The 10 Years to AML: The Path Forward for Management of BLM's Wild Horses and Burros is an agenda of the livestock industry, which aims to eradicate wild horses from America's public lands.
The Senate Appropriations Committee approved $35 million last week for the program supported by an unprecedented alliance including the Humane Society of the United States, American Society for the Prevention of Cruelty to Animals, National Cattlemen’s Beef Association and American Farm Bureau Federation.
They say it would eliminate the threat of slaughter for thousands of free-roaming horses and shrink the size of herds primarily through expanded fertility controls on the range. Critics say it drops long-held opposition to the capture of mustangs across 10 western states and could allow for sterilization of mares — a hot-button issue with horse protection advocates historically.
It should be noted that in July 2019, the acting director of BLM, Casey Hammond, said the Trump administration won’t pursue lethal measures such as euthanasia or selling horses for slaughter. So the fear-based marketing HSUS and ASPCA are using, saying their Path Forward plan would save wild horses from slaughter, has no merit.
They had sought a $50 million increase in the BLM’s $80 million annual horse budget, arguing any boost in spending on contraception and other population controls ultimately will save money as herds shrink.
“This is a historic moment for our herds, containing the strongest language protecting wild horses and burros we have ever seen in an annual appropriations bill,” Matt Bershadker, president and CEO of the ASPCA, said in a statement emailed to The Associated Press on Friday. He said it increases “commitments to protect these animals from killing or sale to slaughter.”
If implemented, “we’ll see massive round-ups, swelling captive wild horse population and jubilation from cattlemen’s associations that secured political cover from the Humane Society for their long-time aspiration to secure a government-funded wild horse depopulation program,” Marty Irby, executive director of Animal Wellness Action, said after the vote.
BLM estimated 88,000 wild horses and burros are roaming public rangelands, more than three times what the agency says the land can support. Another 50,000 that have been removed from the range in recent years were in holding facilities at an annual cost of about $50 million.
Horse advocates have argued the animals must be permitted to roam the range in federally protected management areas established under the Free-Roaming Horse and Burro Act of 1971. They say BLM’s population quotas are often outdated and lack scientific data to support roundups to cull herd sizes.
Ginger Kathrens, director of The Cloud Foundation based in Colorado, said the new initiative dubbed the “Path Forward” should be called the “path to extinction.” She said it sets population targets to less than 27,000 — the total when federal protections first were enacted nearly a half-century ago. “The extinction-level number is what caused Congress to unanimously pass the Wild Horse and Burro Act,” she said.
Source: Time Magazine
U.S. Senate Committee Allocates $35 Million For Cattlemen's Plan to Roundup and Incarcerate Wild Horses
Today, the Senate Appropriations Committee passed a Fiscal Year 2020 spending bill that includes a shocking $35 million in funding to implement a potentially catastrophic mass mustang roundup proposal promoted by the National Cattlemen’s Beef Association, the American Farm Bureau Federation, the so-called “American Mustang Foundation” and other agribusiness lobbying groups and, shockingly, the Humane Society of the United States (HSUS), the ASPCA, and Return to Freedom, a sanctuary.
It could increase the number of horses to 150,000 maintained in captivity at taxpayer expense with no guarantee of funding for their long-term care. "This scheme is the biggest threat to wild horses and burros in the West in decades, and the American taxpayer is going to finance the whole shebang” said Marty Irby, executive director at Animal Wellness Action and a lifelong horseman. “If this ghastly plan is implemented, we'll see massive round-ups, swelling captive wild horse populations, and jubilation from cattlemen's associations that secured political cover from the Humane Society of the U.S., Humane Society Legislative Fund, and ASPCA for their long-time aspiration to secure a government-funded wild horse depopulation program."
Key components of the “controversial and dangerous” cattlemen’s proposal includes:
Humane solutions that should be implemented instead:
We might as well call this what it is: “The Path Backward” or “The Path to Extinction,” since they’re reducing wild horses to the number that existed in 1971, stated Ginger Kathrens, Director of The Cloud Foundation. That extinction-level number is what caused Congress to unanimously pass the Wild Horse and Burro Act. This 'plan' will rip tens of thousands of horses and burros from their dedicated land and their families at catastrophic cost to the American taxpayer billions of dollars spent to incarcerate them in cramped corrals for the rest of their lives, except for the few that are adopted. Why? So private livestock interests, (subsidized by the BLM through your tax dollars), can run cattle on public lands. It's time for the American people to stand up and say, 'No more. Not with my tax dollars. There are better programs to spend these billions of dollars on than this.'
