The proposal includes four prongs that must be undertaken simultaneously:

1. Robust fertility control program: Comprehensive large-scale application of proven, safe and humane fertility control strategies to help stabilize wild horse and burro populations on the range and to slow population growth.

2. Strategic, non-lethal gathering: Targeted roundups of wild horses and burros in densely populated Herd Management Areas that cannot sustain large numbers of animals, to protect horses and burros from forage and water shortages, lower populations, and facilitate non-lethal fertility control and population control efforts.

3. Rehoming of horses: Relocate wild horses and burros living in short-term holding facilities, and those taken off the range, to large, cost-effective, humane pasture facilities that provide a free-roaming environment for wild horses and burros.

4. Increased adoptions: Promote the adoption of wild horses and burros into good homes to improve the lives of currently warehoused horses and burros, reduce the total cost of the program, and redirect funds to long-term strategies for the care and sustainability of horse and burro populations.

The proposal was submitted to members of Congress in an effort to encourage financial support necessary for BLM to carry out a truly humane and sustainable management plan.

Yes. The Wild and Free-Roaming Horses and Burros Act of 1971 (the Act) grants the BLM the authority to sell wild horses and burros in holding facilities without limitation (to slaughter) when those animals are more than 10 years old or have been passed over for adoption at least three times. Further, the Act allows for the BLM to destroy healthy horses and burros that it considers “excess.” While this authority, thanks to groups like RTF, has been blocked by Appropriations language since 1994 (save one year), the political and ecological landscapes are shifting such that if the program is not “rebooted,” it is likely the language blocking the BLM from using lethal measures will be lifted by Congress sometime in the near future.

No. The goal of this proposal is to take lethal tools off the table and create a pathway forward to help manage wild horses and burros without resorting to such unacceptable methods. All parties supporting the proposal have committed to the inclusion of Congressional language that no programmatic funding can be used towards the unlimited sale/and or destruction of healthy wild horses and burros. Further, the program specifies that any long-term holding pasture facility that takes in wild horses and burros removed from the range must also agree that no horses or burros under their care are sold to slaughter and that no healthy wild horses or burros are destroyed. These pasture facilities will be required to sign a contract with the BLM stipulating that they will abide by the BLM’s anti-slaughter and destruction provisions.

RTF does not believe that the set Appropriate Management Levels (AML) are properly supported by current and unbiased science. However, the BLM is mandated to maintain the public lands for multiple uses, and under that legal landscape, the BLM has determined that management of wild horses to AML is necessary in Herd Management Areas (HMAs) and this is supported by the Act and by Congress. The Agency is responsible for setting AML and unmanaged population growth is very likely to lead to lethal management options in the near future if a viable solution is not implemented.

In 2018, the BLM removed more than 11,000 horses. Roundups will continue regardless of whether the proposal is implemented, and as populations rise, roundups will increase in number every year. Without a plan to reduce population growth rates, the cycle will never end. So even if we can postpone removals at some point in the very near future — lethal methods will be used at the discretion of the BLM. When and if advocates have managed to postpone roundups, it’s only been a postponement while the population continues to grow, making the situation worse for the horses.

AML is a very controversial topic with both wild horse advocates as well as ranching interests — for opposite reasons. We at RTF believe that AML needs to be examined on a range by range basis, but currently it is imperative that a successful on-the-range management program is established first. The proposal gives Congress the tools to force BLM to manage wild horses on the range with a robust fertility control program. The proposal reflects a consensus to support the use of proven safe and humane fertility control methods while eliminating the constant threat of lethal alternatives, redirecting the focus away from unrestricted sales and inhumane untenable surgical sterilization methods.

RTF believes the appropriate question is not whether there are too many horses and burros, but whether horses and burros are likely to experience safe and humane outcomes given the politics surrounding range use, the current state of forage and water on the range and given the status quo management regime. Wild horses are at growing risk. While we at RTF would like to see much higher AMLs set for wild horses and burros, other interests who also have a vote would not. Meanwhile, wild horse populations have increased from about 27,000 horses in 2007 to over 80,000 in 2018, putting wild horses and burros at risk because of intensifying clashes with multi-uses on public lands, drought, a changing climate and stressed rangelands.

Because both the BLM and Congress are pushing for a significant decrease in the number of wild horses and burros on BLM lands using both lethal and non-lethal methods, our intent in supporting this proposal is to present a non-lethal pathway towards a more responsible and humane wild horse and burro program. This includes slowing down reproduction on the range, and the relocation of horses and burros in short-term holding to larger pastures allowing them to live as naturally as possible.

