Submission to the Bureau of Land Management's Meeting of National Wild Horse and Burro Advisory Board, to be held 17 Nov. 2008 in Reno, Nevada.
To: Bureau of Land Management (U.S. Department of the Interior), National Wild Horse and Burro Program
From: Friends of Animals, Inc.
Date submitted: 3 Nov. 2008
The Bureau of Land Management is charged with protecting some 60,000 free-roaming horses and burros on rangelands in 10 Western states. Yet, at the taxpayers' expense, it routinely rounds them up with the intent to pass them to private ownership. This policy has resulted in the accumulation of horses in the possession and care of the BLM and the question of what to do with them.
For example, the BLM recently sent out helicopters and chased roughly half the western herd of mustangs (about 30,000) into a corral, and is considering killing several thousand of them. To justify this proposal, officials complain of expenses. Yet this same BLM allows ranchers to enjoy leases to the rangelands at below-market prices.
Ranchers, allowed to graze more than 5 million cows, buffalo, sheep and goats on public lands, find horses and burros inconvenient. Environmental responsibility and government integrity should not mean augmenting the influence of profit-seekers over laws and agencies.
The West's free-roaming horses today number 60,000 or less. About 200 years ago, 3 million wild horses roamed most of the North American continent, in evident harmony with the rest of the biocommunity. At the beginning of the 20th century, 2 million mustangs roamed free. It is absurd to claim the small community of horses left today threatens the environment, and to behave as though the owners of several million domesticated animals do not.
Adoptions Are Not the Answer
In 1973, two years after the Wild Horses and Burros Act was enacted to protect horses from capture and slaughter, the BLM began rounding up free-roaming equids and privatizing them. Thousands of mustangs have been stored in corrals for long periods; at least a few have met their ends in slaughterhouses.
In 2005, the BLM moved to step up the adoption pace, after revising its negotiation and bill-of sale-procedures. Some see adoption into private ownership as a saving grace for horses struggling to survive. That rationale, while well-meaning, misses a critical point. Free-living horses, as individuals and as communities, are viable members of the western ecology. Not only should they be safe from slaughter; they should be safe from being made into commodities.
Testing Contraceptive Drugs on Horses and Burros Is Similarly Unwarranted
The pressure from government and humane groups to put animals on contraception -- essentially because they are inconvenient to the environmentally hazardous beef industry -- is inappropriate.
The BLM and the Humane Society of the United States have collaborated in experimental use of the contraceptive porcine zona pellucida on mares on public land. Contraception is invasive and inappropriate for free-roaming equids, whose numbers are, in any case, naturally contained by the inhospitable terrain that borders their habitat.
The BLM claims that reducing and repressing the free-roaming equine population is necessary to maintain a natural and ecological balance between these animals and ranches, vegetation, and watersheds. The claim is result-oriented. Ranches have nothing to do with the natural balance.
The Agriculture Department's Wildlife Services spends millions each year to kill mountain lions and other predators -- again, to protect agribusiness, not the natural balance of animal life and vegetation. If the government claims to respect free-roaming equids, it must seriously address the perils facing numerous species of animals caused by ranching interests.
Ranching and Ecological Realities
The BLM's mission is, in part, "to sustain the health and productivity of the public lands for the use and enjoyment of present and future generations." Reliance on beef ranching causes problems for generations -- problems our government must ameliorate, not exacerbate.
Animal agribusiness is notorious for its heavy use of fuel and water, a driving force behind environmental damage, and the leading generator of greenhouse gas. Yet nearly all public lands with any forage potential are leased to agribusiness interests. As the point has been put in Conservation Biology: "Urbanized areas, some dense coniferous forests, and a few rock-and-ice peaks are about all that is free from the influence of livestock."
The cattle congregate near water, and gradually destroy riparian grasses and shrubs, removing shelter and food for birds and other animals. As the US General Accounting Office has reported: "Poorly managed livestock grazing is the major cause of degraded riparian habitat on federal rangelands."
There are precedents for reversing the damage. Twenty years ago, land around the San Pedro River in southeastern Arizona, where the BLM had long granted grazing permits, had become a barren wasteland. On 1 January 1988, the BLM instituted a moratorium on nearly all cattle grazing. Congress subsequently designated the San Pedro Riparian National Conservation Area a nature preserve of 58,000 acres. As the river has deepened, fish have rebounded. Native grasses and bushes have re-established themselves. Such ecological success stories should continue in the West.
The treatment of North American horses to date is, in contrast, anything but a success. Canada provides a cautionary tale about the results of command-and-control view of horses. More than a million wild horses once roamed Canada, according to the Canadian Wild Horse Preservation Society. But by 1965, after continual shooting and slaughtering, only four small herds survived. Three herds were in British Columbia and are now gone. By 1974, the official wild horse population in Alberta was only about 1,000. Biologists think this last surviving herd is doomed, too small to maintain its genetic health.
The US government should acknowledge that free-roaming horses and burros have inherent value as a species, and as individuals, and a long-term interest in living on this continent that should be respected. Accordingly, we ask the Advisory Board to declare that wild free-roaming horses and burros shall be protected from roundup, capture, and deliberate harassment. No removal should be authorized, unless the animal dies of natural cause; nor should sterilization or testing of sterilization be authorized.
The Advisory Board provides input and advice to the BLM as it carries out its responsibilities under the 1971 Wild Free-Roaming Horses and Burros Act. We urge the Board to recommend the following:
1. The BLM must not kill the animals.
2. The BLM must not sterilize the animals.
3. The BLM must not privatize the animals through adoption.
4. The BLM must not sell the animals – with or without limitation.
5. The BLM should use its best efforts to return the animals to freedom.
6. Any proposal to Congress to allot more money into for management purposes should place emphasis on genuine conservation.