A Senate Energy and Natural Resources subcommittee will hold an oversight hearing this week to discuss strategies to reduce growing wild horse and burro herds.
Tomorrow's Subcommittee on Public Lands, Forests and Mining hearing will "examine long-term management options for the Bureau of Land Management's Wild Horse and Burro Program," according to summary written by GOP staffers.
The hearing comes in advance of a much-anticipated report BLM is expected to submit to Congress next month detailing specific strategies and funding estimates for reducing the number of wild horses and burros.
What exactly BLM plans to include in the report is unclear. But Steve Tryon, BLM's deputy assistant director for resources and planning, is scheduled to testify at tomorrow's hearing and will almost certainly be grilled about the upcoming report.
One thing the report will not include is a standing Trump administration request for Congress to lift language in appropriations bills that forbids BLM from using euthanasia on healthy horses and burros that cannot be adopted.
Casey Hammond, the Interior Department's principal deputy assistant secretary for land and minerals management who is temporarily overseeing BLM, announced last week at a national wild horse advisory panel meeting that euthanasia is "not an option that's being discussed in the bureau or the department".
How that new Trump administration position sits with conservative Republicans, like subcommittee Chairman Mike Lee of Utah, remains to be seen. But the topic of euthanasia as a option for culling herd sizes is likely to be a major topic of debate at the hearing.
Among those scheduled to testify is Ethan Lane, chairman of the National Horse and Burro Rangeland Management Coalition, which advocates for downsizing herds on public lands to sustainable levels.
Lane is also senior executive director of the Public Lands Council and of federal lands for the National Cattlemen's Beef Association. Both groups joined the American Society for the Prevention of Cruelty to Animals and others in devising a macabre plan submitted to congressional appropriators in April to reduce growing herd sizes without resorting to euthanasia or unrestricted sales (The Path Forward, 10 Years to AML proposal).
Nancy Perry, ASPCA's senior vice president of government affairs, is also scheduled to testify.
The hearing comes as federal land managers say there are at least 88,000 wild horses and burros roaming 27 million acres of herd management areas — more than three times the appropriate management level of 26,690 animals deemed sustainable for natural resources and the wildlife that live on the rangelands.
The 88,000 wild horses "is very, very far away from healthy herds," Hammond told the wild horse advisory board last week.
BLM has ramped up organized roundups of wild horses and burros, as well as efforts to get these animals adopted. But the bureau estimates that it costs about $50 million a year — close to 70% of the Wild Horse and Burro Program annual budget — to care for the animals held in off-range holding corrals and pens.
"We often forget about that number," Hammond said, referring to those costs.
"That's what's eating up a significant portion of the budget that Congress has given us just to take care of the [animals] we've taken off the range [in order] to have a healthy range that we don't have," he said. "So the challenges are significant."
Schedule: The hearing is Tuesday, July 16, at 2:30 p.m. in 366 Dirksen.
Source: E&E News
coalition urges congress to reject the "path forward" 10 years to aml plan for wild horses and burros
Today, a broad coalition of stakeholders, organizations, and businesses sent a letter to the U.S. Congress in strong opposition to a dangerous and unworkable proposal that threatens our iconic American wild horses. The "Path Forward" 10 Years to AML proposal, a brainchild of The HSUS, ASPCA and Return to Freedom, working in concert with the National Cattlemen’s Beef Association and American Farm Bureau Federation, calls for the removal of at least 45,000 to 60,000 and potentially as many as 200,000 wild horses and burros from our federal lands over the next ten years, putting the horses at significant risk of slaughter and placing a burden on taxpayers for an outcome that is widely opposed by the public.
“This is terrible deal for wild horses. The unfunded 'plan' will put tens of thousands more wild horses in government holding, with their fate left to the whims of future appropriators,” said Suzanne Roy, executive director at the American Wild Horse Campaign. “Make no mistake: this could result in the eventual slaughter of tens of thousands of wild horses. The cattlemen’s lobby is the only winner, achieving the near extinction-level population of wild horses they have long sought."
“This ill-considered plan would remove tens of thousands of our iconic American wild horses from the range at a billion-dollar price-tag to the taxpayer over a decade,” said Marty Irby, executive director at Animal Wellness Action. “The biggest beneficiary of this plan would not be horses, but the livestock industry, which will see the federal government remove wild horses so that more cattle can graze on our public lands.”
