Photo taken at RTF’s San Luis Obispo, Calif., satellite sanctuary by Meg Frederick.

The Bureau of Land Management recently released its 2021 Wild Horse and Burro Strategic Research Plan.

Return to Freedom supports the two major areas of research focus – longer-lasting fertility control options and the impacts of climate change – and remains cautiously optimistic for fairer wild horse and burro management on the range.

However, RTF is concerned about and will keep a careful eye on the following:

–That ongoing research not be used as an excuse to forgo the immediate implementation of readily available fertility control that could begin a shift away from the agency’s decades-long practice of removal and warehousing of wild horses.

–That the agency continues to insist upon reaching the BLM’s controversial “Appropriate Management Level” before implementing safe, proven and humane fertility control. This is a fundamental flaw.

Scientific modeling created with ecologists and economists shows that a robust program of fertility control is necessary to slow herd growth, phase out often deadly helicopter roundups and save taxpayer money over time. To make progress in that direction, however, the modeling shows that BLM must begin implementing fertility control in a real way — immediately.

The agency’s increasingly aggressive, roundup-only management will only result in BLM continuing to chase and briefly achieve agency-set “Appropriate Management Levels” (AML) on some of the 177 Herd Management Areas in 10 states. Most advocates believe that the levels are set arbitrarily low, while this document treats them as gospel.

If mares are not treated with fertility control to slow reproduction on the range and released, even in emergency situations, these roundups will be followed by increases in the herd populations, and then, as usual, BLM returning to remove and place more wild horses alongside more than 50,000 already in off-range holding.

–That BLM continues to view the impacts of wild horses and burros in a vacuum. While it’s important to understand the interaction between wild horses and burros and their environment, especially in light of climate change, this document again points to studying the impacts of wild horses and burros without mentioning other public land uses like livestock grazing.

RTF strongly believes that BLM must view management on a Herd Management Area by Herd Management Area basis. It must manage wild horse and burro Herd Management Areas (HMAs) in a holistic way, taking into consideration the full impact of all other legally mandated multiple uses, including, but not limited to, private livestock grazing, energy extraction, and public recreation.

The resource allocation needs for these federally protected wild horses and burros have for decades been considered last when their population and needs should be considered equally on areas that were legally designated for them to free roam, and weighted equally against other multiples uses that overlap Herd Areas / HMAs that were designated for their protection under the Wild and Free-Roaming Horses and Burros Act. BLM should consider higher population targets for wild horses and burros (AMLs) in Herd Management Areas.

–That BLM states that “so long as welfare, health, and free-roaming behaviors are not adversely affected by a given humane fertility control method, more specific behavioral effects of fertility control methods — such as changes in group size, band structure, and habitat use — are no longer considered centrally important research topics at this time.” RTF believes that disregarding natural behaviors and herd dynamics is contrary to the spirit of the Wild and Free-Roaming Horses and Burros Act.

—That although the document says that the agency will continue to use PZP, a non-hormonal fertility control vaccine that RTF has used for more than two decades with 91-98% efficacy, BLM notes that it “plans to significantly expand the use of GonaCon.” Because GonaCon affects the hormone system, it may cause behavioral changes that would alter herd dynamics. Because it has not been used and researched for as long as PZP vaccines have, RTF believes more studies are needed to ensure that GonaCon meets the parameters of ethical and thoughtful wildlife fertility control.

–That BLM “could also consider” surgical mare sterilization methods. RTF strongly opposes surgical sterilization of mares, not least because injectable, immunocontraceptive fertility control has long presented a cost-effective and humane alternative to capturing and warehousing wild horses – and to the risks and costs of sterilization —but is not being adequately implemented by the BLM.

–That the document says that “permanent humane sterilization options could be a fiscally responsible part of local herd management.” No such one-use vaccine currently exists. RTF will be watching this closely and would only support such a tool if it was proven, safe and humane.

–That BLM notes that “while wild burro herds are at levels well above AML, it is the BLM’s recent experience that almost all wild burros can be removed from the wild and placed into private care at costs that are comparable to the cost of treating and releasing them.” This again runs counter to the spirit of the Wild and Free-Roaming Horses and Burros Act, which states that “management activities shall be at the minimal feasible level.” The law provides for the protection of wild and free-roaming horses and burros — not what is most convenient for BLM.

–That BLM references as a continued basis for decision-making the BLM’s deeply flawed 2020 report to Congress. The 2020 report is unclear and inconsistent even on fundamental issues, calling for large removals of varying numbers of wild horses even within the report. In another contradiction, the report called for implementing fertility control after achieving AML but elsewhere seemed to describe scaling up fertility control from year one. Since issuing the report, of which RTF was critical, BLM has embarked on an aggressive campaign of removing wild horses and burros while continuing to use little to no fertility control.

BLM’s Strategic Research Plan does include a number of worthwhile secondary areas of research, but these are much less likely to receive funding. These include: improving herd size estimates and demographic modeling, population genetics, and wild horse and burro health, handling and welfare.

The document also includes as secondary areas of research private care placement and sociological and anthropological research into human attitudes and behaviors regarding wild horses and burros.