I would like to register my views on the report by BLM on the Wild Horse and Burro program sent to Congress on May 8, 2020.
The plan, if adopted, would release an additional $21 million to BLM under the 2020 Appropriations bill.
I ask that you work relentlessly to ensure the plan outlined in the report is rejected.
I ask that only a portion of the pending funding, $6 million, be released to the agency and an actual management report be mandated prior to any changes in programmatic funding for 2021/22.
$6 million, of the pending $21 million, be released and be designated as follows:
- $4 million for BLM to complete actual Herd Management Area Plans (HMAP). The HMAP is the foundation for all other management decisions. In the report BLM misleads Congress into believing these need “updating.” In fact, there are hardly any of these plans in existence; BLM has omitted them in practice. BLM manages 177 HMAs and only 7 west-wide have an HMAP. This egregious deficit has lead to overcrowding of industry on the land set aside for inclusion of wild horses and a continual corruption of the intention of law.
- Without this baseline all other decisions are arbitrary, inconsistent, and at the will of political pressure, not balanced and fair management of wild horses. The HMAP is intended to streamline NEPA, inform Land Use Plans, outline potential mitigation measures, identify critical habitat. BLM’s failure not only corrupts the concept of management, it complicates ongoing NEPA. BLM should not be allowed to skirt this critical step.
- $2 million to ensure that in emergency situations BLM would have the budget to remove wild horses and burros in dire circumstances as they rectify deficits in HMAP creation.
- Continue to ban sales without limits (slaughter) and prohibit BLM from utilizing any prohibit sterilization or large removals (15% of the existing population or greater) in any HMA that does not have an HMAP.
The report is not comprehensive and does not supply justifications for its demands and must be rejected. In fact, the report points to the backwards approach taken by BLM that has caused the issues of today and BLM is now requesting Congress approve the release of funding to accelerate the collapse of the system.
In the plan presented to Congress BLM outlines 10 points of management. They list them in the order in which BLM has prioritized them in this program. Roundups are always BLM’s first line and the last the framework; the HMAP created is often simply ignored. BLM is not mandated to remove; they are mandated to manage. Removal should be the last tool of management.
Congress must create an incentive for the agency to begin to address the framework of management and complete HMAPs. Otherwise, BLM will continue to ignore the mandate to actually manage and simply accelerate the removal machine until the system collapses. The result of the collapse is foreseen in the planning documents presented by BLM as noted in their request to revisit regulatory changes to the sales program in their conclusory statement. The conclusion will be selling wild horses to slaughter.
Please force BLM to begin to preserve wild horse herds and their habitat through creation of HMAPs prior to any additional increases in funding.
Please limit the funding released only to provide for the creation of HMAPs and removals in emergency situations.
Thank you.
