88 Million Acres?

Since BLM announced they have captured so many wild horses and burros from public lands they can no longer afford to feed them and are looking into mass genocide or slaughter to solve the financial dilemma, the public has been asking in earnest; why has 19 million acres of habitat been zeroed out for wild horse and burro use and why can’t those now on death row be returned to their legally designated territories instead of killing them?

This was the most prominent and consistent question and recommendation by the public at the recent November 17th National Wild Horse and Burro Advisory Board Meeting.

For those of you wondering why 19 million acres, this is the difference between what BLM reports was the original acreage identified in 1971 “where wild horses and burros were presently found” versus what their land use planning processes designated as “suitable for management” by granting it Herd Management Area (HMA) status.

For those of you wondering exactly what this means, it goes something like this.

After Congress passed the Wild Free-Roaming Horse and Burro Act in 1971, BLM and U.S. Forest Service (USFS) were required to identify all the areas across the West that had free-roaming equids on it.

These originally identified “territories” were then labeled by BLM as “Herd Areas” (HA) while USFS called them Wild Horse Territories (WHT).

However, after BLM had identified these original Herd Areas they ran into a little problem. Specifically, some of the habitat that had free-roaming herds on it were interwoven in what is called a “checkerboard pattern” of public, state and private lands.

The law specifically mandates that wild horses and burros must be removed from private lands if the owner of those lands requests their removals and we can be sure BLM had its share of complaints (anybody want to guess who was complaining?).

The checkerboard pattern was the most contentious in Wyoming (though not exclusively) and affected millions of acres of private ranches and public lands wild horses roamed on.

I believe this was one of the most pressing original issues that forced BLM to try and come up with some sort of legal compromise to appease the “complainers” (though I may be wrong about this) and this led BLM to the solution in the 80’s of creating Herd Management Areas instead.

Generally, it appears that if the Herd Area acreage was too interwoven with private lands to effectively separate, BLM just zeroed the checkerboard areas out. The other alternative, especially in Wyoming, seems to be a compromise with Ranching and Grazing Associations where BLM asked them how many wild horses they would “allow” BLM to manage in the HMAs that affected their private lands. Their recommendations then became what BLM approved as the Appropriate Management Levels (AML) of wild horses in the HMAs (at least that’s what the evidence is suggesting so far.)

From here, BLM expanded their application of what qualified as “suitable” for Herd Management Area status and began incorporating new standards such as, “Was there sufficient cover available in the HMAs for wild horses and burros?” At one public meeting, someone asked BLM what WH&Bs needed cover for and BLM responded, “To hide from predators” (you know, the ones they don’t have).

The Ely Field Office in Nevada just zeroed out 1.6 million acres by using the criteria of “watershed”, meaning they determined after thirty-seven years there wasn’t enough natural water sources available for wild horses and burros anymore.

By the way, even if an area was once deemed suitable for wild horse and burro management and granted HMA Status, BLM can and has revoked that status in subsequent land use plans ~ just because it’s an HMA today doesn’t mean it will be one tomorrow!

So back to the 19 million acres in question that so many want to see our wild horses and burros returned to rather than warehoused, slaughtered or euthanized.

Currently, BLM reports 53.5 million Herd Area acres and 34.3 million Herd Management Area acres and the 19 million acres is the approximate difference between the two. (Click Here to view)

While BLM has stated they are now looking into this option to see if there are any areas they can be returned too, this is not the first time this has been brought up. Yet when BLM has responded to this question before, they cite the reasons they were zeroed out in the first place haven’t changed (checkerboard, endangered species, etc.) so there is probably little hope of re-establishing herds and habitat in most, if not all of these now zeroed out areas (at least by trying to go through BLM!).

While I personally believe there could actually be a fair amount of acreage that BLM could return wild horses and burros too, considering how often their management and decisions have been so one-sided over the course of the years, I seriously doubt they are going to turn over a new leaf now!