Not really. Although it requires larger removals the first few years, the horses would still otherwise be removed, though over a longer period of time. This, unfortunately, does not reduce reproduction on the range and that would undoubtedly result in lethal alternatives. This proposed program will require the gathering of horses for fertility control, for relocation to large sanctuaries, adoption, and for stabilization of herd size in sync with the available forage and water on the range. The proposal was modeled to run a 10-year course. However, gathers must be frontloaded in the first few years to harmonize herd size with habitat availability and allow the implementation of a fertility control program that is sustainable. We would like nothing more than a fertility control-only program, but modeling showed that is not possible with the number of wild horses on the range today. Although gather numbers will be larger in the first few years of this proposal, the status quo under BLM’s current management structure would result in more horses and burros being removed from the range in the long-term, and as discussed above would very likely to be expanded to include lethal control efforts.

Yes and No. The proposal was modeled on a 10-year course. However, this doesn’t mean the proposal “ends.” Following the 10-year period, the BLM must continue the ongoing use of fertility control tools, and supplement where necessary with small-scale gathers of adoptable wild horses and burros. During this period, long-term holding facilities will be phased out, as more horses and burros are adopted, and large numbers of additional horses and burros are no longer being removed from the range.

Additionally, we have built into the proposal terms that require reporting from BLM to Congress in years three, five and seven to ensure that the proposal is being properly implemented. This will help ensure that the program stays on track to end the need for large-scale removals in the future.

Additionally, we have built into the proposal terms that require reporting from BLM to Congress in years three, five and seven to ensure that the proposal is being properly implemented. This will help ensure that the program stays on track to end the need for large-scale removals in the future.

Wild horses and burros removed under this program will be relocated into long-term pasture facilities, which provide a free-roaming environment. In order to find additional pasture facilities, the BLM must issue a Request for Proposal for organizations and entities throughout the United States that can provide cost-effective humane, long-term, off-range pasture for wild horses or burros. The BLM would retain ownership of and be accountable for ensuring protection of the animals removed from the range, as well as enforcing consequences for non-compliance. Federally-protected status will be maintained.

Additionally, the proposal also directs that the approximately 14,000 wild horses and burros currently held in corral facilities in the United States be relocated to the more natural environment of pasture facilities.

It mandates it. The proposal includes mandatory use of fertility control tools. The proposal was modeled on the basis of using a fertility control tool that is given annually (such as PZP, which RTF has used at its American Wild Horse Sanctuary with 91-98% efficacy) to treat an increasing number of the mares on the range.

However, the proposal acknowledges that the use of safe and humane longer-lasting fertility control tools will lower costs, reduce the need for yearly treatment, and will speed population decline. As such, the proposal supports the use of longer-lasting safe and humane tools that are currently available, and requests that additional safe and humane tools should be implemented as soon as they become feasible.

No. Currently available fertility control tools are effective, but years of fiscal constraints have left many horses and burros at risk. Solving this problem requires an integrated approach of gathers, fertility control, relocation and adoption. While RTF disagrees with BLM’s population targets, the fact is that the agency and Congress are going to pursue those targets with or without this program, and (absent our help) by lethal means. There is no feasible way to quickly decrease the number of wild horses and burros on the range solely using fertility control tools because of the sheer numbers and locations of horses and burros needing treatment, the fiscal and logistical constraints the BLM is working under, and the agency’s and Congress’ desire to see population levels stabilized in coming years. It is only through a combination of techniques, occurring simultaneously, that a humane outcome can be achieved for wild horses and burros without resorting to lethal control methods.

Fact:In its 2013 report, “Using Science to Improve the BLM Wild Horse and Burro Program,” the National Academy of Sciences advised against the Bureau of Land Management’s current policy of conducting roundups and removals only, specifying that the population growth rate of the animals remaining on the range could be increased by removals. However, this was in the context of removals being conducted without fertility control being applied to the remaining herd members. Our proposal mandates fertility control application alongside gather-removals, which is actually what the NAS identified as effective.

From the NAS Report, pages 267-268:

“The committee also finds that, if AMLs remain set at their 2012 levels (Appendix E, Table E-1), contraception or self-limitation strategies may not reduce horse and burro populations to target levels. To manage horses at 2012 AMLs, horses may first have to be removed. Large-scale removal would require the public to accept gathers on a number of [Herd Management Areas] over a short period, probably within less than 5 years, which would be expensive. Once horses were removed, this approach would also require the culling of thousands of animals or the warehousing of many more thousands of horses in long-term holding. If contraception or self-limitation strategies could curtail population growth rates after a large-scale removal, the costs of long-term holding would eventually decline as fewer horses were placed into these facilities and the horses in holding would eventually leave through sale or death.”

