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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.[1]

November 03, 2008 | Horses

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,[2] 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.[3] At the beginning of the 20th century, 2 million mustangs roamed free.[4] 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.[5] Thousands of mustangs have been stored in corrals for long periods; at least a few have met their ends in slaughterhouses.[6]

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.[7] 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."[8] 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.[9] 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."[10]

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."[11]

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.[12] 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.[13] 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 a natural cause; nor should sterilization or testing of sterilization be authorized.

Conclusion

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."[14] 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
777 Post Road, Darien CT 06820
Contact: feral@friendsofanimals.org
Phone: 203-656-1522
Facsimile: 203-656-0267
--------------------------------------------------------------------------------
NOTES

[1] See Federal Register, page 61436 (16 Oct. 2008). Available: http://regulations.justia.com/view/123846/

[2] 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

[3] Robert Alison, "Last Roundup Feared for Canada's Wild Horses," Toronto Star (15 Oct. 2005).

[4] Deanne Stillman, "Wild Horses Aren't Free" - Los Angeles Times (2 Jun. 2008).

[5] 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

[6] 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.

[7] "Alliance Seeks to Stem Wild Horse Births" - AP State & Local Wire (13 Dec. 2005).

[8] 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."

[9] 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.

[10] 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

[11] US General Accounting Office, Report to Congressional Requesters, "Public Rangelands: Some Riparian Areas Restored, but Widespread Improvement Will be Slow" (Jun. 1988).

[12] 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

[13] 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

[14] Public Law 92-195 (15 Dec. 1971).

Comments

I wholeheartedly support your comments to the BLM Advisory Board concerning our wild horses. Thank you for submitting them. In your article you have a mistake about the current population and number rounded up. According to research there are only about 13,500- 16,000 wild horses still running free in all 10 Western states.Visit http://www.americanherds./blogspot.com/ for information. There are approximately 33,000 in holding facilites that have been rounded up from differet Herd Management Areas over a period of time. Also visit www.SaveOurWildHorses.org . It is most unfortuneate that the HSUS has agreed to the use of PZP by the BLM when there are not that many sustainable or genetically viable herds left.

Wild horses are one of our treasured National symbols. Please help save them

i WANNA HELP WILD HORSES I HAVE SOME HORSES OF MY OWN, AND SEEING THESE HORSES IT MAKES ME SAD, ON THE NEWS OF 11-16-08 I WAZ WATCHING THE NEWS AND IM TRYING 2 FINE OUT HOW 2 GET SOME WILD HORSES 2 BRING HOME.HELP

Speaking of BLM, Warren Buffetts, Rocky Mountain Power of Worland Wyoming is currently working at warp speed to cover power lines on BLM lands, that have been killing dozens of eagles. This according to Cody Wy, USF&W enforcement officer, Tim Eicher. Subpeonas have been handed out to numerous Rocky Mountain mangers. There are 4 crews working 6- 10 hour days to cover up their continued assualt on golden eagles. All under the nose of Warren Buffett.

I really don't understand why 60K wild horses spread out over the entire West / Southwest is a "problem." Isn't this a national treasure? Who is making this into a "problem," and why? What harm does it cause to let these animals simply run free? If some horses die of starvation, that's a natural consequence of a free roaming population allowed to fill to the boundaries of the ecosystem. Why should the taxpayer spend any money at all on helicopters, food, fuel, contraceptives, corrals, etc.? I don't get it. B.

