Inequitable Allocation of Forage in Bureau of Land Management Wild Horse Herd Management Areas 82.5% to livestock; 17.

5% to wild horses
April 2, 2013

OVERVIEW The American Wild Horse Preservation Campaign evaluated Bureau of Land Management (BLM) data on forage allocations in 50 Herd Management Areas (HMAs) where roundups were conducted between 2010 and 2012. The survey found that the BLM allocates 82.5% of forage in designated wild horse HMAs to privately-owned livestock, while just 17.5% of forage is allocated to wild horses. THE DATA The data on forage allocations is presented below. It is taken from BLM Environmental Assessments (EAs) for wild horse roundups conducted in 50 of the BLMs 179 existing HMAs between 2010 and 2012. The HMAs were chosen for analysis based on the EAs provision of detailed forage allocations data. The forage allocations are measured in Animal Unit Months (AUMs). An AUM is the amount of forage needed to sustain one

cow/calf pair, one horse, or five sheep for a month. The AUM allocations for wild horses are based on the high Appropriate Management Levels (AMLs) for wild horses. This is the maximum number of horses the agency allows in the HMAs. WILD HORSE HIGH AML AUMs 100 1200 140 1680 151 1812 37 22 140 85 75 80 298 231 250 140 185 518 276 27 60 165 217 180 120 364 40 124 15 18 493 49 444 264 1680 1020 900 960 3576 2772 3000 1680 2220 6216 3312 324 720 1980 2604 2160 1440 4368 480 1488 180 216 5916 588 LIVESTOCK AUMs 7904 58433 8340 6593 3019 2816 4796 4795 1490 21684 27212 16652 8315 11439 36,472 11673 5009 4299 4274 7323 6769 0 13985 2239 4710 4102 6358 22247 477

HMA STATE Swasey HMA UT McCullough Peaks WY Diamond NV Diamond Hills North NV Diamond Hills South NV Murderers Creek OR Buckhorn CA Coppersmith CA Little Humboldt NV Little Owyhee NV Owyhee NV Rock Creek NV Snowstorm Mountains NV Challis ID Triple B NV Maverick-Medicine NV Antelope Valley Herd NV Frisco UT Wassuk HMA UT Jackson Mountain NV Desatoya Mountain NV Pryor Mountain MT Stone Cabin NV Saulsbury NV Flanigan NV Dogskin NV Granite Peak NV Pancake NV Sand Springs West NV

Jake Wash Piceance East Douglas Black Rock Range East Black Rock Range West Calico Mountain Granite Range Warm Spring Canyon Jackies Butte Three Fingers Bitner Fox Hog Wall Canyon High Rock Nut Mountain Augusta Mountains **ANTELOPE COMPLEX `

NV CO NV NV NV NV NV OR OR CA CA CA CA CA NV NV

0 235 93 93 333 258 175 150 150 25 220 25 120 55 308 788

0 2820 1116 1116 3996 3096 2100 1800 1800 300 2640 300 1440 660 3696 9456 91536

8354 6935 1326 2244 2373 2175 3272 3997 3820 3581 8384 3234 3668 2446 6188 56090 431512

**Livestock allocation data provided for the entire complex, which includes four HMAs (Antelope, Antelope Valley, Goshute and Spruce Pequop). Shaded areas represent HMAs that the BLM has grouped together into complexes. Total Forage in AUMs allocated to livestock & wild horses: 523,048 AUMs. ANALYSIS This survey encompasses 30% of the BLMs existing HMAs. It clearly demonstrates that the BLM consistently favors livestock over wild horses by allocating 82.5% of forage in designated wild horses areas to livestock while allocating only 17.5% of forage to wild horses. This preference for livestock occurs despite the fact that the BLM is mandated by federal law to protect wild horses, whereas livestock grazing is authorized entirely at the discretion of the Secretary of the Interior.

Of the 245 million acres of public land managed by the BLM, 155 million is open to livestock grazing (virtually all BLM land outside of Alaska). By contrast, wild horses are restricted to just 26.9 million acres, which they must share with livestock. Even though wild horses are restricted to a small fraction (11%) of BLM land, the agency routinely allocates the vast majority of forage on this land to privately-owned livestock instead of federally-protected wild horses. This inequitable distribution of resources is the basis on which the BLM has set Appropriate Management Levels (AMLs) for wild horses. AMLs do not reflect the carrying capacity of the land for wild horses. Rather, the AMLs reflect the number of wild horses that the BLM has decided to allow after giving away the majority of forage resources to private livestock. For example, in our survey of 50 HMAs, the average maximum allowable population for wild horses is 166 on an average HMA size of 249,000 acres. That is one horse per 1,500 acres or 2.3 square miles! Meanwhile, the average, annual equivalent of cows permitted to graze per HMA is 9,380. This survey puts BLMs claims of wild horse overpopulation in perspective. When the wild horse population exceeds the artificially-low AMLs, the BLM claims the horses are overpopulating. In reality, the wild horse population has only exceeded the artificial management levels established by BLM based on the giveaway of the vast majority of forage to livestock. In virtually every HMA, the number of livestock per HMA fare exceeds the number of wild horses. The BLMs preferential treatment of livestock costs taxpayers money. The BLM charges ranchers $1.35 per AUM to graze livestock on private land. This is the lowest fee allowable under federal law and a small fraction of market rate, thanks to our tax subsidies. (The average monthly cost per head to graze livestock on private land is $16.80.) The BLMs grazing program costs $37.4 million in administrative fees only; the Center for Biological Diversity estimates that the total cost to taxpayers for livestock grazing on public land is $500 million.

REFERENCES Environmental Assessments for Wild Horse Gathers in: Swasey HMA, 2012 McCullough Peaks HMA, 2012 Diamond Complex, 2012 Murderers Creek HMA, 2012 Buckhorn and Coppersmith HMAs, 2012 Owyhee Complex Challis HMA, 2012 Triple B Complex Frisco HMA Wassuk HMA Jackson Mountain HMA Desatoya HMA Pryor Mountains National Wild Horse Range Stone Cabin Complex Flanigan, Dogskin, Granite Peak HMAs Pancake Complex Piceance-East Douglas HMA Tri-state Calico Complex Jackies Butte HMA Three Fingers HMA High Rock Complex Augusta Mountains HMA Antelope Complex Public Lands Grazing Costs Congressional Research Service: Grazing Fees: Issues and Overview (2012) Center for Biological Diversity: Assessing the Full Cost of the Federal Grazing Program.