And page 269:

“The committee believes that the tools suggested above would entail more intensive management of horses and burros than it observed during its review of the Wild Horse and Burro Program. The horses at Assateague Island in Maryland and at Shackleford Banks in North Carolina are not subject to the Wild Free-Roaming Horses and Burros Act (P.L. 92-195), but intensive management has proved successful on these islands. Those locations have advantages over many BLM HMAs from a management perspective in that the animals are confined to discrete spaces and the herds are small enough for each animal to be uniquely identified. Nevertheless, they stand as scientifically studied examples of how intensive management can work and what effects BLM could expect from reducing population size and implementing contraception more consistently and widely. As has been seen on Assateague Island and Shackleford Banks, fertility control can help to stabilize population size (Kirkpatrick and Turner, 2008; S. Stuska, National Park Service, email communication, November 1, 2012). Such an outcome on BLM HMAs could be achieved with intensive management if contraceptives were applied every year, as is the case on eastern barrier islands. Although more frequent gathers would be required to achieve similar results on large HMAs in the western United States, any application of contraceptives or chemical vasectomies to a large percentage of horses in a gather would reduce the growth rate and thus the number of horses that BLM would have to remove to meet management goals. The committee recognizes that the multipronged approach of science-based tools that it is proposing would require substantial financial resources from BLM in the short term. It therefore recommends the identification of sentinel populations and HMAs. As suggested in Chapter 2, select HMAs representative of diverse ecological settings could be studied more intensively to improve assessment of population dynamics and ecosystem responses to changes in animal density, management interventions, and variation in seasonal weather and trends in climate. The results of such studies could be used to inform population and ecosystem modeling efforts for HMAs that have similar characteristics. Selecting sentinel HMAs would be more cost-effective than studying every herd, and it is a scientifically sound strategy.”

Fact: The Wild and Free-Roaming Horses and Burros Act of 1971 grants BLM the authority to sell wild horses and burros in holding facilities without limitation (to slaughter) when those animals are more than 10 years old or have been passed over for adoption at least three times. Further, the Act allows for BLM to destroy healthy horses and burros that it considers “excess.” While kill authority and unrestricted sales have been blocked by appropriations language since 1994 (save one year), the past few years have shown that both the agency and Congress are taking steps toward wild horse and burro slaughter or destruction.

For instance, the following have occurred during the last three years:

2016 — The Bureau of Land Management’s National Wild Horse and Burro Advisory Board voted 8-1 to recommend euthanasia of all unadopted wild horses and burros in government holding facilities throughout the United States.

2017 — The Advisory Board voted 8-1 to recommend euthanasia of all unadopted wild horses and burros in government holding facilities throughout the United States.

For Fiscal Year 2018, the president’s budget proposal requested that BLM be able to use “all tools” in the 1971 Wild and Free-Roaming Horses and Burros Act, including lethal management.

For FY18, the House Interior Appropriations bill included a provision to allow the Bureau of Land Management to kill thousands of healthy wild horses and burros (this was blocked by the Senate in Conference).

2018 — The Advisory Board voted 5-2 to support a plan to reach its population target for wild horses and burros within eight years by killing healthy animals and unlimited sales.

For Fiscal Year 2019, the president’s budget proposal requested that BLM be able to use “all tools” in the Act, including lethal management.
The FY19 House Interior Appropriations bill included a provision to launch a program of mass surgical sterilization—a procedure that research has yet to prove is either safe or humane (this was blocked by the Senate in Conference).

2019 – The president’s Fiscal Year 2020 budget justification continued the request to use “all tools,” including lethal management.

Nothing puts wild horses and burros more at risk than arguing that nothing has to change because these equines are safe right now. As the population of wild horses and burros continues to grow on the range, politicians on both sides of the aisle are becoming desperate to find a way to reduce these numbers in a relatively quick manner and have begun considering authorizing lethal methods when previously they wouldn’t have. The proposal presents a pathway forward that uses humane, non-lethal methods to manage wild horse and burro populations.

The almost 50 years of BLM’s Wild Horse and Burro Program and the approximately 270,000 horses that have already been removed from the range during that span are ample evidence that we need to embrace a bold new path forward that leads to the end of large-scale removals.

Fact: Return to Freedom Wild Horse Conservation, The Humane Society of the United States, the American Society for the Prevention of Cruelty to Animals, do not, have never, and will never support the slaughter of wild or domestic horses or burros. Any statements that say otherwise are hostile and false. Thus, the proposal calls on Congress to expressly prohibit the Bureau of Land Management from killing healthy equines or allowing their sale to slaughter.

The goal of this proposal is to take lethal tools – like slaughter or mass euthanasia — off the table and create a path forward to stabilize the population of wild horses and burros without resorting to lethal methods. All the parties supporting the proposal have committed to the inclusion of congressional language that no programmatic funding can be used towards the unrestricted sale (to slaughter)/and or destruction of healthy wild horses and burros.

