As the 117th Congress begins we as a nation are facing unprecedented urgency in addressing long standing issues nationwide.
We as a nation look to begin repairing our country, we must not only face a pandemic and new policy that has damaged our nation, but the policies that have existed for a very long time.
Leadership, that places value on transparency and equity, has been vacant for a very long time. Our public lands, and every being that live on them, have suffered.
Wild horses and burros are an integral part of the system of public lands, according to the law passed 50 years ago this year. However, wild horses and burros have not been treated as part of the system of management for as long as the law has stood.
The processes that govern decision making by the Bureau of Land Management (BLM) are codified in the Code of Federal Regulations, further defined in a litany of handbooks, through the National Environmental Policy Act (NEPA). The Code of Federal Regulations states they must create management plans for our herds. Their handbook defines the process of creating these plans.
The BLM Wild Horse and Burro program short steps their obligations as they carry out their sworn duties to manage wild horses and burros. BLM simply creates “gather plans” and omits any effort to actually carry out the intention of the law to protect and preserve our American horses and burros and their habitat.
BLM has many reasons for side-stepping this process. Most of the reasons are weak attempts to claim they have no time. However, they have time to create planning for every mine, livestock permittee, and even ATV trails.
The truth of the omission lies in the contentious reality of any effort to preserve any aspect of our nations natural environment to the extent that managers can face intimidation, not only from the profit driven interests seeking permits for exploitation of the resource, but from within the agency itself. The West has a long and violent history that extends from long in the distant past and still exists today.
Placating well-funded and organized livestock and mining interests by simply setting population levels of wild horses and burros ridiculously low, removing and stockpiling them, allowing the resources wild things need to thrive to go to industry, has served the politics of the West well. It has damaged our great American landscape, some have said beyond repair. Managers there blame the wild horse, remove them, continue the cycle.
Until there is real support to break the cycle, it will not end.
We need real leadership.
As you begin to make determinations on policy agenda for our public lands, we urge you to consider that we need no new laws or subsidies, we need clear leadership and direction.
Leadership must concern itself with open and transparent management planning that includes habitat and herd preservation, not simply scapegoating for convenience.
For the last 4 years we have not had a Director of the BLM. We have had a revolving door that has been working through the Deputy Director chair to forward agendas tied to former clients and future clients. The damage they have done to the wild horse program is immense. Directives from the Deputy Director chair have created subsidies that empty pens, but increase the risks of slaughter. Long term gather EAs have been crafted that omit public input, and NEPA compliance checks, for ten years. Directives were sent that push untested and dangerous sterilization. Absolutely no work has been done to protect critical habitat for use by wild horses and the scant 12% of the public lands available to wild horses has left them with less than 2% of the available resources in those areas.
We urge you to include a commitment to robust planning for our Herd Management Areas, as outlined through existing policy, in any legislation you may consider. In simple terms we can not continue to obligate the taxpayer to buy and implement tools without justifying the use of said tool first.
Without a transparent and open process that begins any attempt to address flaws in management, we will simply have a continuation of a system designed for privateers to sell their wares, mislead the public and exploit the American resource that is the wild horse and burro.
As funding requests begin in a few short weeks for fiscal year 2022:
We urge you to only consider amendments that provide for the creation of actual management planning, the HMAP, to be fast tracked. We must have these planning documents prior to justifying any expenses for removals, fertility control. any action that simply perpetuates what has become an extremely inefficient and wasteful program.
It is time Congress takes the responsibility to protect the public interest and public resource (wild horses) to heart. Land managers need an incentive to create actual planning documents. Congress should not approve any requests for additional funding until BLM crafts a site-by-site plan, as they do for any other activity on public lands.
We urge you to prohibit funding for the Adoption Incentive Program (AIP), created through directive from questionable leadership under Deputy Directors of the BLM with strong ties to “extremism” and the pro-horse slaughter movement. The AIP has created a massive (over $5 million in its first year) subsidy program to empty holding pens, increase removals and increase, rapidly, the number of American mustangs landing in the slaughter pipeline. The American public should not be subsidizing this industry.
In 1971 Congress, unanimously, recognized that wild horses and burros were to be protected from slaughter and managed as an integral part of the system of public lands. Congress must begin to take their obligation to hold federal agencies accountable to that intention. Through the upcoming budget debates, Congress can create incentives and hold back funding until agencies begin to demonstrate they take their duties seriously, responsibly and transparently.
Thank you.