"In its current form, this plan would be disastrous for our wild herds,” said Ginger Kathrens, founder and executive director of The Cloud Foundation. “It provides for no meaningful accountability on the part of BLM to implement humane and reversible fertility control measures. This plan gives BLM the mandate it has always wanted to round up more than 50,000 of our wild horses, doubling the number in off-range holding at enormous cost to the American taxpayer. We fear that unless funds are allocated to support those horses in holding for the rest of their natural lives, we will eventually see them sold killed in slaughterhouses. Meanwhile, our wild herds will be even more decimated, suffering deterioration in health due to poor genetic variability. Bottom line, wild horses and burros will eventually disappear from the West altogether. We suspect this is exactly what some of the stakeholders presenting this plan want."
Rounding up horses and burros is a highly stressful and dangerous experience for these animals. Injuries and deaths are not uncommon, and many horses will be separated from their families. The plan places wild horses and burros at significant risk of slaughter. The proposal significantly increases the number of captive horses at federally run and financed facilities and will create a future fiscal crisis. If history repeats itself, this increase will provoke pro-slaughter lawmakers to call for mass slaughter and euthanasia as a matter of fiscal responsibility.
As a humane and responsible alternative, stakeholders are instead calling for a step up in BLM-conducted fertility control programs, which allows horses to be managed humanely on the range. Proposed by U.S. Reps. Dina Titus (D-NV) and Raul Grijalva (D-AZ), fertility control will eliminate the need for mass roundups and removals and spare taxpayers the need to finance long-term care, feeding, and leasing of land.
Nearly 50 signors, including wild horse advocacy organizations, horse rescues, animal protection organizations, and horse-related businesses across the nation have banded together to defeat this egregious measure, urging legislators to reject the dangerous proposal:
Divisions over federal policy on wild horses and burros have come into sharp focus in the last two weeks after the Humane Society of the United States (HSUS) announced a collaboration with the American Society for the Prevention of Cruelty to Animals (ASPCA), Return To Freedom, and pro-horse slaughter groups such as the National Cattlemen’s Beef Association (NCBA) and the American Farm Bureau Federation to convince the House and Senate Appropriations Committees to add $50 million to the Bureau of Land Management’s budget for management of the equids.
Specifically, the groups have called for the roundup of 15,000 – 20,000 horses and burros annually for as many as ten years, and for placement of these horses in government-funded holding facilities, perhaps in Oklahoma, Kansas, and Utah (on top of the 50,000 horses already in holding facilities).
They’ve called for a step-up of “growth suppression programs,” specifically targeting the individual horses and burros remaining after gathers in order to make sterilization or fertility control more practical.
Every reputable animal protection group – including all animal groups on both sides of this debate – opposes the slaughter of wild horses, and also pushed for federal legislation to stop the slaughter of any domesticated or wild horses or burros. And I have no doubt that the program staffers at the HSUS and the ASPCA advocating for this plan have a deep concern for horses and burros. They deserve our respect for their passion for animals. In this case, however, I think they’ve made the wrong judgment and negotiated a bad deal that puts horses and burros at risk. And the absence of a perfect plan in the alternative doesn’t make their plan any more acceptable
The best and most rationale step forward is to use this year’s appropriations cycle to require BLM expand its contraception programs and fund that expansion. If BLM demonstrates an ability to apply the fertility control strategy in a far larger number of Herd Management Areas, then it’s time to talk about a broader plan for managing horses and burros given the presence of a more trusted and reliable government agency.
Oppose The Path Forward, 10 Years to AML plan
For now, though, the wild horse and burro community is right to balk at a plan to gather and remove 45,000 – 60,000 wild horses and burros in the next three years. Advocates should speak up and call their federal lawmakers (202-225-3121), urging them to oppose this dangerous plan and focus funding on the contraception as the centerpiece of any future, more comprehensive management plan.
Source: Drovers, by Wayne Pacelle
Who’s overgrazing BLM lands? Subsidized livestock. BLM data shows it.
The below spreadsheet converts grazing receipts reported by the BLM for private livestock grazed under the public lands grazing program, allowing a direct head-to-head comparison between the number of wild horses (WH) estimated by the BLM and permitted cattle grazing from 2002-2018 (see column 9). What does the data show? Cattle historically outnumbering WH by a factor of 71:1 (in 2002), 92:1 (2007) and 28:1 (2018).