Further, the proposal specifies that any long-term holding pasture facility that takes wild horses and burros removed from the range must also agree that no such animals under their care be sold to slaughter, and that no healthy wild horses or burros may be destroyed. These pasture facilities will be required to sign a contract stipulating that they will abide by BLM’s anti-slaughter and destruction provisions.

Our decision to provide evidence-based solutions to the wild horse issue came from mounting congressional pressure to find a pathway forward. Many have used the wild horse population as a justification for reopening horse slaughterhouses on U.S. soil or for allowing their sale to slaughter across our borders. With the development of this non-lethal, humane, and sustainable proposal, we have neutralized those threats and are garnering support for a shift in the BLM’s general management paradigm away from removals and off range holding and toward fertility control. If we do not provide an effective alternative to lethal means, we are sure to see those options pushed once more.

We must continue to press for the renewal of the annual appropriations provisions preventing BLM from slaughtering wild horses and burros, or destroying healthy horses or burros, independent of the request for this proposal. Because this proposal results in fewer equines both on AND off the range and provides Congress with a humane, sustainable pathway forward, it increases the chance that Congress will continue to include the rider restricting BLM’s authority to kill wild horses and burros in the appropriations bill.

Fact: The humane groups who endorse this proposal vigorously oppose the slaughter of domestic and wild horses and burros, along with the majority of Americans, and any statements that say otherwise are hostile and erroneous. The ASPCA, Humane Society of the United States, and Return to Freedom have always, and will continue to fight to end the slaughter of America’s equines by working to pass the Safeguard American Food Exports Act (H.R. 961 / S. 2006), which would permanently ban slaughter and the transportation of equines for slaughter.

Additionally, these groups work to keep horse slaughterhouses shuttered in the United States by ensuring that the horse slaughter funding prohibition is included in annual appropriations bills, and protect wild horses and burros from lethal management at the hands of federal agencies charged with their care. For instance, Return to Freedom, HSUS and several other organizations are suing to stop the U.S. Forest Service from carrying out a plan that could result in the sale of wild horses rounded up in California to slaughter.

These legal protections are critical and our groups will continue to work on Capitol Hill to protect all equines from the inhumane fate of slaughter.

Fact: Rep. Chris Stewart has been an active participant in the debate over what to do about growing wild horse and burro herds – and we acknowledge that we have fundamentally disagreed with his stance in the past.

Rep. Stewart has offered two amendments to the Interior Appropriations bill in recent years. The first was an amendment that would allow the killing of healthy horses and burros, which made it into the House bill but was blocked by the Senate in Conference. The second was an amendment for large-scale sterilization of wild horses and burros, which was also in the House bill but was blocked by the Senate in Conference. We opposed both amendments strongly – as we do not support the killing of healthy horses and burros, and we do not support a mass sterilization program that would put wild horses and burros at risk.

We reached out to appropriators, including Rep. Stewart, to talk about non-lethal options. Rep. Stewart said he would be open to humane and non-lethal options if we could show that they will work. We presented a proposal to appropriators that did just that, and he has been willing to support it and not offer amendments similar to the dangerous amendments he offered in past years. He’s been willing to listen to us about our concerns. He has also signed on as a co-sponsor of the SAFE Act (H.R. 961 / S. 2006) to ban slaughter and the transport of horses for purposes of slaughter. We would be happy to have anyone – him or any other member of Congress – support our proposal for the good of America’s horses and burros. Helping to move lawmakers to support non-lethal management of wild horses and to oppose slaughter is exactly why these discussions are important.

Fact: The humane groups supporting this proposal do not believe that the Appropriate Management Level is scientifically supported or consistent across Herd Management Areas. However, we recognize that the Bureau of Land Management is mandated to maintain the public lands for multiple uses, and under that legal landscape, the BLM manages wild horses and burros to the “Appropriate Management Level” it has set for each Herd Management Area. Despite years of pressure and efforts by organizations and advocates to try to increase the AMLs for wild horses and burros, efforts to change AML have been unsuccessful and Congress shares BLM’s view. At this point, the reality is that if a permanent non-lethal path forward, as offered by this proposal, is not implemented, it is extremely likely that the status quo will lead to reduced AMLs (because of continued stress to habitat and limited water in many HMAs), as well as lethal and inhumane solutions such as culling and sales to slaughter. Our goal is to maintain wild horse and burro herds at a level where, given the BLM’s capacity to implement fertility control, those tools have an opportunity to be effective. We hope that discussions to raise AML where possible can continue.

