We love American Herds, and concur that BLM should show us the money, but more importantly, show us the horses (and burros): they have, they have killed, and they hope to kill.
Let us, however, let American Herds speak, plainly and succinctly.
American Herds recommends:
- Request BLM report to the Board and the public how many wild horses and/or burros, if any, have now been euthanzied both on the range and in holding facilities since the Board gave its recommendations in November 2008 and through BLMs December 18, 2008 approval of the new Euthanasia Memo #2009-041, which authorizes and outlines policy for large scale euthanasia of wild horses and/or burros.
- The Board request a financial audit of the Wild Horse & Burro Program to determine if any of the current funding crisis is a result of waste, fraud or abuse. For example, in the February 2008 Advisory Board Meeting, BLM presented the Advisory Board with an overview of the projected budget and associated costs of the WH&B Program. However, while BLM included the cost of the adoption program to Board Members, they failed to include the revenue generated from the sales and adoptions of wild horses and burros. This sort of accounting practice may be rampant in the Program and Board Members concerned with the financial issues affecting it have an obligation to actively support a review of an official audit of financial expenditures before supporting any more “disposal” alternatives to relieve BLMs financial pressures.
- The Board request an accounting of why BLM did not immediately investigate the cause of deaths of wild horses and foals in the Oregon HMAs, what rangeland management practices are currently in place that could verify the anonymous comments reports of abuse or may have contributed to their deaths, how BLM intends to remedy these issues so it does not happen again, why the BLM failed to report their deaths to the public and why BLM found an “undermined number” of wild horses still remaining on the range after the removal operations a satisfactory population report.
- The Board recommend the National Manual being developed by BLM to set a standardized AML determination process and create formal guidance on all aspects of Wild Horse and Burro Management be open to public comment and review as its impacts affect all wild horse and burro herds on both site-specific proposals as well as the national program as a whole. Doing so will help prevent future litigation by resolving issues collectively and allow the public a voice in the day to day operations that affect both herds, habitat and the thriving ecological balance BLM is charged with maintaining.
- The Board should be consulted and provide input on all land use plans, resource management plans and changes in AML decisions that affect wild horse and/or burro herds, their habitat or the critical resources necessary for their continued preservation and protection before BLM can issue a final decision on the proposal. If the final decision changes components that were integral within the framework of the original analysis, the BLM should explain why the changes were made, provide an analysis to the Board and public of the projected impacts of these changes and what the details of the changes mean for future wild horse and burro management.
- The Board recommend a viable process be instituted that mandates site-specific proposals [and] examine their actions in relation to cumulative impacts effecting the Program on a national scale. Currently, there is no viable system in place that requires individual field offices to examine the cumulative impacts of their proposals to the Wild Horse and Burro Program on a national level. Nor can the public participate or provide input on policy’s being issued on a national level that is having cumulative impacts on site-specific decisions. This disconnected system has allowed BLM to escape accountability through the necessary “hard look” at the policies being instituted and their resulting cumulative impacts. This is a serious flaw in the current system that has greatly contributed to the current crisis within the Wild Horse and Burro Program on multiple levels.
- The Board request answers and report to the public why BLM was unable to find appropriate mitigation measures in the Ely Resource Management Plan to continue to protect 1.6 million acres of wild horse habitat and the herds that are now being scheduled for removals after almost 40 years of being included in a thriving ecological balance that BLM recently determined can no longer sustain them.
- The Board request why BLM is now implementing management plans that will no longer consider genetic data or traits of historical and cultural significance. Additionally, is it now BLMs intent or has a policy been issued to manage historical herds as nothing more than publicly financed breeding farms for adopters/buyers for whatever “sells” in the market place?
- The Board request BLM begin reporting to the public prior to implementing those actions, an analysis of proposals that may return wild horses and /or burros to the range after conducting removals. The public should be able to review why, how many, the costs associated with the proposal and for what purpose does BLM intend to return wild horses, if they will be returned pregnant and if they should be returned to add “color” or to increase significant historical values to maintain herd characteristics even if those returns cause wild horse and/or burro populations to again exceed AML.
- The Board recommend BLM again revise their post-gather templates to include an age-class structure composition of all gathered wild horses and burros to create a national database on wild horse and burro reproduction/mortality rates, both for determining actual rates as well as to assist in future management actions that may reveal changes or trends in reproduction/mortality on either a site-specific or national level.
- Again I would like to recommend as I have repeatedly done in the past, that the Board begin to explore options for viable means of communicating with the public regarding their concerns, questions, comments, input and suggestions and to make these issues available through the public record in order to provide some measure of accountability for both the Board and BLMs progress towards addressing those issues.