THE FEDERAL WILD HORSE AND BURRO PROGRAM:

A PROBLEM OF MISMANAGEMENT
Written Testimony of the American Wild Horse Preservation Campaign
By: Suzanne Roy, Executive Director
Oversight Hearing: Challenges and Potential Solutions for BLMs Wild Horse & Burro Program
Federal Lands Subcommittee, House Natural Resources Committee
June 22, 2016
BLM'S decisions on how many wild horses to remove from federal rangelands have not been based on
direct evidence that existing wild populations exceed what the range can support.
- U.S. Government Accountability Office, 19901
How Appropriate Management Levels (AMLs) are established, monitored, and adjusted is not
transparent to stakeholders, supported by scientific information, or amenable to adaptation with new
information and environmental and social change.

National Academy of Sciences, June 2013

The American Wild Horse Preservation Campaign agrees that a significant problem exists with the
Bureau of Land Management (BLM) Wild Horse and Burro Program. However, we believe that the
oversight committee is focused on the wrong problem. The problem is not wild horse overpopulation;
the problem is BLM mismanagement as affirmed by numerous government and scientific reports, most
recently the National Academy of Sciences (NAS) in its 2013 report, Using Science to Improve the
BLM Wild Horse and Burro Program: A Way Forward.
The National Academy of Sciences study, which was commissioned by the BLM itself, demonstrates
that BLMs management practices waste taxpayer money, are facilitating high rates of population
growth and ignore scientifically proven solutions to reduce herd growth, including the use of the PZP
fertility control which has reduced some herds to zero population growth.
These are Americas wild horses and burros protected by a law unanimously passed by Congress and
they live on public lands that belong to all Americans.
The will of the American people should prevail, especially when it comes to public lands. Americans
have demonstrated time and time again that they overwhelmingly oppose horse slaughter and strongly
support protecting wild horses and burros on our federal lands.
The Current Facts

The program is unsustainable: The BLM relies on continual roundup, removal and
warehousing of wild horses and burros in government holding facilities at taxpayer expense. In
the last seven years alone, the BLM has removed more than 40,000 wild horses from public

1

http://www.gao.gov/assets/150/149472.pdf

American Wild Horse Preservation Campaign, 1025 Alameda, # 633, Belmont, CA 94002,
contact@wildhorsepreservation.org, 1-877-853-4696

lands.2 The agency now stockpiles nearly as many wild horses in captivity as remain free in the
wild.3

The program is a fiscal train wreck: The BLMs wild horse and burro budget has
doubled since 2009, reaching $80 million in Fiscal Year 2016. Approximately 70% of the
BLMs budget is spent on roundups, removal and confinement, while less than 1% is spent to
implement humane and available management programs for wild horses on the range.4

The program is inhumane. The roundups terrorize wild horses and burros in helicopter
stampedes across miles of rugged terrain and deprive these wild animals of the two things most
important to them: family and freedom. Recently, 1,800 wild horses were illegally sold by BLM
to a kill buyer and the horses likely were slaughtered.5

The program is unscientific. In 2013, the National Academy of Sciences (NAS) found
that the BLMs management practices are facilitating high rates of population growth on the
range and that removals are likely to keep the population at a size that maximizes population
growth rates, which in turn maximizes the number of animals that must be removed through
holding facilities. 6

Adoption is not the solution. The BLM continues to remove wild horses from the range
in numbers that far exceed adoption demand. With nearly 50,000 wild horses and burros already
stockpiled in holding facilities, the BLM simply cannot adopt its way out of this problem.

There is a better way. The NAS recommended use of the PZP birth control vaccine as
a more affordable option than continuing to remove horses to long-term holding facilities.
PZP fertility control is used today to successfully manage 30 wild horse populations in the U.S.
The BLM has eliminated helicopter roundups in numerous Herd Management Areas (Pryor
Mountains, McCullough Peaks, Little Book Cliffs, Spring Creek Basin) by utilizing the PZP
vaccine. However, instead of increasing its use, the BLM has actually reduced the use of PZP
since 2011.

