|Arizona Game and Fish Department submits comments
on BLM’s Wild Horse and Burro Strategy Document
(Aug. 24, 2010)
The Arizona Game and Fish Department submitted written comments to the Bureau of Land Management (BLM) regarding the BLM’s Wild Horse and Burro Strategy Development Document, titled “Working Toward Sustainable Management of America’s Wild Horses and Burros.” The strategy development document identifies draft goals, objectives and possible management plans under consideration by the BLM for the management of wild horses and burros.
The department believes that any horse/burro management proposals must take into consideration wildlife and wildlife habitat needs, and that horse/burro protection needs must be balanced with wildlife/habitat needs, as we believe was intended in the Wild Free-Roaming Horses and Burros Act of 1971.
The department further believes that any new strategy developed for the management of wild horses and burros must require that the BLM and Department of Interior meet their fiduciary and statutory obligations to appropriately identify and mitigate for impacts to wildlife and wildlife habitat under the Federal Land Policy and Management Act (FLPMA), the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and other statutes, regulations and legislation, as applicable.
Information posted by the BLM on its website estimates that more than 38,000 wild horses and burros roam BLM-managed rangelands in 10 Western states. Another 35,000 wild horses and burros are fed and cared for at short-term corrals and long-term pastures. Costs for the program, particularly those for animals in holding facilities, have risen dramatically in the last several years. In Fiscal Year 2009, for example, approximately $29 million, or about 70 percent of the total wild horse and burro program budget of $40.6 million, was spent on animals held in corrals and pastures.
More information is available at www.blm.gov/whbstrategy.
To see past Arizona Game and Fish Commission positions and Arizona Game and Fish Department testimony on wild horse and burro management issues, see below.
Arizona Game and Fish Commission opposes wild horse and burro amendments
The commission OPPOSES passage of either the House or Senate versions of the Restore Our American Mustangs Act (ROAM), because of their potential adverse impacts to wildlife and habitat.
The U.S. Senate is currently considering the Restore Our American Mustangs Act (ROAM), which would amend the Wild Free-Roaming Horse and Burro Act of 1971. An amended version of this bill (H.R. 1018) passed the U.S. House of Representatives on July 17, 2009 and was sent to the Senate. Both the versions of the legislation (H.R. 1018 and S.1579) are currently assigned to the Senate Committee on Energy and Natural Resources and await possible consideration.
The Arizona Game and Fish Commission voted at its Sept. 11 meeting to OPPOSE both the House and Senate versions of this bill because provisions in the bill would expand wild horse and burro populations to all public land and greatly complicate management of wild horse and burro herds. Expanding management of free-roaming horses and burros to all public lands will have devastating impacts to the long-term sustainability of the public’s wildlife resources and habitat.
In a Sept. 30 letter to Senators John McCain and Jon Kyl, the commission expressed concerns about the following provisions in the bill:
- Removing the restriction on limiting wild horses and burros to areas where they were found in 1971. This would lead to a massive range expansion with widespread direct and cumulative impacts to wildlife resources. Currently, the Wild Horse and Burro Program is underfunded and understaffed. Any significant increase of acreage or animals would limit personnel and funding solely for purposes of crisis management – such as responding to lawsuits for damage to wildlife habitat. Under this scenario, wild horse and burro populations, costs, and resource impacts would spiral out of control.
- Requiring that the acreage available for wild and free-roaming horses and burros shall never be less than the acreage where they were found when the Act was passed in 1971. Due to resource conflicts, many of the areas where wild horses and burros were found in 1971 were not designated as Herd Management Areas and were managed for a zero population level. This provision of ROAM alone would instantly increase the acreage available for wild horses and burros by more than 13.7 million acres.