What You Can Do to Help Save Cloud's Herd and America's Wild Horses. Get on the Cloud Foundations e-mail and participate in the educational articles and peaceful protest July 4 through August 30 2009. The Pyrors horses are scheduled for extermination!! Join the Cloud foundation today and write everyone!! Be Bold!! SPEAK UP and Hold Ground !! Over 40% of America’s wild horses have been removed from the wild from 2000-2008 alone and if the agency responsible for managing our wild horses, the Bureau of Land Management, does not change we are in danger of losing the last of our wild horses. Over 100 herds have been zeroed out from the over 19 million acres legally designated for their use. The BLM needs to return wild horses to these areas—over 30,000 are currently in government holding. As few as 13,600 wild horses remain in designated public land herd areas in ten western states in America, among them is Cloud’s herd in the Pryor Mountain area of Montana and Wyoming. Only 25% of our wild herds are currently at genetically viable population levels! Cloud’s herd is one of these although a massive round-up planned for August 2009 would change this. The round-up would result in 60 horses losing their families and their freedom, including some horses who have lived their entire 20+ years in the wild. We must stop the destruction of Cloud’s herd and work for the sustainable future of all our wild horse herds across the west.Congressmen Nick Rahall (D-WV) and Congressman Raul Grijalva (D-AZ) have stepped forward to make real and positive changes to the Wild Horse and Burro program with their recently introduced bill HR 1018. Please write to them to thank them for their hard work. You can read Ginger Kathrens’ comments and suggestions to the congressmen here. Here is a short list of government contacts -- please write, e-mail and/or call on behalf of Cloud and all our wild mustangs. Contact the following agencies and representatives PRESIDENT: President Barack Obama The White House 1600 Pennsylvania Avenue NW Washington, DC 20500 Comment line: 202-456-1111 www.whitehouse.gov/CONTACT/ CONGRESS: 1. Stop the BLM from managing our wild horses to extinction. 2. Halt all round-ups of wild horses until range conditions and herd numbers can be verified. 3. Return wild horses in holding to the 100+ herd areas (19+ million acres) that have been zeroed out. 4. Expand the Pryor Mountain. Wild Horse Range for Cloud’s Herd & protect herd at viable population level of at least 150 adult horses until range is expanded. Congressman Nick Rahall (D-WV) 2307 Rayburn HOB Washington,DC 20515 (202) 225-3452 email Congressman Raul Grijalva (D-AZ) 1440 Longworth HOB Washington, DC 20515 ph (202) 225-2435 fax (202) 225-1541 Email to: Laurel.Angell@mail.house.gov Your US Senators and Congress people Montana Senator Max Baucus (D)—specific to Cloud’s herd 511 Hart Senate Office Building, Washington DC, 20510, phone: 202-224-2651 e-mail from: http://baucus.senate.gov/contact/index.cfm Montana Senator Jon Tester (D)—specific to Cloud’s herd 204 Russell Senate Office Building, Washington DC, 20510, phone: 202-224-2644, e-mail from: http://tester.senate.gov/Contact/ Senate Energy & Natural Resources Committee: 304 Dirksen Senate Building, Washington, DC 20510 phone: (202) 224-4971, Fax: (202) 224-6163, e-mail all 23 members at http://energy.senate.gov/public/index.cfm?FuseAction=Contact.Home Reinstate wild horse protections removed in 2004 by the Burns Rider and include language in the bill that would prevent BLM from destroying healthy wild horses. DEPARTMENT OF INTERIOR- BUREAU OF LAND MANAGEMENT 1. Work to expand the legal boundaries of the Pryor Mountain Wild Horse Range to include the historic and current use areas in the Custer National Forest. This will allow for a truly viable herd of 200-300 mustangs. 2. Keep the population at a viable number of at least 150 adults until range expansion is achieved. This will allow for the preservation of the rare Spanish genetics of the herd. Bringing in horses from other herds is ill advised, unnecessary and costly. 3. Do not remove older horses 4. Work to protect the mountain lions that have kept the herd at zero population growth in years past. Natural management should be the goal. Secretary of the Interior Ken Salazar \ DOI, 1849 C Street NW, Washington DC 20240 Phone: 202-208-7351, exsec@ios.doi.gov BLM Acting Director Ron Wenker & Acting Deputy Director Mike Nedd 1849 C Street NW, Washington DC, 20040, phone: 202-208-3801 Ron_Wenker@blm.gov, Mike_Nedd@blm.gov Don Glenn BLM Division Chief of Wild Horse and Burro Program BLM Washington Office, 1849 C Street NW, Rm. 5665 Washington DC 20240 Phone: 1-800-710-7597 or 202-208-3801, Fax: 202-208-5242, wildhorse@blm.gov Jim Sparks, Field Manager BLM -Billings Field Office 5001 Southgate Drive, Billings, MT 59101 phone (406) 896-5223, fax (406) 896-5281 Jim_Sparks@blm.gov United States Department of Agriculture Secretary of Agriculture Tom Vilsack U.S. Department of Agriculture 1400 Independence Ave., S.W. Washington, DC 20250 Email: AgSec@usda.gov FOREST SERVICE Ask the following people to please work with the BLM to expand the Pryor Mountain Wild Horse Range to include the historic and current use areas in the Custer National Forest. This will allow for a truly viable herd of 200-300 mustangs. • Abigail Kimbell, Chief USDA Forest Service 1400 Independence Ave., SW
Washington, D.C.
20250-0003

 phone: (202) 205-1661, e-mail: akimbell@fs.fed.us • Mary Erickson, Acting Forest Supervisor- Custer National Forest PO Box 130, Bozeman, MT 59771, p. 406-587-6701, mcerickson@fs.fed.us • Chris Worth, Acting Deputy Supervisor 1310 Main Street, Billings, MT 59105 phone: 406-657-6200, cworth@fs.fed.us Please write letters to the editor, ask that your favorite radio and TV hosts cover this story and last but not least, please tell your friends and family about wild horses and ask them to join the Cloud Foundation in helping to protect and preserve wild horses on our public lands. List compiled by The Cloud Foundation, March, 2009 ~ www.thecloudfoundation.org

