Mares and foal in Onaqui Mountains in Utah (photo: Carol Walker)

by Debbie Coffey, V.P. & Dir. of Wild Horse Affairs, Wild Horse Freedom Federation

In my humble opinion:

The ASPCA, Return to Freedom, HSUS, Humane Society Legislative Fund, and the little known American Mustang Foundation (formed by lobbyists in 2016) are signatories on a proposal titled “The Path Forward for Management of BLM’s Wild Horses & Burros” that is really a road to extinction for America’s wild horses & burros on public lands.

In this proposal, ASPCA, HSUS, Return to Freedom, Humane Society Legislative fund and American Mustang Foundation didn’t ask for viable herd numbers to be established or for the return of captured wild horses & burros to millions of acres of public lands that have been taken away from them.

These organizations completely capitulated to the signatories representing the interests of the powerful livestock grazing industry:  National Cattlemen’s Beef Association, American Farm Bureau Federation, Society for Range Management, Public Lands Council, National Horse and Burro Rangeland Management Coalition (organizers of the secretive 2017 “Slaughter Summit” in Utah that was co-hosted by the Utah State University and the state of Utah), Eureka County Nevada Commissioner Office (headed by J.J. Goicoechea, a past President of, and a current Executive Committee Member, of the Nevada Cattlemen’s Association), Beaver County Utah Commissioner Office, and the Utah Governor Office (Gov. Gary Herbert, who delivered the welcome at the 2017 “Slaughter Summit”).

These organizations representing livestock grazing interests have been rabidly pushing for the slaughter of America’s wild horses & burros for years.

How did the ASPCA, Return to Freedom, HSUS, Humane Society Legislative Fund and the American Mustang Foundation lobbyists sell out America’s wild horses & burros?

They put the names of their organizations on a document that presents false assumptions and lies about our wild horses & burros.

They agreed to the roundup of 15,000-20,000 wild horses & burros per year for 3 years, fertility control for 90% of the mares remaining on the range, AND sex ratio skewing of 70% stallions to 30% mares.

If there were any real negotiations, it seems there was not one compromise by the groups representing livestock interests.  In fact, there was not even a mention of any of the many problems caused by privately owned livestock grazing on public lands.

So, LIE #1 is the basis of this entire proposal, that defines “THE PROBLEM” as being too many wild horses & burros on public lands, the costs of roundups and holding facilities, and blaming wild horses & burros for seemingly all of the damage to rangelands.

THE REAL PROBLEM is the millions of privately owned livestock grazing on public lands.  Specifically:

  1. Privately owned livestock grazing on public lands have grown bigger and are eating more forage. Mike Hudak wrote an article in 2013 containing a statement that applies not only to USDA’s Forest Service, but also to the Department of the Interior’s Bureau of Land Management:  “Research by Daniel W. Uresk (Senior Research Biologist, USDA Forest Service) finds that the weight of cattle that graze on Forest Service lands in 30 states has since 1980 increased on average by 124 pounds. One implication of this finding is that the monthly unit of forage consumption per cow-calf pair (the AUM), generally accepted as 900 pounds of forage per month is an underestimate. Based on Uresk’s findings, cow-calf pairs today across Forest Service lands in 30 states are on average consuming 52 pounds of forage more per month than in 1980. Yet the Forest Service is managing the cattle on those lands based on estimates of cattle consumption in 1980 or earlier.”                                                                                                                                                                                             
  2. AUMs on public lands need to be updated and clarified.  The BLM and the Forest Service define an AUM (animal unit month) as: “The amount of forage needed to sustain one cow, five sheep, or five goats for a month.”  Dr. John Carter in his 2016 report titled “Updating the Animal Unit Month” noted that “BLM, for example, has typically used 800 lbs/month of forage as the consumption rate for a cow/calf pair. BLM also does not clarify if this is air dry or oven dry weight….They use a value of 26 pounds of forage per day for a cow calf pair and have used other values such as 34 pounds per day for a “head month” or cow/calf pair. These inconsistencies need resolution.”                                                                                                                                                                                                                                                                                            
  3. The BLM continually hides data regarding (and damage caused by) livestock grazing on public lands. Recently, a press release by Public Employees for Environmental Responsibility (PEER) titled “BLM Commercial Grazing Program Goes Undergroud” states that “The U.S. Bureau of Land Management (BLM) website has demoted commercial livestock grazing from a program to a sub-program, sharing equal billing with “reindeer grazing in Alaska.” This “reflects a broad abdication of responsible range management because data about conservation outcomes and resource abuses are no longer available. For example:
    • The last time BLM published Rangeland Inventory Monitoring Evaluation (RIME) data was for 2015; that showed more than one-third of lands assessed failed to meet BLM’s own Standards for Rangeland Health reflecting minimum quality of water, vegetation and soils – a total of 40 million acres, or about the area of Washington State. The overwhelming portion (more than 70%) of range health failure was due to livestock overgrazing in allotments covering more than 30 million acres, the size of New York State. BLM has not published RIME data since 2015;
    • Last month, BLM lowered grazing fees to the lowest level allowed by law, under the rationale that “public rangelands remain healthy, productive working landscapes” – a claim for which it offers zero evidence, nor has it answered a Freedom of Information Act request for the justification; and
    • Despite two critical Government Accountability Office reports, BLM does little to detect or deter unauthorized grazing, ala Nevada’s infamous Cliven Bundy. A 2018 PEER lawsuit confirmed that the agency still does not even monitor grazing trespass from year-to-year.”                                                                (PEER has also written about the need for grazing reform and the problems with the BLM’s grazing data.)