Fact: While the proposal doesn’t specifically require BLM to use PZP, it does mandate the use of available fertility control tools that are considered humane, safe, and effective. As recognized by the National Academy of Sciences, PZP is the best currently available tool that fits into all of those categories. The proposal was modeled using a fertility control vaccine that is given annually (such as Zonastat-H – a form of PZP), and which has a mean efficacy rate of approximately 90%. We did this on purpose — to show that even a conservative approach (i.e., don’t over promise) is more efficient and effective than the current management paradigm. The model we used does not assume that 90% of the mares are treated in every situation. We modeled scaling up fertility control to a point that is achievable and still shows a significant decrease in population growth rates.

The proposal acknowledges that the use of safe and humane longer-lasting fertility control tools will be more efficient and will further lower costs and the number of gathers. As such, the proposal supports the use of longer-lasting safe and humane tools that are currently available, such as PZP-22, and recommends that BLM begin using additional safe and humane tools as they become available.

There are many tools, including surgical sterilization, or gelding, that BLM has been unable to show are safe and humane or effective management techniques for wild horses and burros. This is why our suggested congressional appropriations language requires that all tools used be safe and humane – specifying clearly that BLM cannot use tools that it cannot show meet this criteria. These criteria, because they would be portions of any management plan on public lands, must be met through the National Environmental Policy Act process, which allows for public input.

If passed, appropriations language included in the proposal specifying that methods must be safe and humane would provide additional protections against using dangerous procedures. Absent that language, there is no current legislative mandate specifying that population growth suppression tools used by BLM must be safe or humane.

Fact: The various stakeholders who have been part of formulating this proposal have divergent positions on sterilization and particularly the surgical sterilization of mares. Only fertility suppression that is proven safe and humane would be allowed under this proposal. Currently, no surgical methods have been proven to be safe and humane and it remains to be seen whether any sterilization would be used at all. RTF opposes any surgical sterilization of mares, has been vocal about that in all discussions, and continues to advocate against it. RTF’s position is that not only is surgical sterilization inhumane — especially for wild mares and on the range, it is untenable and fiscally irresponsible. Most people agree that gelding has been proven safe and humane and other methods of fertility control are being developed that could be proven safe and humane. Any sterilization program would need to be thoroughly examined and transparent.

Fact: Continuing the status quo of Bureau of Land Management removals and minor fertility control application is actually significantly more expensive over the long term than this proposal. We acknowledge that this proposal will require an influx of funds to the BLM Wild Horse and Burro Program, however, the proposal envisions an end to large-scale removals into long-term holding facilities. These would be phased out, significantly reducing program costs. At that point, programmatic funding could go to the right priorities: on-range fertility control, determination of accurate “Appropriate Management Level” targets for each Herd Management Area, increased data monitoring of rangeland health and wild horse and burro populations, rangeland restoration work, and better adoption rates. Indeed, if the BLM continues on its current course, the agency’s program would cost more in the 10th year than in the 10th year under the proposal. In other words, the cost of this proposal will decrease over time while the cost of BLM’s status quo management would continue to balloon.

Fact: At current population levels, fertility control alone cannot curb nor maintain population growth on the range. It is that simple.

Currently available fertility control tools are incredibly effective. However, fiscal, logistical, and physical restraints make it impossible for a fertility control-only approach to work. The approximate population of horses and burros on the range is 88,000, according to the Bureau of Land Management. In order for fertility control to stabilize population growth collectively (program-wide, on all Herd Management Areas), close to 90% of female herd members must be treated with some form of fertility control year after year. That means managers have to be able to administer fertility control to about 40,000 animals annually. This is a number well beyond the agency’s physical capacity and/or that of partnered volunteer groups in a given year. Therefore, removals of some horses and burros from the range into low-cost lifelong pasture facilities will be necessary on the front end of the program to stabilize on-range populations.

There is no feasible way to decrease the number of wild horses and burros on the range solely using fertility control tools because of the sheer numbers and locations of animals needing to be treated, the fiscal constraints BLM is working under, and the agency’s and Congress’ desire to see population levels stabilized. It is only through a combination of techniques, occurring simultaneously, that a humane outcome can be achieved for wild horses and burros without resorting to lethal population control methods such as slaughter and mass culls.
There are HMAs where effective fertility control programs are underway and others where populations may be solely managed with fertility control tools. BLM must maintain those programs, and expand them to additional appropriate areas. We cannot stress this enough: this proposal does not result in moving away from partnership-based darting programs on the ground. Instead, it looks to enhance those programs as part of a programmatic-wide application of increased fertility control and public-private partnerships.

Fact: Sex-ratio skewing is not unprecedented, and the Bureau of Land Management has and continues to use it. It is up to the local district manager as to whether he or she wants to use this as a management method to reduce reproduction. Sex-ratio skewing, or indeed ANY management action, must be analyzed in a National Environmental Policy Act document, which is signed off on by the BLM district manager.

