Statement from AWHC and RTF to the BLM Wild Horse and Burro Advisory Board

Statement of American Wild Horse Conservation and Return to Freedom

Presented to theBLMWild Horse and Burro Advisory Board

April 14, 2014, Presented bySuzanne Roy

This statement is made on behalf of the American Wild Horse Conservation (formerly American Wild Horse Preservation Campaign), a national coalition of more than 60 organizations, and our parent organization, Return to Freedom Wild Horse Sanctuary, based in California.

Wild horses are fenced in, fenced out, and given the scraps of forage in Herd Management Areas after theBLMhas allocated the vast majority tolivestock. They are forced to live under unnatural conditions, setting them up for crisis due to theBLM's failure to require reductions or elimination of livestock grazing in designated wild horse habitat areas to provide forage for horses.

Nosolutionsto this program will ever quell the intense controversy surrounding it without addressing the gross inequity of resource allocation on the 11% ofBLMlands designated as wild horse and burro habitat.

Wild horses are restricted to just 26.9 million acres ofBLMland, whilelivestockgrazing is authorized on 154 million acres. Yet even on this small amount of land designated for wild horse use, theBLMallocates the vast majority of forage to privately-owned livestock instead of federally-protected wild horses. Our survey, based onBLM's own data obtained through review of scores of Environmental Assessments, showed that more than 82% of forage in Herd Management Areas (HMAs) is allocated to livestock, while less than 18% is designated for wild horses.

The NAS addressed this gross inequity in resource allocation by stating thatequityand transparency are necessary when establishing AMLs and making them adaptable based on changes in social values.

A federal regulation (43 CFR 4710.5) gives theBLMthe authority to reducelivestockgrazing to make forage available for wild horses and burros in designated HMAs. Protection of wild horses is mandated by Congress, whilelivestockgrazing is authorized entirely at the discretion of the Interior Department.

Ms. Guilfoyle said that AML is foundational to the program. We agree. But as currently established, AML does not represent the carrying capacity of the land for wild horses, but rather the number of wild horses and burros theBLMhas decided to allow after giving away the majority of forage tolivestock.

Since Ms. Guilfoyle has pledged to maintain and improve transparency, we call for immediate disclosure of all forage allocations and actual use oflivestockAnimal Unit Months in every one of the 170-some HMAs. The public must be able to see what is happening on the small amount of land that theBLMhas designated as wild horse and burro habitat. This is basic transparency that doesn’t exist today.

Regarding the NAS report, it’s telling that Chief Guilfoyle did not address the recommendation that “tools exist now” to deal with many management challenges. The tool that is available right now isPZP. It’s proven, yet theBLMis vastly underutilizing PZP. Instead of investing resources in treating wild horses with native PZP, the agency is kicking the can down the road, asking for more money for research, pushing the solution off to the future. Worse,BLMis seeking funds for research into methods of population control, such as spaying of mares, that were specifically recommended against by the NAS.

Searching for a longer-acting fertility control vaccine is not an excuse for not fully utilizing the tool that is at hand, which isPZPfertility control. The statistics about lifetime holding costs for horses makePZPeven more cost-effective. YetBLMis just continuing the same “business as usual” that NAS found was “expensive and unproductive for theBLMand the public it serves.”

Regarding genetic diversity, burros are a very important issue of concern. Ms. Guilfoyle said that theBLMis monitoring to “make sure that we have no genetic problems with burros.” However, the NAS report was clear that the burro population has a genetic problem, a problem so serious that “removing burros permanently from the range could jeopardize the genetic health of the total population.” In addition, Dr. Gus Cothran has stated that one-third of wild horse populations are beginning to show low genetic variability in part because of the large number of horses that theBLMhas rounded up and removed from the range.

Finally, we’ve heard a lot today from ranchers about sage grouse, and I’d like to address some misrepresentations. As with other environmental concerns, it’s not wild horses, butlivestockthat present a threat to the sage grouse’s survival. TheBLM’s own statistics, disclosed in Environmental Impact Statements for sage grouse protection plans, demonstrate this clearly.

In Utah, for example, wild horse habitat overlaps just 2% of sage grouse habitat, whilelivestockgrazing allotments overlap 55% of mapped sage grouse habitat in the state. TheBLMallows just 253 horses and the annual equivalent of 75,760 cattle in mapped sage grouse habitat in Utah.

The statistics make one thing very clear: if you want to protect sage grouse, get rid of the cattle.

It’s time for theBLMto manage our public lands for all Americans, not just a small handful of individuals who profit from public lands grazing and the taxpayer subsidies that accompany that privilege. National opinion polls make the public position on this matter clear: 80% of the public opposes horse slaughter. 72% of Americans support protecting wild horses and burros on our public lands, and only 29% of the public wants our public lands to be available forlivestockgrazing. The prevailing public sentiment makes clear that when the health of the range is a top priority, the cows must come off first on the small amount ofBLMthat has been designated for wild horse and burro use.

Thank you for your consideration.