What does Project 2025 say about wild horses?

/ In The News, News, Staff Blog
A mare and her foal of the Salt Wells Herd Management Areas (Wyo.) Photo by Meg Frederick.

The Heritage Foundation’s Project 2025 drafted a plan to overhaul the federal government, “Mandate for Leadership: The Conservative Promise,” in order to “to lay the groundwork for a White House more friendly to the right.”

Project 2025 includes at least 45 “right-of-center organizations” and the document, called a “policy guide” spanning government agencies “represents the work of more than 350 leading conservatives,” the associate director of the 2025 Presidential Transition Project wrote. It was published in April 2023.

Republican nominee Donald J. Trump has repeatedly disavowed the document.

Published in April 2023 at a length of more than 900 pages, the document even includes the management of federally protected wild horses and burros on pages 560-1 (see complete text in italics below).

The section concludes this way: “Congress must enact laws permitting the [Bureau of Land Management] to dispose humanely of these animals.”

The chapter on the Department of the Interior, including BLM’s Wild Horse and Burro Management Program, is credited to William Perry Pendley. He served as the acting director of the BLM from July 2019-July 2021.

Why does the language in the think tank’s document matter?

This threatening language related to wild horses harkens back to 2017, a time during which the House voted to authorize the BLM to euthanize — shoot, in all likelihood — tens of thousands of captive wild horses and burros. Fortunately, the Senate ultimately rejected that move.

As we said at the time: “Killing tens of thousands of wild horses and burros would be a betrayal of millions of taxpayers who want wild horses protected as intended in the 1971 Wild Free-Roaming Horses and Burros Act and who have invested tens of millions of dollars in their care.”

However, this is not a given.

The 1971 Wild Free-Roaming Horses and Burros Act allows for euthanasia and sales without restriction. The Public Rangelands Improvement Act of 1978 again listed that wild horses be kept at a population target, called an “Appropriate Management Level,” by listing outright that the management agencies “determine if AML should be achieved by removal or destruction of excess animals.”

Americans do not want their wild horses and burros managed via euthanasia. In 1981 and 1982, the BLM euthanized 47 horses for management — and the public outcry was tremendous. This led then-BLM Director Robert Burford to ban the destruction of healthy horses and burros for the purposes of management.

Congress too has repeatedly inserted annual budget language barring the BLM from killing healthy wild horses and burros or selling them to slaughter. RTF successfully lobbied to have the same prohibition extended to the U.S. Forest Service starting in 2020.

Colorado State University and the U.S. Fish and Wildlife Service recently looked at American Wildlife Values:  Americans have an overwhelmingly mutualistic view of wildlife, seeing animals as part of our lives, with non-lethal management highly preferred.

The language in the Project 2025 document reflects older views in a conversation we’ve worked very hard to change both in tone and substance. That such language persists in a document published by a prominent foundation should be disturbing to anyone who cares about the future of America’s wild horses and burros.

Our and others’ work with divergent public lands stakeholders has resulted in broad support for a non-lethal wild horse and burro management approach that includes the use of proven, safe and humane fertility control.

Because of this support, Congress has begun calling for (though not yet demanding) fertility control use and providing additional funding for the BLM program.

The agency has not meaningfully scaled up fertility control, however.

Instead, BLM has doubled down on capture and removal, resulting in thousands more captured animals living in off-range holding facilities at ever-greater cost to taxpayers. That cost and the number of wild horses on and off the range could again be used to justify a push for euthanasia as it does in the Project 2025 policy guide.

Should this kind of lethal management language resurface in Congress or elsewhere, we must stand ready to resist it.

Project 2025 text

Wild Horses and Burros. In 1971, Congress ordered the BLM to manage wild horses and burros to ensure their iconic presence never disappeared from the western landscape.1 For decades, Congress watched as these herds overwhelmed the land’s ability to sustain them2, crowded out indigenous plant and other animal species3, threatened the survival of species listed under the Endangered Species Act, invaded private and permitted public land, disturbed private property rights4, and turned the sod into concrete.  BLM experts said in 2019 that some affected land will never recover from this unmitigated damage.5

There are 95,000 wild horses and burros6 roaming nearly 32 million acres7 in the West—triple what scientists and land management experts say the range can support. 8These animals face starvation and death from lack of forage and water. The population has more than doubled in just the past 10 years and continues to grow at a rate of 10 to 15 percent annually.9 This number includes the more than 47,000 animals the BLM has already gathered from public lands, at a cost to the American taxpayer of nearly $50 million annually to care for them in off-range corrals.10

This is not a new issue—it is not just a western issue—it is an American issue. What is happening to these once-proud beasts of burden is neither compassionate nor humane, and what these animals are doing to federal lands and fragile ecosystems is unacceptable.11 In 2019, the American Association of Equine Practitioners and the American Veterinary Medication Association—two of the largest organizations of professional veterinarians in the world—issued a joint policy calling for further reducing overpopulation to protect the health and well-being of wild horses and burros on public lands.12 The National Wild Horse and Burro Advisory Board, a panel of nine experts and professionals convened to advise the BLM, endorsed the joint policy.13 Furthermore, animal welfare organizations such as the American Society for the Prevention of Cruelty to Animals and the Humane Society of the United States recognize that the prosperity of wild horses and burros on public lands is threatened if herds continue to grow unabated.14

The BLM’s multi-pronged approach in its 2020 Report to Congress included expanded adoptions and sales of horses gathered from overpopulated herds; increased gathers and increased capacity for off-range holding facilities and pastures; more effective use of fertility control efforts; and improved research, in concert with the academic and veterinary communities, to identify more effective contraceptive techniques and strategies.15 All of that will not be enough to solve the problem, however. Congress must enact laws permitting the BLM to dispose humanely of these animals.16

Selected Footnotes and RTF Comments

  1. Wild Free-Roaming Horses and Burros Act ↩︎
  2. This implies that wild horse and burro herds were not being managed, a task assigned by the 1971 Act primarily to the Bureau of Land Management. The agency has tried and failed for more than 50 years to manage wild horses and burros through capture and removal without addressing reproduction. Proven, safe and humane fertility control has been available all along and RTF has called for its use for more than two decades to slow herd growth without stopping it.
     
    This also strongly implies that wild horses and burros are solely responsible for range degradation. That is false. Under the 1976 Federal Land Policy and Management Act, the Bureau of Land Management and U.S. Forest Service are required to manage our public lands for “multiple uses,” including private livestock grazing, energy extraction and public recreation as well as habitat for wild horses, burros and other wildlife. Of the 245 million acres of public land managed by the BLM, the agency allows livestock grazing on 155 million acres (63%). Wild horses and burros are restricted to 26.9 million acres (11%).
     
    In 2021, the most recent year for which data are available, authorized livestock use on BLM-managed lands was 8.3 million Animal Unit Months, the annual equivalent of 690,662 cow-calf pairs. Authorized wild horse use on BLM-managed lands is 321,420 AUMs or 26,785 wild horses and burros. Even on BLM-managed land designated as wild horse habitat, the agency allocates the majority of forage to privately owned livestock — not wild horses. 
     
    Pitting one species against another has not proved constructive. We must instead insist upon thoughtful and responsible use of public lands. They are mandated for multiple-use, a perhaps impossible task, but one we must follow with management decisions based on ecology and health of the lands which support all of our uses, but also all of the life on that land.
     
    Diversity in the natural world is the solution and not the problem. We must focus more on how the grazing animals are managed. Our own experience at the sanctuary with the implementation of regenerative holistic grazing is yielding positive results. We imitate how herds would have moved at a time with predators but before fences. This allows land to rest and for the native grasses to regenerate. ↩︎
  3. This implies wild horses are not a native species. In fact, they are a reintroduced native species. Horses originated in North America some 53 million years ago and traveled over the Bering Land Bridge, dispersing into Asia 800,000 to 1 million years ago. DNA evidence shows that the horse remained in North America at least as recently as 5,000 years ago.  They may be relegated to fragile high desert and sagebrush steppe now, but decisions about their management should be based upon a true belief that they belong on the landscape. ↩︎
  4. Under the Act, the BLM is required to remove wild horses and burros from private land if requested by the landowner. ↩︎
  5. Among those that declared “some lands in the West will never recover” was the acting director of the BLM, William Perry Pendley. He went so far as to call wild horses “an existential threat” to public lands, language mirrored by the BLM in its budget justification under his leadership. “Critics noted that Pendley failed to also mention the impacts of increased oil and gas development, livestock grazing and climate change on rangeland health,” noted E&E News. Pendley served as acting director for two years during the Trump administration but was never confirmed by the Senate. Prior to being appointed, he lobbied for public lands to be sold off. ↩︎
  6. This figure is based on a 2020 BLM estimate. As of March 2024, the BLM estimates that there are 73,520 wild horses and burros on land that the agency manages. The U.S. Forest Service has previously said that it manages about 7,900 wild horses and burros. ↩︎
  7. The BLM manages wild horses on 26.9 million acres and the USFS on 2.5 million acres for a total of 29.4 million acres. ↩︎
  8. The BLM-set “Appropriate Management Level” for wild horses and burros on lands that it manages is 26,785. Wild horse advocates including RTF believe this is an arbitrary number that is not based in sound science. ↩︎
  9. he BLM’s population estimates did more than double from 2005-08 to 2017. A 2013 National Academy of Sciences report identified fertility control as an effective tool for managing the wild horse population while blaming BLM’s system of capture and removal for promoting population growth (since competition is removed when population numbers go down and remaining animals experience a population surge due to availability of resources). Between 2020-23, the BLM captured and removed about 50,000 wild horses from the range while treating just 4,237 mares with fertility control. Wild horse population growth rates can be near 20%, which is very high for hooved mammals.  In the words of Allen Rutberg, director of the Center for Animals and Public Policy at Cummings School of Veterinary Medicine at Tufts University and a long-time wild horse contraception researcher, “The wild horse challenge cannot be solved unless wild horse reproduction is managed on the range … To reduce the number of gathers and the flow of animals into holding, improve the health of the range long-term and find its way out of its perpetual wild horse crisis, the BLM must develop and put into practice locally tailored long-term plans to manage wild horses and burros with fertility control.” ↩︎
  10. Because of the BLM’s single-minded focus on removals, there are now 63,034 captured wild horses and burros in off-range holding facilities — only 17% fewer than the number that the agency estimates are living on the range. Of the horses and burros in holding, more than 22,000 live in often overcrowded corral facilities. As of Fiscal Year, 2023, off-range holding cost $108.5 million — 69% of the BLM’s annual Wild Horse and Burro Program budget. Population modeling has shown that immediately implementing fertility control alongside any removal that the BLM is already conducting is the only realistic way to stabilize herd growth, replace removals as the agency’s primary management tool and save taxpayer dollars over the long run. RTF has also advocated for — and Congress has called for — relocating wild horses and burros from corral facilities to more natural and cost-effective pastures. ↩︎
  11. Placing the blame solely on the wild horses and burros themselves — not livestock grazing, energy extraction, road building, logging, recreation, mining, climate change, the BLM’s management decisions or congressional funding — is ridiculous. All of our uses on public lands impact those lands, and the effect is cumulative over time. We have fast entered a phase where all of our uses will need to be compromised due to a drying western landscape and ecosystems that lack both resistance (the ability to withstand ecological stressors) and resilience (the ability to recover from ecological stressors). ↩︎
  12. Many equine veterinarians disagree with this stance, and we feel these organizations representing them are taking a dated approach to this issue and should seek centered, common ground from which to operate. ↩︎
  13. Since 2020, the National Wild Horse and Burro Advisory Board has crafted recommendations that are based on the diverse experiences and backgrounds of the board members and that are strategic, broadly acceptable, unified and actionable; they have voted repeatedly to support fertility control, not lethal tools. ↩︎
  14. The ASPCA and HSUS support a non-lethal, multi-pronged approach to wild horse and burro management that emphasizes the use of fertility control and is more economically and environmentally viable. Like RTF and a broad variety of other public lands stakeholders, they agree that BLM’s program is unsustainable and needs redirection. ↩︎
  15. The BLM did indeed include a multi-pronged approach in a 2020 report to Congress. RTF spoke out critically about the report, calling it unclear and inconsistent on even fundamental issues. Most importantly, the BLM report said that the agency would implement fertility control — but only after achieving its own “Appropriate Management Level.” In other words, the agency would continue to focus on removals, the same approach that has failed for decades. ↩︎
  16. In 1981 and 1982, the BLM did euthanize 47 horses for management — and the public outcry was tremendous.  This led then-BLM Director Robert Burford to ban the destruction of healthy horses and burros for the purposes of management.  In 2017, House Appropriators passed an amendment to the Interior appropriations bill that would have allowed BLM to euthanize — in all likelihood shoot — healthy wild horses and burros. A year later came a push to allow mass sterilization. The American people and Congress rejected both, as they have over and over again, with Congress again including budget language barring the BLM from killing healthy wild horses or burros. ↩︎