Sex-ratio skewing is mentioned in this proposal as one type of possibility in managing specific herds, and not as a programmatic approach. Because there are members of the stakeholder group who utilize sex-ratio skewing to manage animals, their interest in this method had to be discussed.

RTF is not supportive of sex-ratio skewing as a management tool and has expressed this clearly in stakeholder meetings and in our response to Environmental Assessments as BLM moves through the NEPA process for each proposed action. We cannot blindly argue what we do not agree with – we must actually research methods and define our concerns respectfully and with accuracy, not rhetoric.

RTF does not feel sex-ratio skewing is effective to begin with, NOT ONLY because of welfare or behavioral concerns but because mammal populations generally return themselves to the more normal 50:50 sex ratio after a few years’ time. This means that sex-ratio skewing is only effective as a stop-gap, a type of management that we are working to shift. We find it more reasonable and appropriate to defend our position from this angle and to argue towards longer-term, more effective management.

Fact: In advocating for a science-based ecological approach, we are uncertain as to why this means that “wealthy cattle interests and their lobbyists” are the “winners.” We must move forward from points of common ground to find solutions to a problem that can no longer be ignored. The old model, or even a slightly enhanced model, of wild horse and burro management will result in tens of thousands of dead horses on the range, or a desperate attempt to “fix” a catastrophic scenario via culling or euthanasia, perhaps much sooner than most imagine. Like climate change itself, this is no longer an issue to sit back and passively watch unfold, nor to continue, without listening, in the same combative, argumentative, chaotic and reactionary fighting between user and interest groups as has been the pattern. In times of environmental stress, ranchers can remove their cattle from public lands in a day and ship them to market. We cannot do that with wild horses. We must absolutely set our biases aside to achieve healthy horses on healthy lands.

The issue of livestock vs. wild horses and burros vs. wildlife on public lands is and has always been a complicated mire of Western lands usage and rights. Balancing those, along with mining, timber harvest, recreation, and oil and gas extraction is, whether we like or agree with it, how our public lands are managed. There is historical damage to range from overgrazing of livestock, it is true. Whether the carrying capacity of an ecosystem has been exceeded because of historic overuse, too many animals (livestock, wild horses and burros, or other wildlife) or uses in an area, or some combination those, does not matter right now, today. What matters is that we work diligently to open communication and determine ways that ranges can be managed towards the balance of multi-uses on public lands, as required by current law, while we continue to find solutions so that the horses and burros receive a fair share of range and resources.

Congress must provide proper oversight and ensure public transparency of federal agency management. Lawmakers must hold the Bureau of Land Management and other agencies accountable for managing wild horses and burros in accordance with the law and the wishes of Congress, as expressed through the annual appropriations process. We will continue to have discussions with the BLM, cattle interests, range ecologists, advocates, and other land-use managers to further the effort to reduce livestock grazing impacts, implement meaningful fertility control for wild horses, and begin the slow, steady work towards restoring the delicate, high desert ecosystems which wild horses and burros rely upon. If range conditions improve, so too does the possibility of increasing the BLM-set “Appropriate Management Level” for wild horses and burros, where appropriate.

As BLM carries out the stewardship of public lands on behalf of the American people, we will continue to work to change policies towards minimally intrusive management methods and be an active participant in the National Environmental Policy Act process, evaluating the agency’s planned actions related to wild horses and burros and their habitats, providing public comments consistent with current science and best management practices, and, when necessary, entering into litigation if agencies are not complying with the law or to prevent inhumane management or handling methods.

Fact:Stakeholder discussions are complex and involve engaging with perspectives and groups, some of whom we disagree with. There are certainly times when it is helpful to have everyone around a big table. When you’re trying to get into the weeds to develop ideas around policy proposals and management plans, the work is more easily accomplished in smaller groups. It’s just a matter of scale.

This process has included many perspectives, organizations, and people, but neither everyone nor every group is appropriate or has been interested in being involved – and that makes sense. It’s a rugged and messy process, and oftentimes it conflicts with a value or view, and it can certainly interfere with optics. Of course, we hate the rhetoric and the angry backlash, but we feel it is worth the complexities and we respect that other advocacy groups cannot and will not support a diversified stakeholder approach.