Humane management = cost effective management: The cost savings of humane

management utilizing the PZP vaccine are well documented in the scientific literature. One
economic model demonstrated that BLM could save $8 million over 12 years by using PZP in
one HMA alone. Multiply that by 179 HMAs and the cost-savings reach the hundreds of
millions.7

http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html
http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/statistics_and_m
aps/holding__adoption.Par.53188.File.dat/WOFacRpt052016_web.pdf
4
http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/advisory_board_
10_2011.Par.57112.File.dat/Budget Presentation 9 2015.pdf
5
http://www.latimes.com/nation/la-na-wild-horse-slaughter-20151029-story.html
6
http://www.nap.edu/catalog/13511/using-science-to-improve-the-blm-wild-horse-and-burro-program
7
http://zoowildlifejournal.com/doi/abs/10.1638/1042-7260-44.4S.S34
3



BLM 2017 Budget: Heading in the Wrong Direction
Instead of following the NAS recommendations, the BLMs 2017 Budget calls for sterilization of wild
horses on the range, and opens the door to slaughter, something that is strongly opposed by the
American public.

Sterilization will take the wild out of wild horses. Unlike humane PZP fertility control,
which is non-invasive and does not affect natural behaviors, surgical sterilization of wild horses
on the range poses grave safety risks and will inalterably destroy their natural behaviors8 the
very essence of what makes these animals wild and distinguishes them from their domestic
counterparts.

Creating a slaughter loophole. The proposed Section 110 budget language to amend the
Wild Horse Act to allow the BLM to strip captured wild horses of their protected legal status
before turning them over to local and state governments, ostensibly for use as work animals,
opens the door for slaughter. Currently Congress prohibits the sale of captured wild horses and
burros for slaughter, but this requested provision would be an end run around this prohibition.
Even suggested language to make this provision less harmful, is not sufficient to protect wild
horses from slaughter because it would strip wild horses of their protected status, not prohibit
non-commercial slaughter and contains no enforcement mechanism to ensure that wild horses are
not sold for commercial slaughter.
The Myth of Wild Horse Overpopulation
The BLM bases its claim of wild horse and burro overpopulation on its inequitable and unfair
Appropriate Management Level (AML) system. However:

AMLs are not based on science. The NAS stated that it could not identify a sciencebased rationale behind the BLMs AMLs, finding how Appropriate Management Levels
(AMLs) are established, monitored, and adjusted is not transparent to stakeholders, supported by
scientific information, or amenable to adaptation with new information and environmental and
social change. 9

National AMLs are based on fast disappearing population levels. By setting a

national AML of just 16,300 27,00010 for all wild horses and burros under BLM management,
the BLM seeks to drive the wild horse and burro populations back to the number (25,000) that
existed in 1971, when Congress determined these iconic animals were fast disappearing. At
that time, Congress indicated that increased numbers of wild horses and burros were desired and
that wild horses and burros should be considered as components of the public lands coequal
with wildlife and domestic livestock. (Sept. 15, 1971 Interior and Insular Affairs report)

http://www.wildhorsepreservation.org/media/kirkpatrick-declaration-sterilization
http://www.nap.edu/catalog/13511/using-science-to-improve-the-blm-wild-horse-and-burro-program
10
http://www.blm.gov/wo/st/en/prog/whbprogram/history_and_facts/quick_facts.html
9

Habitat has been reduced by almost half. Since Congress unanimously passed the Wild
Free Roaming Horses and Burros Act in 1971, the BLM has reduced habitat for wild horses and
burros by 40%.11

Wild horses comprise a tiny fraction of grazing animals on public lands. Today, wild
horses and burros are present on just 12% of federal rangelands.12 Over 75% of forage resources
within wild horse and burro HMAs to privately-owned livestock.13 Wild horses & burros are
outnumbered 47-1 on public lands.
BLM Grazing in States with Wild Horses
State
BLM Acres Grazed BLM Acres Wild Horse
by Livestock
and Burro HMAs
Arizona
California
Colorado
Idaho
Montana
Nevada
New Mexico
Oregon
Utah
Wyoming
*includes Dakotas

11.5 million
7 million
7.8 million
11.5 million
8.2 million*
43 million
13 million
14 million
22 million
17.4 million

1.5 million
2 million
365,000
383,000
27,094
14 million
24,500
2.7 million
2.1 million
3.6 million

% of BLM
rangelands
occupied by wild
horses & burros
13
28
5
.03
.003
33
.001
19
10
21

Wild horses & burros are not the problem. Only a tiny fraction of western forage on
federal grazing lands is consumed by an estimated 67,000 wild horses and burros, which live on
just 26.9 million acres of public land14. Thats roughly one animal per over 400 acres of land -certainly not an overpopulation problem.
Public Lands, Public Animals, Public Support

Polls document the publics strong support of wild horses and burros on public
lands. Three out of four Americans favor protecting wild horses and burros15, while 80% oppose
horse slaughter16.

