Eyewitness Report on the BLM Wild Horse and Burro Advisory Board Meeting
April 14-15, 2014
As always, attending these board meetings is a frustrating experience. This board is stacked against the horses, dominated by members from the livestock industry. The BLM as always appears to be spinning its wheels. The agency wants to spend millions of dollars on research into “population suppression methods” but is ignoring the proven fertility control tool it has on hand – the PZP vaccine which has proven safe and effective over more than two decades of use in wild horses. Instead of employing this proven technology immediately, as recommended by the National Academy of Sciences, the agency is doing nothing to reduce population growth on the range.
Having caused an off-the-range crisis by stockpiling an astounding 50,000 wild horses in holding facilities, the BLM is now busy creating an on-the-range crisis by failing to reduce livestock grazing in wild horse Herd Management Areas, despite drought conditions; failing to use available fertility control to reduce population growth rates; and curtailing removals. And, the agency is revising its SOPs for killing wild horses on the range as “an act of mercy” after setting them up for suffering by failing to address livestock grazing in HMAs and failing to secure water sources for horses within designated habitat areas.
Interestingly, even the pro-livestock members of the board are perplexed at the BLM’s failure to use available fertility control. Board member Rick Danvir remarked, “One tenth of one percent of the program budget is focused on field fertility work. It’s every bit as important to start doing some things at a much larger scale now with what we’ve got, then to put it all into research. This should be a bigger line item in the budget.” BLM’s Dean Bolstad replied that BLM’s general policy is to only capture horses to remove them, not to apply fertility control without removals. When he asked if the Board was suggesting BLM change the policy and capture horses to apply fertility control and then release them, even if they were over “appropriate” management level (AML), board chair Boyd Spratling answered: “Yes that is what we are saying. To be paralyzed and not do anything because we cannot remove horses is foolish.”
In addition to funding research instead of action on humane fertility control, the BLM is also investing millions to count horses in HMAs. Although improving and standardizing census methods is badly needed, the failure to couple population surveys with administration of fertility control has a predictable end: the BLM will say that there are even more horses out there than we thought and after much hand-wringing we’ve decided that the only possible solution is to kill the horses on the range, or sell them for slaughter off the range. It’s where this program has been headed for years.
Advisory Board member Tim Harvey insightfully described the situation at the meeting: “BLM is like a big tanker but eventually when you turn the helm, the ship will follow.” The problem is, despite promising to turn the helm, the BLM and Department of the Interior leadership have not meaningfully changed direction, and the ship is continuing on a path to destruction.
As important as what was said at the meeting is what was not said. There was no talk of drought or reducing livestock in HMAs pursuant to the Code of Federal Regulation 43 CFR 4710.5, which provides BLM with the authority to close HMAs to livestock grazing “If necessary to provide habitat for wild horses or burros… to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury…” There was an oblique reference to killing horses in poor body condition on the range, but no owning up to the BLM’s role in setting up the horses for this situation in the first place.
No mention was made of the Office of Inspector General’s into the BLM’s sale of 1,700 federally-protected wild horses to a known kill buyer, Tom Davis, except to note that the BLM employee who sold Davis the horses has been “detailed to another department at BLM.” And significantly missing was any discussion of exploring the repatriation of wild horses in holding to zeroed out Herd Areas (designated habitat from which BLM has eliminated all horses) as one solution to the off the range holding crisis.
Please read on for a detailed report on the meeting. To view AWHPC’s press release about the board meeting, click here.
What follows here is a detailed report on key aspects of the meeting.
The Board has three new members:
Interestingly, Dr. Robert Bray, who was the previous representative on the board for the wild horse and burro research category, was not asked to serve again by the BLM. During his time on the board, Dr. Bray exhibited independence and a willingness to question the BLM on its policies, and in particular the science behind them. It is unknown whether Dr. McDonnell will continue on that path as a badly needed independent scientific voice on the advisory board is sorely needed.
In total, the board remains overwhelmingly stacked against the wild horses, with five of nine members having clear ties to the livestock industry:
Also attending the Board meeting this month was Greg Shoop, assistant director of the BLM’s Division of Renewal Resources and Planning.
The BLM’s Wild Horse and Burro Division Chief Joan Guilfoyle was not present at the meeting, due to a family emergency, but provided a program update via telephone. Representing the wild horse and burro program at the meeting was Dean Bolstad, Wild Horse and Burro Senior Advisor.
Sage Grouse Conservation Plans – Comments periods for all Environmental Impact Statements have closed. The comments are being analyzed and the BLM is figuring out what the proposed projects will look like in the end. Their goal is to get the final plans out by late summer or early fall at the latest.