The Government Accountability Office (GAO) was also mandated to look into the acreage issue but apparently the “new” GAO crafted under the Bush Administration has become a Marketing & Survey Firm instead of an internal controls government investigative unit. So like most of the issues the GAO’s recent report on the Wild Horse & Burro Program “investigated”, they deferred this portion of the inquiry to BLM to answer for them as well. (1)

I can personally testify to sending the GAO, at their request, dozens of documents on questionable acreage and decisions I have found throughout the Program but it now appears the GAO wasn't that interested after all or were incapable of investigating this on their own.

However, here was one of the links and questions given to the GAO they failed to examine or publicly address.

Currently, BLM has posted on their Wild Horse & Burro Program website a page I ran into over a year ago created by the United States Geological Survey (USGS), the most credible and scientific branch of the Department of the Interior.

At that time, I asked BLMs National Program Office why USGS was publishing this paragraph:

“In reality, the wild horse and burro population survey requirements for the BLM are daunting. The agency is responsible for managing 178 wild horse and 51 wild burro populations located across more than 88 million acres of public lands. Given the number and distribution of these populations, surveys of all burro herds and most wild horse herds are currently made from an aircraft.”

Though BLM never officially addressed my question about where USGS was getting 88 million acres from, a disclaimer was added to the BLM website stating something like, “You are now leaving the BLM official website and we are not responsible for the content and accuracy of these links.” Today, BLM isn’t bothering with this step and have chosen to just paste the USGS page directly into the Wild Horse & Burro Program website instead. (Click Here to view)

So far, previous inquiries into this question received no response from BLM or USGS and obviously, the GAO refused to touch it as well.

Recently, I have again asked BLM and USGS to address where are they getting “...88 million acres of public lands” from? Obviously, if USGS is reporting the accurate acreage versus BLM, we are looking at a loss of over 53 million acres since wild horses and burros became "protected", not 19 million acres as currently believed.

While I’m not holding my breath waiting for a response, or at least a credible one, I’ll keep everyone posted if an answer finally does arrive.

(1) United States Government Accountability Office, Bureau of Land Management, Effective Long-Term Options Needed to Manage Unadoptable Wild Horse (GAO-09-77), pg. 5/6.

Update
BLMs National Program Office has now responded to the inquires about the 88 million acres in question. An edited version of their response limited to the applicable information is pasted below.

“I've consulted with Mr. Roelle and decided to respond because the USGS web page that contained the sentence you inquired about is no longer posted on USGS's website. A copy of that old USGS web page was copied onto BLM's web site instead of being linked, and it contains inaccurate information that you have requested sources for. This copy of the USGS page on BLM's website is out of date and in error and will be changed. Thanks for helping us discover this error.”

”As background to this situation, about one year ago BLM added wild horse and burro research to our national webpage and in doing so copied a page from USGS on counting wild horses. Awhile after this, BLM and USGS worked together to update the USGS website. The sentences you inquired about, "In reality, the wild horse and burro population survey requirements for the BLM are daunting. The agency is responsible for managing 178 wild horse and 51 wild burro populations located across more than 88 million acres of public lands. Given the number and distribution of these populations, surveys of all burro herds and most wild horse herds are currently made from an aircraft." were found to be in error and BLM provided feed back for changes and corrections to their website. Unfortunately, we didn't delete the outdated USGS page from our website.” (Ed. Note: The original inquiry was sent to BLM on July 28, 2007.)

”I don't believe there is a reference for the inaccurate information you are asking about. I believe it was the result of misinterpretation and/or miscalculations. When BLM and USGS discovered the errors about a year ago, BLM conveyed to USGS that BLM had a total of 199 HMAs, 167 of which had only horses, 16 that had only burros and 16 that had both horses and burros and that these areas comprised about 34 million acres when both BLM and other ownerships are considered. As you know the number of HMAs has changed since BLM reported this to USGS.”