PRESS RELEASE For immediate release A Unified Call for an Immediate Moratorium on Wild Horse & Burro Roundups COLORADO SPRINGS, CO (The Cloud Foundation) – November 18, 2009 120 Organizations, celebrities and scientists in the United States, Canada, the United Kingdom and South Africa signed onto the following letter sent to the President, Congress and the Department of the Interior to rein in the Bureau of Land Management today. A Unified Call for an Immediate Moratorium on Wild Horse & Burro Roundups And a humane, fiscally responsible plan for preserving and protecting the iconic, free-roaming wild horses and burros of the American West President Obama, Members of Congress and the Department of the Interior: We, the undersigned, request major changes to the Bureau of Land Management's (BLM) Wild Horse and Burro program. This must begin with an immediate moratorium on all roundups. While we agree that the program is in dire need of reform, and we applaud your Administration's commitment to avoid BLM’s suggested mass-killing of horses, the plan outlined in October by Interior Secretary Ken Salazar raises numerous concerns. These include: • Perpetuating the flawed assumption that wild horses and burros are overpopulating their Western ranges. In reality, the BLM has no accurate current inventory of the 37,000 wild horses and burros it claims remain on public lands. Independent analysis of BLM’s own numbers reveal there may be only 15,000 wild horses remaining on public lands. • Continuing the mass removal of wild horses and burros from their rightful Western ranges: The BLM intends to spend over $30 million in Fiscal Year 2010 to capture more than 12,000 wild horses and burros. This stockpiling of horses continues even as an astounding 32,000 are already being held in government holding facilities at enormous taxpayer expense. • Scapegoating wild horses and burros for range deterioration even though they comprise only a tiny fraction of animals and wildlife grazing our public lands. Far greater damage is caused by privately-owned livestock, which outnumber the horses more than 100 to 1. • Moving wild horses and burros east off their Western homelands to “sanctuaries” in the east and Midwest at an initial cost of $96 million creates significant health concerns if animals adapted to western landscapes are managed on wet ground and rich grasses. Removing tens of thousands of horses and burros from their legally-designated Western ranges and moving them into government-run facilities subverts the intent of the 1971 Wild Free-roaming Horse and Burro Act, which mandated that horses be preserved “where presently found.” A 2009 DC district court case held that “Congress did not authorize BLM to “manage” the wild horses and burros by corralling them for private maintenance or long-term care as non-wild free-roaming animals off the public lands.” We appreciate your Administration's recognition of the horses’ value as an ecotourism resource. However, the display of captive, non-reproducing herds in eastern pastures renders them little more than zoo exhibits, further discounting the contribution to our history and the future of the American West. We believe that workable solutions to create a healthy “multiple use” of public rangelands, protect the ecological balance of all wildlife, and preserve America's wild horses and burros in their rightful, legally protected home can be achieved. We are calling on the Obama Administration to reform the BLM's Wild Horse and Burro Management Program. We ask that you reverse the current course and immediately take the following actions: 1) Place a moratorium on all roundups until accurate and independent assessments of population numbers and range conditions are made available and a final, long-term solution is formalized. 2) Restore protections included in the 1971 Wild Free-Roaming Horse and Burro Act. Update existing laws that protect wild horses by reopening certain public lands to the mustangs and burros, thus decreasing the number in captivity. Return healthy wild horses and burros in holding to all available acres of public land designated primarily for their use in 1971. If these lands are not available, equivalent and appropriate western public lands should be added in their place. 3) Support federal grazing permit buybacks. Reduce livestock grazing and reanalyze appropriate management levels for herd management areas to allow for self-sustaining, genetically-viable herds to exist in the west. 4) Conduct Congressional hearings regarding the mismanagement of our wild herds and further investigate the inability of BLM to correct the shortcomings of the program as audited by the Government Accountability Office’s 1990, 1991 and 2008 reports. Supported by the undersigned on November 16, 2009 For further information & photos please contact: Makendra Silverman The Cloud Foundation 719.633.4933 office 719.351.8187 cell info@thecloudfoundation.org www.thecloudfoundation.org Spokesperson: Ginger Kathrens Volunteer Executive Director The Cloud Foundation 719.633.4933 ginger@thecloudfoundation.org

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