Reversible fertility control vaccines are available. PZP has been available since the 1980s. Where these reversible vaccines are used consistently, no roundups are necessary and social structure is preserved because natural behaviors are preserved. Preserving natural behaviors must be the litmus test for responsible population management of wild horses.
BLM has made statements in the past declaring “PZP doesn’t work.”
That is only correct if you don’t use it! Our organization stands ready to support BLM in delivering reversible vaccines. Model programs in Wyoming, Idaho, Nevada and Colorado serve as examples on how to move forward humanely.
Please reject cruelty. Embrace fairness. Allow volunteers to participate. And fulfill the hopes and desires of a unanimous Congress when they passed the Wild Horse and Burro Act in 1971.
Thank you.
Charlotte Roe, founder of the Wild Equid League of Colorado, and policy advisor to TCF.
Public comments to the BLM Wild Horse & Burro Advisory Board, Sept. 24, 2020
I’d like to say a word for the wild burros, and about the BLM, which needs to stop mismanaging them to extinction.
The booming Chinese trade in ejiao, has made donkeys a critically endangered species. A 2019 study by the UK’s Donkey Sanctuary found millions are being slaughtered and skinned to meet the insatiable demand for donkey hide gel. Populations are collapsing across Africa, South America and Asia. US donkeys, both domestic and wild, supply this sinister trade through kill buyers who transport them cross-border to Mexico and Canada.
In not one NEPA document or gather plan has the BLM addressed this global survival threat. Instead the BLM keeps crying that their populations must be drastically culled to prevent range damage. This is unproven and false on its face.
Numbers tell the story: The BLM’s first census the Wild Free-Roaming Horses & Burros Act found the wild burro population, once thriving in the West, was down to 15,000 animals, a level that triggered passage of the Act to keep them from “fast disappearing” from the West. Today, BLM’s says the total wild burro population is 15,546, in itself an exaggerated estimate. Yet the agency is moving aggressively to reduce them to extinction level. The justification? A broken measure called AML
The National Academy of Sciences’ 2013 review of the BLM’s WHB program found no “science-based rationale” for the BLM’s forage allocation and AMLs. The NAS recommended a reforming AMLs to allow for self-sustaining, genetically viable herds to exist. The false AMLs are used to drive wild equines off the lands guaranteed them by the 1971 Act.
Nearly every HMA with wild burros is below the level needed for long-term survival of the herd. You can either rename these targets “inappropriate management levels,” or revise the AMLs based on the land’s carrying capacity, the health of the herd and the law. The 1971 Act is clear: where the wild horses and burros were originally found are areas to be “devoted principally though not necessarily exclusively to their welfare.” If an area so designated is not managed principally for wild burros and horses, it is being mismanaged.
The BLM’s population stats are just as bogus. In its assessment justifying a near-total removal of the Black Mountain burros, the BLM took a fragmentary 2014 helicopter survey and doubled the estimate in 2020, claiming a completely unfounded “expectation” of 15% annual growth. In another example, the BLM recently rounded up nearly 600 Bullfrog wild burros, based on a partial helicopter count and an outdated and questionable 2012 EA.
In the wild, burros are notoriously hard to identify. Unlike horses, they don’t always stick to bands. Their coloration and size makes double-counting a huge probability in surveys that last over a day, or are broken up by weather events. Wild burros do not reproduce like rabbits or magically multiply, nor do wild horses. Extrapolating from small samples to project population increases of 15-20% annually betrays a deep bias and ignorance regarding these keystone species.
Like a broken record, the BLM claims that roundups are needed to “protect rangeland resources from deterioration associated with an overpopulation of wild burros, and to restore and maintain a thriving natural ecological balance (TNEP).”
Guess what: Wild burros are not overrunning the range, they are disappearing. In its 2013 report on the BLM’s program, the NAS warned that the genetic diversity of small, fragmented wild burro populations was seriously weakened, and that “removing burros permanently from the range could jeopardize the genetic health of the total population.”
There’s no science behind the claim of range degradation by wild burros. In fact, they help restore the land; they are integral to TNEP. Research by noted scientists including Dan Rubenstein, Scott Abella, and Eric Lundgren have revealed these equines’ unsung ecological services.
They remove dead-stem grass layers. Their presence minimizes invasion by non-preferred vegetation. They graze down fire-prone brush. They dig deep waterholes that help other species access water and create vegetative nurseries in the desert. Why is this science denied? Why does BLM treat these amazing animals with such derision and prejudice?