This isn’t the story the BLM tells the public. In fact, the BLM doesn’t publicly report subsidized livestock numbers. It hides them, instead spinning a story of overpopulation and overgrazing by wild horses to justify costly WH roundups, removals, sterilization and sale/euthanasia proposals.
The column 9 ratios prove that justification to be false. And the ratios low-ball how many cattle actually compete with wild horses for water, forage and land, since grazing fees are calculated according to self-reported rancher AUMs and do not reflect underreporting and trespass grazing (like the more than $1 million that Cliven Bundy owed in back grazing fees in 2014). So the actual number of subsidized, privately owned livestock on public lands is likely much much higher.
Other Key Findings:
The identities of the permittees are sometimes obscured by corporate names, but data provided by the BLM shows that the folks leasing great swaths of public land to graze their cattle and enjoy enormous government subsidies include both people and corporations on Forbes “Billionaires” and “Richest Americans” lists (see p. 138 or click here).
When advocates claim that livestock outnumbers and out-grazes wild horses on public lands, this is not an emotional argument or an opinion. It is an argument based on the above data from the BLM and other government sources — data that the BLM doesn’t make available to the public and media, because it doesn’t want them to know…about the cattle, their owners, the damage they cause, and the massive subsidies they are taking from average Americans.
Sources for BLM spreadsheet data:
Column (1) BLM budget justification reports. 2018 $ are estimated. 2002-2017 are actual. (2) BLM website (3) calculated by dividing column 1 by column 2, then by 12 (4) multiply column 3 by 2 to account for 1 animal unit = 1 cow and her calf or 1 horse (5-6) BLM website (7) total columns 5+6 (8) column 4 divided by column 7 (9) column 4 divided by column 5. All data compiled by dailypitchfork.org.
Source: The Daily Pitchfork
The Bureau of Land Management spends about $50 million a year to house and feed more than 46,000 wild horses and burros in corrals. Another 73,000 of the animals roam freely across the western states, producing foals and grazing on public lands that conservationists and federal officials say are quickly deteriorating.
It’s an escalating equine-population problem, and the fiscal 2018 budget President Trump proposed this week suggests a solution: using “humane euthanasia and unrestricted sale of certain excess animals.”
The change could lead to sales of wild horses to slaughterhouses in Mexico or Canada, as well as to the culling of herds, to address what the bureau calls an “unsustainable” situation. But it has been condemned by horse and other animal advocacy groups, some of which have consistently resisted efforts to impose limits on an icon of the American West that has been federally protected since 1971.
The Trump proposal notes that the BLM’s wild horse and burro budget has quadrupled since 2000, from $20.4 million then to $80.4 million in 2017, and that most of the money goes to care for animals that reside in taxpayer-funded corrals. The proposed budget anticipates saving $10 million annually by selling some of those animals and by reducing roundups and horse and burro birth-control programs.
The use of euthanasia and sales to manage the population is not a new idea: The 1971 Wild Free-Roaming Horse and Burro Act permits the interior secretary to remove older and unadoptable animals by those methods. But for much of the past three decades, Congress has used annual appropriations bill riders to prohibit the killing of healthy animals or “sale that results in their destruction for processing into commercial products.” While it is unclear whether lawmakers would now be willing to lift the prohibition, an aide on the House Appropriations Committee said the request would be considered.
Although the last U.S. horse slaughterhouse closed in 2007, meat processing plants in Mexico and Canada slaughter tens of thousands of domestic American horses each year for export to Europe and Asia. And despite the congressional ban, some wild horses sold to private buyers have been slaughtered anyway. In November 2015, federal investigators found that a Colorado rancher to whom the government had sold 1,794 mustangs turned around and sold them to slaughterhouses in Mexico.
As the wild horses and burros, which have no natural predators, have increased in numbers, officials and conservation groups say they have depleted the amount of forage food and water available to native species in the West. That, in turn, has increased the risk of widespread starvation and thirst among these herds and wild animals on public lands.
Wild horse advocates counter that the bureau is pandering to ranchers who view the horses as competition on public range land also used for cattle grazing.
Meanwhile, adoptions by the public — the bureau’s primary program for reducing the population in government corrals — have not increased with the population. Last year, 2,912 wild horses and burros were adopted, up from 2,583 in 2012, according to agency figures.