The welfare organizations involved in this process have the backgrounds and range of expertise, including scientific expertise, necessary to evaluate the outcomes of various management scenarios, and to speak to the challenges of a successful and well run, programmatic fertility control project for wild horses. Advocating for an outcome and working to discover what actually needs to occur for such an outcome to come to pass are separate activities. As it stands now, is it really possible to stabilize and then manage the population of wild horses and burros with immunocontraceptive vaccines? What would need to happen to scale up such a program and what are the least invasive methods (available currently) through which that could be attained? What would such an effort cost? And most importantly, how long would that take, and how does that time frame compare to the rate at which other uses (public lands are managed for multiple uses, and while we may not agree with those uses, it is the law) compounded by climate change are degrading our rangelands. We are the first group of animal welfare advocates to try to use a science-based ecological approach to modeling outcomes utilizing non-lethal methods: we looked at how different levers in a multi-pronged wild horse and burro management scenario play off of and affect one another.

We are not trying to stifle dialogue; we are trying to find where common ground exists so that we can move forward from that point to find a solution to a problem that absolutely can no longer be ignored. The old model for wild horse and burro management will result in tens of thousands of dead horses on the range, or a desperate attempt to “fix” a catastrophic scenario via culling or euthanasia, perhaps much sooner than we imagine. Like climate change itself, this is no longer an issue to sit back and passively watch unfold, nor to continue, without listening, in the same argumentative, chaotic, and reactionary fighting between the user and interest groups as has been the pattern.

Return to Freedom has been a pioneer for solutions in the horse advocacy and rescue world since 2000. They were the fourth project in the world to manage horses with immunocontraceptive vaccine, and since 1999 they have tested the efficacy of PZP on the fertility of wild horses that they manage. While these projects began on one small ranch, they have expanded to four large ranches and 500 horses, and numerous field based monitoring activities. RTF has managed harem bands on acreages ranging from 300 acres to 30,000 acres. RTF also contributes data towards several long term research projects that characterize the effects of immunocontraceptive fertility control vaccine use on horse reproductive tracts, the immunological response (or lack thereof) of non-responders, and studies of genetic diversity. The RTF biologist assists with the Science and Conservation Center PZP trainings, works with other organizations to help with in-field darting, and sits on the National Wild Horse and Burro Advisory Board.

The Humane Society of the United States houses the Botstiber Institute for Wildlife Fertility Control, a clearinghouse for wildlife fertility control research and data, with an emphasis on advancing effective, sustainable wildlife management methods. The HSUS has been directly involved in wild horse and burro fertility control projects since 1992, partnering with Dr. John Turner (University of Toledo, Department of Physiology and Pharmacology) and the late Dr. Jay Kirkpatrick (Director, Science and Conservation Center) in the earlier years of investigating whether or not immunocontraceptive fertility control could be used effectively on a programmatic scale for wild horses and burros. It further partnered with the Annenberg Foundation, from 2008–2015, to test and evaluate wildlife contraceptive vaccines for wild horses and burros application. Multiple peer-review journal articles have been published about this work.

The ASPCA has a long history of commitment to wild horse and burro welfare. The organization has deployed resources and staff to monitor and report on helicopter gathers, hired experts to conduct detailed analysis of wild horse and burro population dynamics, provided funding for and consulted with private entities on wild horse and burro sanctuaries, been a partner in the development of PZP programs, and been an active participant in tribal solutions. The ASPCA has a renewed focus in equine adoptions – an important piece of the wild horse and burro program – after research in conjunction with Edge Research revealed that there are 2.3 million Americans in the U.S. who are both willing and able to adopt a horse. These programmatic efforts, in conjunction with legislative work, have paved the way for a brighter future for our wild horses and burros.

Collectively, these groups represent over 100 years of horse advocacy experience, and over 50 years of research into the efficacy of fertility control. They are leveraging their on-the-ground understanding of fertility control with science based population estimates to test and evaluate different management scenarios with the hope of finding a path towards sustainable wild horse population management in an era where climate change will greatly reduce the wildlife healthy rangeland can support.

Fact: With a 20% population growth rate, wild horse populations double approximately every four years. Right now, the Bureau of Land Management estimates there are a minimum of 80,090 wild horse on the range. With no gathers, and no targeted NON-LETHAL population control, there could be 219,197 wild horses and burros on-range in five short years, 545,431 in ten years, and so on. Would these numbers really occur? Quite possibly the population would begin to deteriorate in health, and the land would struggle. Climate change has altered our rangeland habitat and there are simply not enough resources to sustain hundreds of thousands of additional wild horses and other wildlife, including endangered species, that rely on rangelands. Indeed, if the BLM continued with “business as usual,” which would mean an average of 12,000 horses gathered and removed per year and no meaningful fertility control, that would mean 129,898 wild horses and burros on-range in five years, and 233,930 at the end of 10 years, with an on-range population continuing to increase. That’s the kicker: at the end of that 10 years, 233,930 horses and burros would be on-range, with no potential to back off of or discontinue gather-removals. Our non-lethal Proposal achieves approximately 45,000 wild horses and burros on-range in five years, and 37,600 in 10, with gather-removals finally an exception, and not the rule. It was developed to stave off the very real threat of reaching an ecological breaking point, where lethal means could no longer be rejected by Congress, no matter how loud the American public screamed.