7. The Advisory Board should urge Congress to discontinue roundups of equids.
The Wild Free-Roaming Horses and Burros Act was a response to a public outcry over roundups. Yet roundups were codified in the law. That's because in 1971, Congress saw the equids as "living symbols of the historic and pioneer spirit of the West." That rhetoric befits a made-for-television historical drama, but lacks biological, environmental, or ethical basis. In the past, people thought nature could be treated as though it existed for human purposes alone, and global warming had yet to be heard of. The Act's mission needs updating to match current human knowledge and an evolving environmental ethic.
Wild free-roaming horses and burros should be entitled to genuine and full protection of the law. Thus, no exemptions or permits should exist to sell or remove a wild free-roaming horse or burro from the public lands; nor should killing be authorized, except in such cases of illness or disability, in the best interest of the horse or burro.
In summary, the international animal-advocacy organization Friends of Animals submits that the only way to truly protect free-living horses on the pockets of public lands that constitute their habitat is to let them remain free. Instead of cutting back on conservation provisions, the Bureau of Land Management must augment them. This is sure to result in new questions and challenges. We are ready to help our lawmakers meet the challenge.
Submitted on this 3rd day of November 2008 by Friends of Animals
Priscilla Feral, President
Lee Hall, Legal Director
777 Post Road, Darien CT 06820
- See Federal Register, page 61436 (16 Oct. 2008). Available: http://regulations.justia.com/view/123846/
- Bureau of Land Management Public Lands Statistics, "Summary of the Authorized Use of Grazing District Lands" (FY 2004). Available: www.blm.gov/natacq/pls04/pls3-8a_04.pdf
- Robert Alison, "Last Roundup Feared for Canada's Wild Horses," Toronto Star (15 Oct. 2005).
- Deanne Stillman, "Wild Horses Aren't Free" - Los Angeles Times (2 Jun. 2008).
- Bureau of Land Management, "Wild Free-Roaming Horse and Burro Removal and Adoption by Office," Fiscal Year 2005 (Table 5-13). Available: www.wildhorseandburro.blm.gov/statistics/2005/pls5-13_05.pdf
- See FY 2005 Omnibus Appropriations Act, PL 108-447, Division E, §142, Sale of Wild Free-Roaming Horses and Burros, amending §3 of the Wild Free-Roaming Horses and Burros Act of 1971 (16 U.S.C. 1333) to allow sales if "the excess animal is more than 10 years of age; or the excess animal has been offered unsuccessfully for adoption at least 3 times." An equid meeting either criterion "shall be made available for sale without limitation, including through auction to the highest bidder, at local sale yards or other convenient livestock selling facilities, until such time as all excess animals offered for sale are sold; or the appropriate management level, as determined by the Secretary, is attained in all areas occupied by wild free-roaming horses and burros." Proceeds "shall be credited as an offsetting collection to the Management of Lands and Resources appropriation for the Bureau of Land Management; and used for the costs relating to the adoption of wild free-roaming horses and burros, including the costs of marketing such adoption." Sales were suspended in April 2005, in response to a public outcry over slaughtering.
- "Alliance Seeks to Stem Wild Horse Births" - AP State & Local Wire (13 Dec. 2005).
- As stated on the BLM website, on the public release "BLM's 'Seeds of Success' Program Aimed at Improving Health and Productivity of Public Lands" (24 Aug. 2007): "The Bureau's multiple-use mission is to sustain the health and productivity of the public lands for the use and enjoyment of present and future generations."
- Moreover, the United States — home to about 5% of the world's population — generates approximately 24% of the world's extra greenhouse gases. See generally U.S. Dept. of Energy, Energy Information Administration, "Emissions of Greenhouse Gases in the United States 2003," Report #: DOE/EIA-0573 (2003) (released 13 Dec. 2004); available: ftp://ftp.eia.doe.gov/pub/oiaf/1605/cdrom/pdf/ggrpt/057303.pdf, at page 2 ("US Emissions in a Global Perspective") following the Executive Summary.
- Thomas L. Fleischner, Review: From "Ecological Costs of Livestock Grazing in Western North America," Conservation Biology 8(3):629-644 (Sep. 1994). Available: http://archives.evergreen.edu/TESCWriters/AlumniWriters/Fleischner/FleischnerLivestock.html
- US General Accounting Office, Report to Congressional Requesters, "Public Rangelands: Some Riparian Areas Restored, but Widespread Improvement Will be Slow" (Jun. 1988).
- See David Krueper et al., “The effect of cattle removal on vegetation and breeding bird communities in riparian habitat, San Pedro River, Arizona, USA,” Conservation Biology, 17, 607-615 (2003); summary and link to the original available at: http://www.conservationevidence.com/ViewEntry.asp?ID=418. For background information on this area, “a rare remnant of the desert riparian ecosystem, a tantalizing trace of the extensive network of similar riparian systems that once existed throughout the Southwest,” see San Pedro Riparian National Conservation Area, "The Land's Story"; available: http://gorp.away.com/gorp/resource/us_blm/az_san_p.htm
- David Kreuper et al., US Geological Service's Forest and Rangeland Ecosystem Center, "Response of Vegetation and Breeding Birds to the Removal of Cattle on the San Pedro River, Arizona" (2003). Available: www.rangenet.org/trader/Kreuper_etal_2003.pdf
- Public Law 92-195 (15 Dec. 1971).