National Academy of Sciences Report –The BLM has no response to this report in writing nearly one year after it was released. Mr. Shoop noted, ““You haven’t heard a lot from us on this” but claimed that BLM has been “quietly engaged in getting some things done.”
Budget – Program was funded at $77 million for Fiscal Year 2014. This budget allows BLM to continue “critical operations” and to “implement the NAS recommendations.” The President’s budget for FY 2015 calls for $80 million for the Wild Horse and Burro Program, which “allows for more implementation of NAS recommendations.” Mr. Shoop stated that the major focus is on more research.
Editor’s Note: In reality, instead of implementing the NAS recommendations, the BLM has been cherry-picking its findings. The agency has seized on the NAS finding that the current census estimates likely underestimate the number of wild horses on the range. Therefore, the agency is spending millions of dollars to count horses in FY 2014. While improving census methods and having accurate population counts is certainly a worthwhile goal, the BLM’s concentration of resources in this area, while significantly scaling back funding for on-the-range management through existing PZP fertility control, is worsening the situation. The agency also seeks millions of dollars for research into new “population suppression methods” and is pushing hard for spaying and neutering horses – surgical procedures that were specifically recommended against by the NAS.
Meanwhile the NAS’ strong warning that “continuation of business as usual practices will be expensive and unproductive for the BLM and the public it serves” is being ignored. The NAS found that “tools already exist for BLM to address many challenges.” The primary tool available now as identified by the NAS is PZP fertility control, which has proven to be safe and effective in over two decades of use on wild horses. Yet the BLM is REDUCING its use of this drug, targeting fewer than 500 mares for vaccination this year, down from the 2,000 per year promised under the agency’s “accelerated reform” strategy announced in 2011.
California Wild Horse Population:
California Burro Population:
BLM California is working with the Sacramento County Sherriff’s Department to set up a wild horse training facility – horses to be used in law enforcement. The facility is presently under construction. Inmate training is scheduled to begin by FY 2015. Conveniently located near I-5 and SR 99; in partnership with U.C. Davis.
Adoptions are down in California:
BLM California relies on partnerships & events for adoption.
The board’s charter expires on July 21, 2014. The charter commissions the board to advise the Interior Secretary and the administration on its policies. The board was originally chartered to write a report. It was reconstituted to evaluate a strategy and produce a report. The Interior Secretary has chosen to reappoint and reconstitute the board every two years since it was created.
The Board’s bylaws and SOP’s are board documents, the content of which is at the discretion of the board.
The estimated operating cost of the Advisory Board is $128,500 annually
Callie Hendrickson, the pro-slaughter cattlewoman who is supposed to represent the “public at large,” took this discussion as an opportunity to express her “frustration over the entire program and how the board is being used.” “This board over years and years has made some really good sound recommendations and we’re going the opposite direction right now,” she said. Chief among Hendrickson’s frustrations is that the BLM is not selling captured wild horses for slaughter.
Guilfoyle joined the meeting by phone. Key points she addressed include:
Three open positions on the Advisory Board – a federal register notice announcing that BLM is accepting applications for the following positions will be forthcoming:
BLM’s response to Advisory Board recommendations/NAS findings.
It was difficult to follow much of Guilfoyle’s presentation, as she was referencing a binder that was given to the Board but not made available to the public at the time of the discussion. However key points from her responses include:
Editor’s Note: the funds are being used to conduct census surveys, not to implement tools identified by NAS to manage horses on the range, i.e. PZP fertility control.
Editor’s note: BLM is asking for funds for research into methods NOT recommended by the NAS.
Editor’s note: AML’s do not represent the carrying capacity of the land for wild horses. Instead they represent the number of horses the BLM has decided to allow after giving away the vast majority of forage to livestock. By BLM’s own admission, nearly 80 percent of forage in designated Herd Management Areas is allocated for privately-owned livestock instead of federally-protected wild horses and burros.
Editor’s Note: The BLM is using this recommendation to ignore the NAS recommendations regarding fertility control and to pursue invasive and destructive methods that were specifically recommended against by the NAS.
Human Resources Updates:
BLM has reorganized program:
BLM Updating Instruction Memoranda:
Comprehensive Animal Welfare Program
Board member Tim Harvey commented that in his experience, horses will always seek out areas of lowest wind in cold temps and shade in hot temps. Doesn’t take academic experts to know that horses prefer this – it is common sense. He asked why BLM did not accept offers of donations (through Cloud Foundation) for windbreaks, if for nothing else than to foster good feelings. Guilfoyle replied that they will work with people who want to work with BLM and not be “it’s my way or the highway.” Horse experts at BLM do not agree that wild horses need wind breaks and that’s why they’re consulting outside experts. Harvey noted that BLM requires every adopter to have a three-sided shelter for every horse. This is a requirement for minimum care and the agency makes compliance checks to ensure that this is provided. This may be a place where people who want to help the horses can donate money and labor to make the lives of some of these horses in holding a little bit better. Callie Hendrickson chimed in that she has a different opinion. She believes that horses do not need shelter from the elements and that the adoption requirements are too strict.
