PEER Report Finds Livestock Outnumber Wild Horses/Burros 125:1 

By Amy Hadden Marsh

(December 15, 2022) In FY 2022, the Bureau of Land Management (BLM) rounded up 21,971 wild horses and burros from public lands in the West, permanently removing 20,169 of those animals. More than 64,000 wild horses and burros are warehoused in BLM and private holding facilities across the country - the largest number of wild horses and burros to be held in captivity since the BLM Program began. The agency likes to claim that the number of wild horses and burros is out of control and that the animals are degrading the range. But, what the agency fails to acknowledge is the damage caused by livestock grazing on those very same rangelands. A recent study by Public Employees for Environmental Responsibility (PEER) found that livestock outnumber wild horses and burros on public lands by more than 125:1. And, the agency’s own land health data neglect to prove that wild horses are the cause of rangeland degradation. In fact, PEER states that livestock grazing is the main culprit.

PEER data overview

In March 2022, using BLM ‘s rangeland assessment data from 1997 - 2019, PEER published an interactive map, depicting range conditions on 21,000 grazing allotments covering 155 million acres of public lands in the West. “BLM is required to conduct assessments about every 10 years, but this target has never been met,” said Chandra Rosenthal, Rocky Mountain Office Director for PEER. “Many have never been formally assessed by the agency since the requirement went into effect in 1997.” In fact, PEER’s map shows that  27% of all grazing allotments - over 40 million acres -  have never been assessed. 

In certain situations, a federal loophole  - called the “National Environmental Policy Act (NEPA) exception” - allows the agency to legally forego land health assessments. “It was mandated so [BLM] could expedite permits,” said Rosenthal. The NEPA exception was initially created to help with a backlog of permit renewals. “When Congress did it, the idea was that they're going to let BLM catch up and then the use of the loophole would eventually go away,” she explained. “Instead, it's been increasing exponentially.” A recent report by Western Watersheds Project, an environmental watchdog organization, found that the amount of grazing allotments authorized without a NEPA analysis has almost doubled between 2013 and 2021. 

BLM allotment data not available to the public

PEER’s map reflects all records received via Freedom of Information Act (FOIA) requests from BLM as of 2020. Significantly, the agency does not maintain grazing allotment land health standards evaluation records in electronic format or in any centralized location.  Nor does the agency track the actual number of acres that fail federal land health standards. Rosenthal told AWHC that the process for obtaining these records is time-consuming. “BLM rangeland assessments are on paper and kept in filing cabinets,” she explained. “The [BLM] National Operations Center has to request [from] each field office that they compile their most recent records and submit them to the state office, where they are compiled and sent back to the National Operations Center.” PEER analyzed the data in 2021 and published the map the following year.

To be clear, BLM posts certain data to the agency website, including annual Public Land Statistic (PLS) reports, dating back to 2001. But, said Rosenthal, “The PLS reports reflect the BLM’s permitting process, not rangeland health.” PEER found problems with agency dataset accuracy, resolution, completeness, timeliness, omissions, and inconsistencies. Other report highlights include: 

  • BLM land health standards (LHS) were met on 54,500,000 acres of land assessed,
  • LHS not met on 54,000,000 acres of land assessed,
  • Livestock grazing is the reason why 72% of rangelands did not meet land health standards,
  • 41,000,000 allotment acres have not been assessed.

BLM rangeland management practices promote double standard 

In November 2022, PEER took a deeper dive into the data to get a clearer picture of wild horse and burro impacts on the range. Despite BLM and ranchers’ claims that wild horses and burros are primarily responsible for range degradation, this is not what the data show. “The key finding is that wild horses are responsible for a failing allotment less than 1% of the time compared to livestock,” explained Rosenthal. Yet, in most cases, wild horses and burros are the first to be removed from the range if BLM determines the range is degraded. 

“The key finding is that wild horses are responsible for a failing allotment less than 1% of the time compared to livestock,” explained Rosenthal.

This double standard was abundantly clear in Colorado in 2022. The BLM used drought conditions as a reason why wild horses in the Piceance-East Douglas Herd Management Area would be removed but, reported PEER, the agency neglected to issue an official nationwide or statewide drought call, which requires a reduction of livestock on the range.  

BLM data analyzed in the PEER report show:

  • Of all allotments that failed LHS standards, 72% was due to livestock grazing, 
  • 86% was due to a combination of livestock and wild horses.
  • Horses were the sole cause of LHS failure on 14% of all allotments assessed.
  • Within HMAs, lIvestock grazing was the number one cause of more than half of allotments that fail land health standards.
  • Despite a national wild horse and burro program strategy, BLM does not have a similar national strategy to analyze the impacts of the agency’s livestock grazing program.

Other data include livestock grazing and oil and gas production impacts on greater sage grouse habitat.

Rosenthal told AWHC that the report raises many questions, including why the agency continues to spend millions of taxpayer dollars on wild horse management and comparatively little on similar management of livestock.  “I'm not saying that wild horses don’t have impacts on the land,” she explained.  “But, livestock grazing really seems to be the area that would make some big changes if [BLM] would make some management decisions.”

PEER’s recommendations include:

  • Improve the grazing database and make it accessible
  • Complete and update land health standard assessments
  • Use the data to make land use decisions
  • Prioritize biodiversity, including the greater sage grouse
  • Use agency data to evaluate wild horse/burro impacts on the land compared to livestock.