Friday, July 6, 2012

If you can count wild horses, you should be able to count cows, too.

Recently an advocate shared an e-mail conversation she had with the BLM and asked for people to follow-up.

Here are my comments emailed this morning (7/06/2012) to JoAnn Worley, BLM spokesperson.


Ms. Worley,

I was allowed to read part of an email you sent to an advocate recently and wanted to correspond with you about some of your comments. I hope I don't take anything out of context, but here goes. FYI, your comments are in blue, all quotes from the BLM website or from internet articles are in red and my comments are in black.

First of all, you stated:

  • --The land wasn’t “taken” from the wild horses.  Herd management areas were determined in 1971 based on where wild horses were on the public lands at that time.  

 The BLM actually has "taken" over 22 million acres from the WH&B program since its inception. Please read your BLM Myths and Fact page below :  

Myth #3:  Since 1971, the BLM has illegally or improperly taken away more than 20 million acres set aside for wild horses and burros (from 53.8 million acres to 31.6 million acres).
Fact:  Of the 22.2 million acres no longer managed for wild horse and burro use:
Do we really need to get into semantical differences between "taken" or "no longer managed", or "removed" or "decimated" the fact is that acreage has been erased from use by wild horses and burros and those HMA's have been "wiped out" by your agency.  While no specific amount of acreage was set aside, that part of the response is disingenuous at best as many of the BLM determined herd areas are now gone as in they have ceased to exist. Since there were horses in those HMA's when the law was passed in 1971 to say that you have "taken" land from the wild horses is correct. And every year, the BLM wants to erase more HMA's and remove all the horses, such as what your agency currently plans for Colorado's West Douglas Herd.

You also said:

--Livestock use is controlled by month; wild horses use an area year-round.  There isn’t a bias, it is a way to average the use.  

Once again, I am confused by your comments. Divide the livestock AUM's by 12 and you can easily compare the numbers of cattle allotted to the HMA's and the number of horses allotted to those same HMA's for a 12 month period. In nearly ALL cases, except where the HMA's are designated as wild horse ranges, the allotment of AUM's for cattle exceeds the allotment for wild horses. And in many cases, the part of the year the livestock can be on the range is six months or more. Saying the livestock use is controlled by the month is meaningless unless one knows how many months the livestock are allowed usage on each HMA and in many cases, it's far more than a month and also in many cases it's in the prime part of the year for forage and water supply.

Let's take the Jackson Mountain HMA and information found on the BLM website as just one example.

The HMA acreage comprises 31% of the total allotment acres. There are a total of nine livestock operators (permittees) currently authorized to graze livestock in these allotments annually.  The total permitted use for these permittees is a combined total of 32,744 Animal Unit Months (AUMs) yearly in the six allotments (including on non-HMA lands).
There is a lot of information missing from the BLM data provided on livestock grazing, but here are some questions for you. Is livestock grazed evenly across the areas mentioned which include the HMA; how many months of the year is the allotment utilized; and what percentage of the allotment is utilized? 

Forging ahead regardless, rough math (and I think I have it right) tells me that 31% of 32,744 is 10,150 AUM's or up to 1690 livestock AUM's (cattle) six months of the year or up to 845 livestock (cattle) every day of the year. Those numbers are four times the Wild Horse upper AML and over five times the lower AML in the Jackson Mountain HMA if the allotment is 100% utilized.

The appropriate management level (AML) range established for the Jackson Mountains HMA is 130-217 wild horses. 
Surely someone in your office, when contacting the permittees  about the drought, asked them how many cattle (or livestock) they had on the range and received an answer. That would be the first question I would have in similar circumstances. How could your agency NOT want to know this information in order to better understand range utilization during a drought? So, here is the question that I have not seen in any BLM response. How many cattle are on the Jackson Mountain HMA and how many months of the year are they allowed to be there.
--The BLM has tried everything that you can imagine, including conflict resolution. Advocates want changes that would require the action of the U.S. Congress.  The BLM doesn’t create the laws, we follow them.  

The history of the DOI and the BLM would suggest otherwise. Who went to Congress to amend the Wild Horse and Burro act to allow the use of helicopters in roundups if not the BLM?

And are you aware that the multiple use philosophy actually originated within the DOI? Please read the excerpt below;

"A fledgling multiple use philosophy within the Bureau was legally endorsed for the public lands in the Classification and Multiple Use Act (CMU Act) of 1964. BLM was reorganized to reflect new programs and authorities under this mandate: concerns for wildlife, recreation, soil, and water resources were integrated into traditional programs (range, forestry, lands, and minerals) through a land use planning process.
Inspired by the conservation accomplishments of Theodore and Franklin Roosevelt, Secretary Udall launched the nation's "Third Conservation Wave" by requesting a new legislative mandate for the public lands from Congress. Part of this agenda included formal recognition of multiple use management on BLM lands, patterned after the Forest Service's Multiple Use Sustained Yield Act of 1960. Other components centered on getting BLM a more flexible land sale authority and repealing outdated settlement acts…"
The phrase in bold bears repeating … .. "Secretary Udall … requesting a new legislative mandate."  JoAnn, the BLM is fully capable of going to Congress and requesting changes and has done so in the past. So, saying the BLM doesn't create the laws is simply not based in historical precedent.

In closing I want to remind you why wild horses advocates continue to perceive a bias under the current administration. When Ken Salazar was appointed Secretary of the Interior, did he immediately start reforming the Minerals Management Service which had had known problems prior to 2008? 

No, his first big policy move I became aware of was to declare a massive roundup and removal of America's wild horses. While the oversight on wells like the Deepwater Horizon, which ultimately blew, was lacking; while West Virginia mines were crumbling, he was busy plotting his big move on America's wild horses. People died off the coast of Louisiana and people died in West Virginia, but our cattle ranching Secretary of the DOI  was going to solve that "wild horse problem" come hell or high water. Only after two disasters and public uproar did he turn his attention to MMS. Hasn't worked out very well for the victims who lost their lives and their families, has it?

Best Regards,


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