Guilfoyle presented slides that painted the bleakest possible picture regarding wild horses in the West. For the first time, BLM is now including all wild/”feral” horse populations in its presentation, and showed a map that depicted areas in which wild horses live not only on BLM and Forest Service land, but also on tribal, Department of Defense and National Park Service land. She then posited – without evidence – that there are probably over 50,000 wild horses on BLM land and 150,000 – 200,000 wild horses out there. “All very charismatic animals. People love them. They have no real predators. They double in population every four years. They are assertive foragers. They’re across the landscape on a massive scale. We need to think about that as we think about how to address this.” She then presented slides that showed, among other things that with no management action, wild horse populations will grow to 1 million by 2030.
Editor’s note: Guilfoyle’s discussion here perpetuated the BLM-promulgated myth that wild horses are overpopulating the West. Her presentation failed to include any perspective or context for this discussion, such as how many millions of acres these horses inhabit, or the fact that tribal horse population estimates are completely without foundation. (At the previous BLM advisory board meeting, a Navajo tribal official told the BLM that their horse population estimate was based on the idea that every person on the reservation had three or so horses!) The basis of her projections of horse population numbers without management is unknown, but it does not appear that she factored in natural horse attrition (deaths) and population self-regulation mechanisms that would kick in as populations arise into these outlandish projections.
Guilfoyle claimed that the cost per horse for lifetime holding was $46,252 and that “Every time we remove 1,000 animals from the range, we just made a commitment of $46 million dollars.”
Later, upon discussion, BLM’s Dean Bolstad admitted that the estimate was a worst case scenario, based on a horse spending his or her life in short term holding which is far more expensive than long-term holding pastures. (The BLM is concerned about losing long-term holding space, as beef prices are up and ranchers can make more by running cattle than by housing horses for the BLM.)
Public lands rancher and Advisory Board member John Falen commented that his foundation, which is a lobbying organization for ranchers who receive tax subsidized grazing on public lands, had made the same projections and “it’s absolutely not sustainable in the direction we are going.” Of course, no one disagrees with Falen’s assessment; the public does disagree, however, with his proposed solutions: slaughter of captured horses and surgical sterilization of wild horses on the range.
Humane advocate Tim Harvey noted that these numbers only strengthen the case for on the range management of horses. If you’re not removing horses, you “don’t have to warehouse them, you don’t have to feed them. They’re not costing us anything.” He added of course, that horses must be maintained at a sustainable level
SPAY VAC Pasture Trial:
SPAY VAC April 2014 New Study:
Carson City Prison pen trial – started 2011:
Request for Applications for Research Projects
NAS related research projects (This year with USGS (DOI research arm) – beginning these studies):
BLM creating a foundation to fund research.
PAUL GRIFFIN, US GEOLOGICAL SURVEY – POPULATION SURVEYS
“Wild horses represent a lot of things to a lot of people. They’re strong, resilient, inhabit beautiful parts of our country. They remind us of our history. They mean so much to so many people. They have attributes that remind us of pioneers coming across the west. They’re fertile as many of our ancestors were.”
We can use knowledge from other aerial surveys conducted for wildlife to learn about accuracy and precision for wild horses and burros. All agree that the first step for making management decisions is knowing how many horses there are in HMAs or other management areas.
Mr. Griffin went on to describe the two methods they are using to count horses (Mark/Resite and Simultaneous Double count), and the models and methods used to calculate detection bias – how to account for the horses that are not seen. Mark/Resite method involves taking pictures of groups of horses and identifying them through marker horses (horses with unique color or other markings). Simultaneous double count method involves two teams of observers counting horses and comparing count results.
Best methods for counting horses in specific HMAs depend on many factors including how much color variation there is among the horses, how big the area is, how much cover there is, etc.
The USGS is bringing a lot of statistical information into the analysis of which method is right for which HMA and how to individualize detection bias for each HMA. Previously, there was no standardized census method for BLM.
Mr. Griffith also noted that USGS is developing more tools for population estimates including:
DEBBIE COLLINS: ADOPTION PROGRAM
Other presentations were made by programs adopting out horses and burros, including Mustang Heritage Foundation, the Northern Nevada Correctional Facility training program and the Platero Project of the Humane Society of the United States (for burros).