11

http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/statistics_and_ma
ps/hma_and_ha_stats_all.Par.50867.File.dat/2016_HAHMA_Stats_0316_for%20web.pdf
12
http://www.blm.gov/wo/st/en/prog/whbprogram/history_and_facts/quick_facts.html
13
http://www.wildhorsepreservation.org/media/zach-reichold-email-re-aums
14
http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html
15
http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html
16
http://www.prnewswire.com/news-releases/aspca-research-confirms-americans-strongly-oppose-slaughter-of-horses-
for-human-consumption-138494089.html

Overwhelming support for preservation. The public outcry over the U.S. Forest
Service plans to remove the Salt River wild horses in Arizona was notable. In less than a week,
300,000 citizens signed a petition calling on the Forest Service to abandon removal plans, and 97
percent of respondents to an ABC television poll supported protection of these horses. The entire
Arizona Congressional delegation and Arizona Governor Doug Ducey responded by calling for
protection of these horses.
Win-Win Solutions
To date, the BLM has failed to follow recommendations made by the NAS which are strong supported
by the American public including to:

Use the proven PZP fertility control vaccine, which has been safely and effectively
used to manage wild horse populations for decades, to reduce population growth rates.

Create public-private partnerships to implement humane management programs. The

AWHPC is currently working through a Cooperative Agreement with the State of Nevada to
humanely manage an estimated 2,000 wild horses on over 300,000 acres of habitat under state
jurisdiction in northern Nevadas Virginia Range.

Adjust the artificially low and unscientific AMLs to accommodate current population
levels and allow for the preservation of wild horses and burros in genetically viable herds.

Develop mechanisms to allow for voluntary retirement of grazing permits in wild

horse and burro Herd Management Areas and financial compensation (public or private) to
ranchers for grazing permit retirement or non-use of grazing allotments. Compensating ranchers
will be far more cost efficient than continuing to roundup, remove and stockpile wild horses in
holding facilities.
Conclusion
The BLM Wild Horse and Burro Program is profoundly broken and in need of reform. But in order to
fix the problem, the Congress must adequately diagnose it. A Congressional inquiry into a so-called
excess wild horse problem that focuses only on wild horse numbers, without evaluating the programs
unscientific and fiscally wasteful underpinnings will serve only to perpetuate the current system. That
system benefits a handful of special interests at the expense of the American taxpayers and our iconic
wild horses and burros.
In summary, there is a serious problem with the wild horse program, but the problem is rooted in agency
mismanagement, not horse populations. The National Academy of Sciences study, which the BLM itself
commissioned and for which the agency sent set the scope, shows BLMs management practices waste
taxpayer money, cause population increases and ignore scientifically proven solutions to reduce her
growth, including the use of PZP which has reduced some herds to zero population growth.
The myth of overpopulation is based on the misleading notion of "appropriate" management level. By
setting a national AML of just 16,300 27,000, the BLM seeks to drive the wild horse population back
to the number (25,000) that existed in 1971, when Congress determined these iconic animals were fast
disappearing. This is counter to the intent of Congress to protect these iconic animals by allowing their
numbers to increase and treating them equitably with livestock and other wildlife species.
5



BLM mismanagement also leads to inhumane treatment of the horses, including brutal helicopter
roundups and warehousing, destruction of herd family units, and horse slaughter, such as the recent
slaughter of 1,800 healthy horses, for which the Inspector General found BLM failed to follow its own
policies and ensure protection of the horses.
Wild horses are present on just 12 % of federal range lands. Wild horses are not overrunning the West or
destroying the range. Since we are talking about a small piece of the overall federal lands grazing pie,
this problem can be resolved, but it will take leadership from Congress and a commitment within the
agency for true reform.
Slaughter is not a solution. Not only is it overwhelmingly opposed by the American people, but also
having slaughter as an outlet for disposing of excess wild horses would perpetuate the unsustainable
cycle of roundups and removals that are causing wild horse populations to increase at higher than
normal rates. By continuing removals, BLM is creating the very problem it seeks to resolve.
There is overwhelming public support for wild horses on public lands and the will of American people
should prevail, especially on public lands. The current standard of treatment of these living symbols of
American freedom is far below what Americans expect and demand.
We can do better and the American people deserve better, and fortunately there are inexpensive and
effective solutions, including the use of PZP
Over the last decade, Congress has stood firm against slaughtering America's iconic mustangs and it
should continue to do so.
Thank you for your consideration.
Attachments to AWHPC Testimony, Submitted for the Record
Key Findings of the National Academy of Sciences 2013 Report