In fact, in the BLM’s 2017 Public Lands Statistics (issued June, 2018), on Page 41, Table 2-1, Health of Public Grazing Lands Administered by the BLM, all data was completely omitted, with the explanation “Table 2-1 is reserved for use in a future edition of Public Land Statistics and is currently in development.” 

4)  Livestock grazing fees need to be raised to market rate.  In 2019, George Wuerthner (ecologist and President of the Board of Directors of Western Watersheds Project) wrote “The federal government just reduced its grazing fee to $1.35 an AUM for ranchers with grazing privileges on Bureau of Land Management (BLM) and Forest Service lands.  “According to the non-partisan Congressional Research Service, grazing on private lands typically runs $22.60 an AUM or more for leases on private lands.  Due to failure to keep up with inflation, the price paid to graze on public lands is estimated by one 2015 study to be more than a billion dollars annually and covers only 7% of the real costs of administrating these lands. 

Other concerns with, and lies contained within, this proposal:

This proposal offers a “solution” of “safe and humane growth suppression strategies.”  But these groups cannot promise this.  The BLM has just announced another Environmental Assessment to use an outdated, barbaric sterilization procedure on wild mares.

What cattlemen consider to be “humane” may not be what you consider to be humane.  It is a subjective term.

This proposal has included the BLM’s estimates of the population of wild horses & burros on federal lands as over 81,951.  However, Wild Horse Freedom Federation’s 2017 White Paper (p. 35) noted that the BLM’s own population estimate data has been inaccurate and unscientific for years.  The BLM’s own data has claimed some herds increased by as much as 750% to 1250% in only one year.

This proposal focuses on the cost of wild horses & burros in BLM holding corrals and pastures.  However, the real truth is that thousands of horses that were supposedly in off-range pastures were seemingly not actually in those locations.  Somehow, those horses disappeared.  (See the White Paper, p. 22)

Part of the “solution” of this proposal is to “make progress toward” (maintain) the currently established national AML (Appropriate Management Level) of wild horses & burros.  This is no solution, because most of BLM’s AMLs do not allow the minimum numbers needed for a viable herd.

This proposal claims these groups share common goals for rangelands, including ecosystem health.  However, Erik Molvar, Executive Director of Western Watersheds Project, in The 10 Big Lies of Traditional Western Politics wrote “Wild horses are a rare sight, so for the overwhelming majority of lands that are in poor condition, the domestic livestock are the cause when land health and wildlife suffer. Even where wild horses do occur, the impacts of horses are vastly outweighed by the damage caused by the domestic livestock that graze on public lands, which outnumber wild horses on the range by more than 36 to 1.”

This proposal intends for tens of thousands of wild horses & burros to be placed on private lands.  This removes America’s wild horses & burros from public access, and in spite of seeming promises, there will be even less accountability.  The public will likely not be able to file Freedom of Information Act (FOIA) requests for the records of these private facilities.

These groups have filed few, if any, FOIA requests to obtain records regarding the operations and activities at BLM holding facilities, especially long term, off-range pastures.  So it is doubtful they have a working knowledge of the compliance and accountability issues involved or improvements that are needed.

While pushing to remove America’s wild horses & burros from public lands, this proposal claims that “failing to act now will result in continuing irreparable, long term damage to our natural resources.”  How does this make sense when considering statistics on page 77 of BLM’s 2017 Public Lands Statistics, showing that out of the total of 7,564,895 AUMs, only 38,157 AUMs are for wild horses & burros?  The other 7,526,738 AUMs are going to the millions of privately owned livestock on public lands.  Again, (and we need to stress this) it’s the millions of privately owned livestock doing damage to our public lands.

No wild horse advocacy groups with nothing to gain and who have actual experience and knowledge of managing wild horses on the range were consulted or even informed of this plan.  These groups do not speak for the vast majority of wild horse advocates.
The BLM does not own our wild horses & burros – they belong to the American public and the American public wants to see them continue to remain wild and free on our public lands, not rounded up and incarcerated in holding facilities for the rest of their lives.
This extremely expensive and ill-advised plan to roundup and remove 15,000 – 20,000 wild horses & burros in 2020 will cost $15 – $20 million and storing them in holding facilities will add $30 million for just one year to the BLM’s budget.
The plan to have the National Cattlemen’s Beef Association and other pro-horse slaughter livestock groups help to “increase” adoptions, especially with BLM’s new $1,000 adoption incentive, is likely to lead to more wild horses & burros being adopted, then “titled” and becoming private property, and then ending up in the slaughter pipeline.  (Just like now, but on a larger scale.)
This plan prioritizes cattle over wild horses – 80% of the forage in wild horse herd management areas is allocated to privately owned livestock.
Do you trust that the National Cattlemen’s Association and other groups that have been advocating for horse slaughter will find “good homes” for our wild horses & burros?
This proposal does not offer a brighter future for wild horses & burros, and it is not a “new dawn” or “new territory.”  No matter how any of these groups try to spin it, this proposal is a complete sell out.
It is likely that a large percentage of these wild horses & burros will end up at slaughter.

In conclusion, Wild Horse Freedom Federation and most wild horse & burro advocacy groups OPPOSE this proposal.

If you OPPOSE this proposal, please contact your Congressional representatives and tell them you OPPOSE the proposal titled “The Path Forward for Management of BLM’s Wild Horses & Burros” by HSUS, ASPCA and others.