Wild horses on the Onaqui Mountain Herd Management Area in Utah.
We, the undersigned, call upon Congress to provide greater oversight of legally mandated multiple-use management of public lands in the intended, comprehensive scientific manner, taking into account ecosystem health in a changing climate. Specifically, we urge lawmakers to require the Bureau of Land Management (BLM) and U.S. Forest Service (USFS) to consider higher population targets for wild horses and burros, known as Appropriate Management Levels (AML) in Herd Management Areas / Wild Horse Territories (HMAs).
The resource allocation needs for these federally protected animals 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 of 1971.
As BLM / USFS work to stabilize wild horse and burro herd numbers through the use of safe, proven and humane population control methods, the agencies should revisit their population goals through the lens of stabilized populations and ecosystem health. When analyzing these areas and the potential for adjusting AML, BLM and USFS should take into account necessary forage and water for wild horses or burros and other wildlife. They should also take into consideration the full impact of all other multiple uses, including, but not limited to, private livestock grazing, energy extraction, and public recreation.
BLM and USFS should strive to manage for multiple uses and healthy ecosystems under the agencies’ own established methodologies to determine if ecologic parameters are met. Their assessment approaches include Proper Functioning Condition (PFC: ecologic parameters that must be assessed and synthesized to determine overall health of a riparian or wetland area) and Interpreting Indicators of Rangeland Health (IIRH: ecologic parameters that must be assessed to determine overall health of upland habitats). These are well-established assessments for determining ecological conditions and vital management tools for decision making. Proper oversight is required to ensure already established protocols are implemented with consistency across field offices with the goal of ensuring ecological integrity, and that the process of implementation does not become politicized or inconsistently applied.