The budget proposal comes eight months after the bureau’s wild horse and burro advisory board, a volunteer body that makes no binding decisions, sparked an uproar among wild horse advocates by recommending euthanasia or sales for the animals. Subsequent false reports about a looming government plan to kill 45,000 wild horses prompted the BLM, then under the Obama administration, to say it “does not and will not euthanize healthy animals.”
Some board members said their recommendation was made, in part, to shock Congress into doing something about a problem they believe is spiraling out of control.
“All these horses in long-term holding are eating up 60 percent of the wild horse and burro budget. Other things can’t be done well or thoroughly because we’re feeding a lot of stockpiled horses that no one wants,” Julie Weikel, a large-animal veterinarian on the advisory committee, said in an interview this week. “I fully expect a full-court press from the advocates to put the rider back on. But I assure you that will not solve the problem.”
The question of how to address the problem appeared on Interior Secretary Ryan Zinke’s radar not long after he was confirmed. According to his personal schedule, he held a video call on the topic on March 24 with the BLM’s acting director, Michael Nedd, and several other senior officials.
For more than 40 years, past administrations have tried but failed to control the animals’ numbers. In 2009, then-Interior Secretary Ken Salazar proposed that the U.S. government spend roughly $96 million to buy land in the Midwest and East to create two preserves that could each support 3,600 horses. He also suggested that federal officials partner with nonprofit organizations and other private groups to create five additional preserves, so that 25,000 animals would be living on preserves within five years. The government also would aggressively sterilize the horses and burros to keep them from reproducing.
At the time of Salazar’s proposal, about 37,000 horses and burros were roaming and another 32,000 were in holding pens. But the money did not materialize, and the number of animals on public range lands increased sharply. It now is about three times more than officials say is sustainable.
Some animal advocacy groups say the BLM has not proactively pursued horse and burro birth control, though other activist groups have sued the agency over the use of injectable contraception and the spaying of mares. In a statement this week, Matt Bershadker, president and chief executive of the American Society for the Prevention of Cruelty to Animals, said the animals could be “humanely” managed with fertility control, but the BLM “would rather make these innocent animals pay for draconian budget cuts with their very lives.”
Weikel said she hopes Trump’s budget proposal prompts Congress to consider lifting its usual rider. Considering the proposal, along with the advisory board’s recommendation, “maybe thoughtful people…would realize we have a true problem out there. And we are not using all the tools.” In addition to euthanasia and sales, she said, permanent sterilization should be utilized more.
In a statement, the BLM said its goal “is always to find good homes for the thousands of wild horses and burros gathered from overpopulated herds on our country’s public lands.” It continued, “With an expanded suite of management tools, the BLM can strengthen its efforts to reverse the declining health of our nation’s wild horse and burro herds and manage the public lands on which they and so many other species depend.”
Source: The Washington Post
"It really at a fundamental level provides some stability for the grazing industry by assuring that our permits will be renewed in a timely fashion," said Jim Magagna, executive director of the Wyoming Stock Growers Association.The legislation allows agencies to approve permits in the face of environmental lawsuits against permit renewals.
U.S. Bureau of Land Management officials reported a permitting backlog of more than 5,600 permits nationwide in September. At the time, Congress was required to renew these permits annually.
"The agencies didn't have the resources to meet that requirement, (which) basically put people in a position where they couldn't get their permits renewed in a timely manner," Magagna said. "In some cases, they couldn't graze their livestock for extended periods of time."
Under current law, permitting is subject to environmental analysis prior to renewal of a permit. The new legislation allows federal agencies to approve permits without requiring environmental analysis. Agency range managers will still conduct environmental reviews at their discretion. Magagna said the new law focuses range management on the health of allotments.
"Environmental analysis has been tied to permit renewal, and really that analysis isn't about the permit. It's about the actual range condition," he said. Sen. John Barrasso, the author of the bill, said it will provide added protections for Wyoming ranchers seeking consistency in their operations.
"For too long, our ranching families have been the target of anti-grazing litigation that puts their grazing permits in jeopardy,” Barrasso said.
The legislation passed as part of the National Defense Authorization Act.
Source: Billings Gazette, by Trevor Graff
Wyoming public lands grazers could see shorter permitting times after Congress passed a bill seeking to streamline grazing permit renewals. The Grazing Improvement Act, approved last week, allows the U.S. Bureau of Land Management and U.S. Forest Service to speed the renewal of the agency's 10-year grazing permits.