The board discussed many aspects of the program and workings of the board.
Why isn’t BLM using fertility control?
The most interesting line of discussion centered on the BLM’s lack of focus on using PZP fertility control. Board members took BLM to task on this issue:
“One tenth of one percent of the program budget is focused on field fertility work. It’s every bit as important to start doing some things at a much larger scale now with what we’ve got, than to put it all into research. This should be a bigger line item in the budget.” – Rick Danvir
“This [using available PZP fertility control] is actually a major recommendation of the NAS.” - Boyd
“If you don’t have holding capacity, you’ve got to stop gathering. The fact that there is no gathering and you’re not doing any fertility control, that’s a big frustration. Where was money diverted to?” – Callie Hendrickson
Dean Bolstad explained that the BLM has used fertility control (in his words “population growth suppression”) only in conjunction with removals. In other words, if they’re not going to remove horses from the range, BLM has no interest in gathering them. He asked if the Board was suggesting the BLM change that policy and go into the HMAs over AML and just treat horses with PZP.
Boyd Spratling answered emphatically: “Yes that is what we are saying. To be paralyzed and not do anything because we cannot remove horses is foolish. Since none are coming off, maybe you need to treat more animals. Be more liberal with the treatment. The goal is still to achieve AML but maybe this is step one.”
Dean Bolstad responded that the budget includes treatment of just 450 mares this year with PZP. Application is mostly ground treatment via darting.
Board members remarked that the number was so minimal that it is hardly worthwhile. They asked why the money that had been earmarked for removals couldn’t be moved over for large gathers for fertility control.
“I know you’re not totally satisfied with PZP, but if we could do 4,000 horses and not 400 we can start to make a dent. I just had visions of a larger scale field trial/management action for this year.” – Rick Danvir
“By slowing down the reproductive rate, we slow down the need for removals. This option [PZP fertility control] is accepted by the public.” –Boyd Spratling
“Why isn’t the BLM using PZP? If BLM isn’t going to gather for removals, why can’t the money be used to round up every single mare and PZP them? That will cover 1-2 years of greatly reduced growth rate. That makes a lot of sense. We have an opportunity to gather and use PZP. Let’s gather 4,000 horses and use fertility control.” – Tim Harvey.
BLM’s Greg Shoop responded that he believed if you gather up the horses and treat them, you’ll never find them again. (Editor’s note: This is not supported by evidence or experience.) He stated, “We want to touch them once and never touch them again,” confirming BLM’s preference is for destructive sterilization of horses on the range.
Although rancher and board member John Falen stated his clear preference that BLM surgically spay/neuter wild horses, he agreed that BLM was “not going to physically spay enough mares to make a difference.” So he agreed that PZP “might be the only option.” BLM should “select areas where you can gather horses more than once and go in there and give those mares a shot.”
Bolstad indicated that vaccinating mares with PZP on a large scale would take more helicopters and a larger budget, something most Board members seemed to support. “These are complications, not roadblocks,” said one board member.
Regarding spaying of horses pushed by Falen, Spratling and a few others, Shoop stated, “We get it. We are interested in doing something as fast as we can. John, the fact is that we have to be judicious and prudent in how we go about it. We do have an obligation to do this in the best way we can so that the health of the horses is ensured. ….There is a difference between a domestic horse in a domestic situation and a wild horse. We want to be relatively sure that we’re pretty confident that what we’re doing is going to work and the horses are going to be ok.”
Once again, the BLM gave Callie Hendrickson a forum to show pictures of emaciated horses on barren land to prove her point of view that wild horses are destroying the range. Ironically, some of the photos Hendrickson used in her slide show were 9 years old. When questioned about why, if there is such an urgent crisis on the range, she would not have a wealth of current photographs demonstrating the dire situation, she said she was just trying to show how range deterioration can impact horses. Of course not a word of her presentation was devoted to the impacts of the vastly larger number of livestock on the public rangelands.
Hendrickson put on her slide show to lead into a discussion of how, in her opinion, BLM was “violating NEPA (National Environmental Policy Act) by leaving horses in the HMAs over AML. She put forth the recommendation that BLM conduct an Environmental Analysis of the environmental impacts of its decision not to roundup horses in HMAs over AML. Excluded from her “analysis” was the fact that BLM has the authority to restrict or eliminate livestock grazing on the 11% of BLM land that is designated as wild horse and burro habitat, and that by simply reducing livestock grazing levels, the land could easily accommodate current wild horse populations.
The Board concluded with three recommendations: