RTF opposes proposed regulatory changes reducing transparency, public input

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Photo of Sarge taken at RTF’s American Wild Horse Sanctuary by Paloma Ianes.

The White House and members of Congress have called for streamlining regulations related to the landmark National Environmental Policy Act. The law requires government agencies, including the Bureau of Land Management, to lay out options considered during the land-use planning and environmental review process and consider the consequences of their actions. Read RTF’s comments below.

Comments by:
Return to Freedom Wild Horse Conservation
August 20, 2018

We are writing to express our strong opposition to proposals that would streamline National Environmental Policy Act regulations regarding management of wild horses and burros, rangeland and resources in a way that would reduce transparency and, as a consequence, sow public distrust.

Specifically, a Bureau of Land Management report BLM Report in Response to Secretarial Memorandum on Improving Planning and NEPA Processes and Secretarial Order 3355 suggested the following categorical exclusions from NEPA regulations that would leave the public almost entirely in the dark about critical functions of the BLM’s Wild Horse and Burro Program. These include:

* Wild horse and burro gather operations;

* Sales of excess wild horses and burros;

* Application of population growth suppression techniques to wild horses and burros, including contraception and sterilization;

* Euthanasia of excess wild horses and burros for which an adoption or sale demand does not exist.

The BLM report also calls for shortening or even eliminating public comment periods, altogether, and limiting the number of Freedom of Information Act requests from any one organization, increasing fees and requiring more stringent justification for fee waivers.

The production of Environmental Assessments that examine the consequences of BLM actions are critically important when dealing with an issue as volatile as resource, range, and wild horse and burro management — not for wild horse advocates alone, but for all of those with a vested interest in the multiple uses of BLM land and its future. Transparency is essential for helping the public understand how and why their tax dollars are being used in regard to public land generally and wild horses and burros specifically.

Indeed, public trust and an open examination of the options that BLM considers when making decisions about wild horses and burros are vital at a time when Congress, stakeholder and the agency itself are trying to find a politically viable path forward that provides wild horses and burros with a sustainable future — one that begins to more humanely manage these iconic, federally protected animals in a forward-thinking way while working to curtail cost.

Limiting the avenues through which the public can participate in the decision-making process will further frustrate the public. It will feed distrust of BLM at a time when discussions about wild horse management between opposing sides and public-private partnerships are relatively new and fragile.

Finally, restricting the ability of organizations to seek information by limiting FOIA requests and/or higher fees or reducing waivers will hinder the effectiveness of all but the largest organizations to act as a watchdog on behalf of citizens. The American people deserve to know how BLM is using their tax dollars to manage wild horses and burros on public lands.

To so dramatically reduce transparency would be wholly undemocratic. It would be a complete breach of the principles and spirit of freedom upon which this country was founded – a spirit that many Americans feel is embodied by the wild horse.

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