This new Wyoming lawsuit is a waste of public tax dollars amounting to nothing but a display of chest-pounding bravado to appease ranchers and energy extraction capitalists. This positioning is also a show of allegiance and support for the fringe political initiative to have states take over the management of public lands. It should be duly noted that after BLM's September 2014 round up in Wyoming, the entire population of horses in the state is now only about 2,000 horses! ~ Horses For Life
CHEYENNE, Wyo.- Today, the State of Wyoming filed suit against the United States Department of the Interior and the United States Bureau of Land Management (BLM) over the federal government's failure to appropriately manage wild horses in Wyoming. Wyoming announced its intent to sue in August.
“The lawsuit asks the court to force the BLM to manage wild horses in Wyoming as required by the Wild Free-Roaming Horses and Burros Act,” Governor Mead said. “It is my belief, and the belief of other western governors, that the BLM does not have the resources to manage wild horses effectively. By filing suit it sends a message that wild horse management is a priority and the BLM must be provided the funding necessary to manage them.”
The Wild Free-Roaming Horses and Burros Act requires the BLM to manage wild horses below previously set appropriate levels and to remove excess horses when populations exceed those levels. Herds will continue to exponentially grow beyond what the BLM determined is ecologically appropriate for each herd management area (HMA). These herds have population growth rates that range from as low as 25% to as high as 58% each year. Horses often stray from HMAs onto state and private land.
“Excess wild horses in Wyoming can harm the habitats used by other wildlife species, including sage-grouse, antelope, deer and elk,” Governor Mead said. “Overgrazing caused by overpopulation threatens all animals including horses.”
- View Wyoming's December 8, 2014 Petition for Review. Additional documents, including correspondence with the BLM, can be found on the Attorney General's website at: http://ag.wyo.gov/current-issues.
Source: Wyoming Governor Press Release
Agency Sage Grouse Review Puts Thumb on Scale to Magnify Wild Horse and Burro Effects
The method used by the U.S. Bureau of Land Management to assess range conditions is seriously skewed toward minimizing impacts from domestic livestock and magnifying those from wild horses and burros, according to an appraisal by Public Employees for Environmental Responsibility (PEER). As a result, the BLM’s approach to range management targets scattered wild horses and burros while ignoring far more numerous cattle. The agency’s assessment is part of a 2013 report on factors influencing conservation of the Greater Sage-Grouse, a ground-dwelling bird whose numbers have declined as much as 90% across the West and which is under consideration for protection under the Endangered Species Act. That report concludes that twice the area of sage grouse habitat is negatively impacted by wild horses and burros than the area negatively impacted by livestock. A PEER appraisal of the methodology found:
“At BLM apparently not all hooves are created equal,” said PEER’s Advocacy Director Kirsten Stade, noting that the LHS evaluations cover more than 20,000 grazing allotments and examine whether a grazing allotment meets the agency’s standards for rangeland health with respect to several vegetation and habitat conditions. “This helps explain why wild horses are regularly removed from the range but livestock numbers are rarely reduced.”
The BLM assessment influences not only the agency’s range management decisions but also will figure into the Fish and Wildlife Service’s decision on whether to list the sage grouse under the Endangered Species Act.
Last year in response to a complaint by PEER filed under agency Scientific Integrity policy, BLM claimed that it does not have enough “reliable data” about commercial livestock impacts to include them in current assessments of environmental conditions on Western range lands. Yet, BLM has more data on the grazing that it authorizes through permits than virtually every other topic.
“When it comes to cattle, BLM plays with a marked deck,” Stade added, pointing out the PEER analysis that will become part of PEER’s new grazing reform web center set to launch in several weeks. “We are posting BLM’s own data in a way that allows apples-to-apples comparisons while displaying satellite imagery that depicts the true livestock landscape impacts.”
Compare BLM claims to what their data reveal
The relative negative influence area of feral ungulates with respect to domestic livestock based on BLM’s spatial analysis approach (USGS OFR 2013-1098) are completely at odds with BLM’s own land health standards (LHS) evaluation causal data, used to inform BLM’s analysis. BLM concludes in OFR 2013-1098 that the negative area of influence of feral ungulates is twice that of domestic livestock, when the records show that only 3% of grazing-related failures of standards are attributed to wild horses and burros.