It’s time to end the charade and give wild burros their due. I propose the following, for starters:
A moratorium on roundups. Though stoical, donkeys are extremely sensitive animals that tend to freeze or scatter in terror during helicopter-driven gathers. Those captured, if they survive, lose their freedom, their family bonds and their purpose in life, and can easily succumb to pathogens. In just one of many such , the Sinbad roundup in Utah left 37 dead. The removals make no fiscal or ecological sense.
Establish a wild burro range in Arizona’s Black Mountains, the largest, most genetically robust burro population. A reserve that is free of cattle or sheep and that allows predators to coexist would go a long way to preserve these unique long-eared animals in their natural state. It would also help restore this cattle-ravaged land.
Reopen zeroed out HAs and HMAs to captive burros and mustangs so that, as an initial priority, older jennets and mares along with geldings can be rewilded. This would help lower the astronomical costs and numbers of those in holding while protecting them from the deaths, stresses and diseases that result from being imprisoned.
Implement federal grazing permit buybacks to reduce harmful overgrazing by cattle and sheep and to achieve true ecological balance. Limiting, rather than expanding, the presence of these domestic ruminants is essential to combat harmful climate change impacts. No way should permittees be allowed more flexibility in grazing authorizations and decisions about when to move their livestock, as BLM proposes in new regulations.
Stop all sex ratio manipulation and sterilization. Disrupting mustangs’ and burros’ natural social balance, and conducting permanent, dangerous surgeries such as ovariectomies, are violations of the 1971 Act. It constitutes animal abuse. Universities have rejected taking part, for good reason. Why does the BLM keep going down this nightmarish road?
Revamp the adoption incentive and related programs. Paying people $1,000 to adopt mustangs and burros as though they are excess baggage, with no monitoring or follow-up to ensure they remain in good hands, opens the gates to the brutal ejiao trade. The widespread presence of BLM-branded burros in kill pens has been extensively documented for years. The BLM needs to close this back door to slaughter
Diversify the WHB Advisory Board, which currently lacks wild horse or burro advocates with experience in on-range documentation and wild equid behavior or in educating the public about their crucial niche in Western ecosystems. Wild horses and burros need understanding and protection, not a propaganda barrage. The real ravagers of public land — “acting” Secretary Pendley, taxpayer subsidized ranchers, big oil, big prospectors and their abandoned mines — promote this propaganda to maintain regulatory capture of the Agency and its public relations. Burros and mustangs need a voice. Those who spread the misinformation about them should be shown the door.
Dana Zarrello, TCF Deputy Director.
Public comments to the BLM Wild Horse and Burro Advisory Board, Sept. 24, 2020
Hello. I’m speaking today on behalf of the Cloud Foundation. I’m a business-oriented person, so I understand it’s difficult to run an agency as large and complex as BLM in a multi-stakeholder situation.
But - public perception of BLM is poor. The agency appears to support a biased system, where the rights and wishes of the many are subjugated for the benefit of a few.
The result has been an age-old anti-wild horse and burro P-R campaign which, when examined, lacks a comprehensive, holistic evaluation of all users on the range.
Wild horses live on a tiny fraction of BLM lands. To call them an “existential threat” is not just laughable, it’s nonsensical. And to continue to insist they’re an invasive species when the science of evolutionary biology has concluded they are native to North America, is equivalent to insisting that the world is really flat. It just makes one look silly and uneducated.
On average - 80% of the forage in federally-designated wild horse habitat is allocated to privately owned livestock. This is land that, according to the Act, is supposed to be principally managed for the welfare of the horses. And - the impact of these truly non-native livestock on the range is almost never considered in BLM environmental assessments.
Public lands ranching is a privilege, not a right.
It’s time for both sides of this issue to come to the table as fellow Americans. We can’t have a fact-based discussion about range conditions without looking at the impact of ALL users. Failure to do so makes finding a common solution impossible
The adoption incentive program, despite the opinions of the panel, creates a loophole to slaughter that is being exploited. There is information that an increased number of BLM-branded horses and burros are landing in kill pens. A reputable nonprofit just secured 12 un-gentled, newly titled mustangs who had all been adopted by people with the same family name and dumped in a Kansas kill pen. This program is being called Pay and Slay - it has to be fixed
We must have accountability and oversight.
If BLM were a business not supported by the government, it would’ve failed long ago. Taxpayers are sick of bailing out an agency that isn’t responsive to their wishes. The collective will of the American people supports the humane treatment of these animals and their right to live and die WILD on the range, with their families.
I urge you to advise BLM to move in that direction rather than continuing the same failed practices that have bankrupted this program. Thank you.
As you know, we cannot do the important work of fighting for America’s mustangs and burros without your help. Please consider a donation today - no matter what the amount - to help us continue the fight.
Thank you for your caring and support for our work, and all our wild horses and burros, on and off the range!