- Requiring the BLM and United States Forest Service (USFS) to exhaust all practicable options before capturing and removing wild horses and burros. This would delay necessary removal operations, slowing down an already cumbersome removal approving process. Also, managers may be reluctant to push for removals until resource damage is obvious. With a population growth rate of 15-20%, wild horse and burro populations can double in 4-5 years. In our fragile southwestern habitats, an overpopulation of horses and burros can quickly lead to habitat and watershed degradation.
- Limiting the amount of time captured burros and horses can be held in corrals and holding facilities to 6 months. Due to inadequate adoption demand, and with few other options available, many wild horses removed from the range because of overpopulation would likely have to be returned to the overpopulated range after 6 months - or they may have to be transported to a different range, expanding the distribution of the animals, the associated costs, and the habitat damage.
- Requiring the identification of new rangelands and sanctuaries – or exclusive use areas – for wild horses and burros. This directive would elevate the importance of one species above all other species that use the range, severely impacting the Arizona Game and Fish Department’s ability to manage wildlife populations. It is also inconsistent with the multiple use mandates in the Federal Lands Management Act of 1976.
- Revoking a provision that allows the BLM to destroy old, sick and lame animals; and excess horses and burros for which an adoption demand does not exist. This would increase costs of holding and long-term care, which would decrease the availability of funds for removals and surveys. Due to limited funds and holding facilities, managers would have to return more animals back onto the range - exacerbating resource damage.
- Allowing the BLM and USFS to relocate wild horses and burros to public lands where they did not exist before the Act. This would have the effect of increasing and spreading the impacts to wildlife habitats, but it may be the land managers’ only recourse given the restrictive provisions in these measures for controlling wild horse and burro populations. Relocating wild horses and burros will only transplant the problem and could increase the problem beyond the Wild Horse and Burro Program’s ability to control it. This would lead to extreme, and geographically expanding, population growth and habitat damage.
- Requires that an adoption demand exists prior to capturing wild horses and burros. Over the years it has been demonstrated that there is not sufficient adoption demand to keep up with wild horse and burro population growth. This provision would cause wild horse and burro populations to remain on the range at levels beyond its ability to support them and the wildlife that depend on the same resources.
The commission believes that a more effective strategy to manage wild horse and burro populations is to adequately fund the current Wild Horse and Burro Program. The current Act, if adequately funded, has built-in checks and balances to prevent overpopulation and reduce resource damage on the range. It would be much more cost effective to increase funding for the current program than to expand the distribution of wild horses and burros, which would increase adverse impacts to natural resources.
- Copy of the commission’s letter to Senators John McCain and Jon Kyl [PDF, 40kb]
Testimony from Arizona Game and Fish Director Larry Voyles to House Natural Resources Subcommittee
In March 2009, Arizona Game and Fish Department Director Larry Voyles told a congressional committee that the ROAM bill (H.R. 1018) could result in adverse impacts to wildlife and habitat, as well as to the horses and burros the legislation seeks to further protect. He offered several recommendations on ensuring a viable future for each.
Testimony from Arizona Game and Fish Director Larry Voyles to National Wild Horse and Burro Advisory Board
In June 2010, Arizona Game and Fish Department Director Larry Voyles told the National Wild Horse and Burro Advisory Board that federal proposals to change how wild horses and burros are managed must have a goal of ensuring a thriving ecological balance between horses and burros and wildlife, and include the involvement of state wildlife agencies, as intended in the Wild Free-Roaming Horses and Burros Act of 1971.
Background on wild horse and burro management
The Wild Free-Roaming Horses and Burros Act of 1971, as amended by the Federal Land Policy and Management Act of 1976 and the Public Rangeland Improvement Act of 1978, directs the protection and management of wild horses and burros on public lands.
Responsibility for protecting, managing and controlling wild horse and burro populations on federal lands falls to the Bureau of Land Management (BLM) and the USDA Forest Service.
For information on the wild horse and burro program and related management issues, visit the BLM’s Web site at www.blm.gov/wo/st/en/prog/wild_horse_and_burro.html and click on the “Information Center” link in the box at the right.