The ongoing increase in wild horse and burro populations has resulted in repeated calls to use all of the tools in the 1971 Wild and Free-Roaming Horses and Burros Act to reduce on- and off-range populations — including increasing sales without restrictions against slaughter and killing “excess” animals in holding facilities.

The Bureau of Land Management has stated more than once that it plans to increase wild horse and burro removals in coming years. We thought it was critical to be part of a dialogue with other rangeland interest groups that often lobby to reduce the number of wild horse and burros. If we want to truly protect wild horses and burros for the long run, we must find common ground, non-lethal alternatives, urging Congress to both shut down pathways to slaughter / euthanasia and mandate that BLM implement proven, safe and humane management tools.

The proposal requires that the gather and removal of wild horses and burros is done with the explicit goal of eventually eliminating this as a management option (because it would no longer be needed). There is no other way to achieve this outcome. Further, this proposal calls for gather and removals of fewer horses (because there would be an end to this cycle) than current BLM practices.

Because BLM will be removing larger numbers of horses in the coming years, this proposal recommends that BLM frontload them, removing larger numbers of horses in the first three years while simultaneously implementing a fertility control program for the mares left on the range. That allows fertility control to “catch up” with reproduction.

For years 4-10, the proposal calls for steadily decreasing numbers gathered and removed, with an eventual balance between fertility control and maintenance of populations achieved. This would mean that by year 10 removals would be limited — an exception to the rule, ending the more than 40-year-old capture-and-removal management paradigm.

Fact: The nonprofit humane organizations supporting this proposal have nothing to gain financially and are not being paid in any way by the ranching industry. Further, there is no formal partnership between any of the groups supporting this proposal. Nor does the mutual support of this proposal impact any of our important campaigns, including preventing the slaughter of America’s domestic or wild equines for human consumption.

Fact: The Bureau of Land Management has been consistent over the past few years in the way it wants to manage wild horses and burros: the agency wants to be able to use lethal means or remove horses and burros down to the agency-set “Appropriate Management Level.” The agency has said recent statements to Congress stated that it is looking for a humane pathway forward that will not involve killing horses and burros — and we hope that Congress will require the agency to adopt this new pathway forward.

Fact: Here is the list of groups that currently endorse this proposal to Congress. We hope to see more groups that are frustrated with the Bureau of Land Management’s status quo join us in supporting this humane path forward for wild horses and burros.

• ASPCA
• American Farm Bureau Federation
• Society for Range Management
• Humane Society Legislative Fund
• Public Lands Council
• Return to Freedom Wild Horse Conservation
• National Horse and Burro Rangeland Management Coalition
• Eureka County, NV County Commission Office
• The Humane Society of the United States
• National Cattlemen’s Beef Association
• Beaver County, UT County Commission Office
• American Mustang Foundation
• Utah Governor’s Office

Fact: In some areas, wild horses and burros can be removed from the range or treated with fertility control tools without the need for helicopter gathers. In those areas, the proposal specifies that the agency should focus their efforts on ground darting programs, and bait-and-water trapping for the removal and/or application of fertility control for wild horses and burros. However, in other areas, wild horses and burros are unapproachable and live in incredibly remote and inaccessible areas. In those cases, it may be necessary for the agency to use helicopters to ensure removal and the application of meaningful amounts of fertility control (this is true regardless of whether this proposal is implemented).

With that said, other wild horse groups have fought amazing battles establishing the Comprehensive Animal Welfare Program (CAWP), though we know the Bureau of Land Management and its contractors do not always abide by it.

Because helicopter gathers will continue (with or without our proposal), we believe that it is important to have appropriations language stressing that BLM must abide by the Comprehensive Animal Welfare Program (CAWP) to ensure the safety of the herds during removals, showing Congress’ intent that BLM follow the CAWP guidelines for the first time.

Fact: For the purposes of modeling only (necessary to conclude whether or not a large-scale fertility control program would be effective, how long it would take, and how much it would cost), this proposal strives to achieve a population of 20% over the Bureau of Land Management’s currently established “Appropriate Management Level” and focuses solely on BLM lands (there are also free-roaming horses on tribal lands, U.S. Forest Service lands, state lands, and National Park Service lands). There is no supporting evidence or documentation that this population level on BLM lands would lead to the extinction of wild horses or burros. We are proposing a long-term solution in which healthy herds of wild horses and burros can exist on public lands in perpetuity — without the risk of lethal means of population control.