The Bureau of Land Management (BLM) Wild Horse and Burro Advisory Meeting
By Suzanne Roy, AWHPC Director
The first meeting of the BLM Wild Horse and Burro (WHB) Advisory Board was held in Columbus, Ohio on April 22-23, 2015.
The big takeaway from the meeting is that the BLM is still headed in a very dangerous direction by pursuing the use of surgical sterilization of wild free roaming horses on the range. The agency is allocating more funding for further research into gelding and spaying in the wild than to implementing the use of currently available, noninvasive, and reversible birth control methods -- even though it continues to receive hundreds of thousands of public comments calling for humane, on-the-range management using the proven birth control vaccine, PZP.
In 2014, the BLM vaccinated just 387 mares (out of an estimated population of over 40,000 wild horses) with PZP birth control and intends to inoculate fewer than 700 in 2015, down significantly from 2,000 a year promised in 2011 (a number that is still too low for population control). So, instead of allocating funds to implement the the effective tool it has at hand, the BLM is kicking the can down the road and spending $9 million for research on new solutions – most of them surgical sterilization techniques – that are highly objectionable and years away from implementation.
At the same time, the agency has reduced removals from the range, while remaining intransigent on adapting the artificially low Authorized Management Levels (AMLs) to the new realities, including NAS findings that low AMLs actually contribute to high population growth rates (by keeping the population well below the level that would allow for density dependent self-regulation) and the lack of space to house captured mustangs (holding facilities are nearing capacity with more than 48,000 wild horses warehoused). Of note at the meeting was the BLM’s acknowledgement that current AMLs are based on the numbers of wild horses that existed in 1971 when the Wild Free Roaming Horses and Burros Act was passed – a time when Congress determined the horses were “fast disappearing” from the American West (and numbers that are quite outdated in 2015 -- 44 years after a statute was enacted to protecst these animals)!
The upshot is that the BLM continues to ignore public opinion and move inexorably toward drastic and dangerous policies for wild horses and burros by creating a crisis both on and off the range. This crisis is of the agency’s own making – as its stubborn refusal to implement the humane management of wild horses with birth control clearly indicates. As always one is left with the impression that the endgame of this self-induced crisis is to create a situation in which the sale of federally protected wild horses for slaughter (“sale without restriction”) becomes a viable solution. It’s clear that the “Double S Strategy” of sterilization and slaughter is the preference of ranchers, who view wild horses as competition for cheap, taxpayer subsidized livestock grazing on our public lands, and the BLM is trying hard to deliver results for this constituency that it caters to above all others.
Also interesting is the fact that this agency, which consistently declares a commitment to public accountability and transparency in its operations, continues to withhold from public release two critically-important reports detailing the results of the Office of Inspector General investigation into BLM’s sale of more than 1,700 wild horses to known kill buyer Tom Davis and its internal investigation into the deaths of at least 75 wild horses at a Kansas feedlot. The agency has “no idea” when either report will be released to the public, although both apparently have been completed.
Please read on for an overview of the April 2015 Advisory Board meeting.
WILD HORSE AND BURRO PROGRAM AT A GLANCE
- 2,158 wild horses and burros removed from the range in 2014.
- 2,118 wild horses and burros adopted in 2014
- 387 mares treated with the PZP birth control vaccine
- 17,085 wild horses in short term holding pens
- 31,250 wild horses in long term holding facilities
- 40,815 wild horses on the range (BLM estimate)
- 8,394 burros on the range (BLM estimate)
- $77.2 million annual program budget
- Fraction of 1% of budget expended on humane on-the-range management, while over $1 million was spent to round up and remove horses from the range in 2014.
The board includes two new members : Julie Weikel, DVM, a livestock veterinarian who has been advocating for the spaying of wild mares as a member of the Southeastern Oregon Resource Advisory Commission (RAC), and Jen Sall, program manager for the National Outdoor Leadership School. Ms. Sall replaces Callie Hendrickson, the pro horse slaughter cattlewoman, as the Public Interest representative on the board, while Dr. Weikel replaces Dr. Boyd Spratling, another livestock vet and past president of the Nevada Cattlemen’s Association, to fill the Board’s veterinary medicine slot. In addition, June Sewing, Executive Director of the National Mustang Association was reappointed to represent Wild Horse and Burro Advocacy on the Board.
Ranching interests continue to dominate this board, with four members (Dr. Weikel, Robert Cope (livestock vet), Rick Danvir (works for a Utah cattle ranch) and John Falen (public lands rancher) directly tied to the livestock industry. Full board roster is available here.
The new Board Chair is Fred Woehl, an Arkansas horse trainer and BLM volunteer, who displayed a troubling lack of knowledge about the BLM program and the issue during the meeting. Mr. Woehl often answered questions intended for the BLM, providing factually inaccurate responses based on demonstrably wrong information.
PROGRAM UPDATE – Mary D’Aversa
- Mike Tupper is the new Deputy Assistant Director of BLM division of Renewable Resources and Planning who now oversees the Wild Horse and Burro Program.
- Wild Horse and Burro Division Chief Joan Guilfoyle is out after a failed nearly four-year term.
- Mary D’Aversa, a 20-year BLM employee and former manager of the BLM Schell field office in Ely Nevada, is serving as acting division chief for four months.
- Holle Hooks, head of the new “off-range branch,” overseeing holding facilities.
- Bryan Fuell, former Schell, NV field manager, is head of the new “on-range branch.”
Rearranging the Deck Chairs:
In addition to reorganizing the division, the BLM has adopted new language to describe key program elements.
- Adoption is now “placement into private care.”
- Short-term holding facilities are now called “off range corrals” (ORC’s)
- Long-term holding facilities are now called “off range pastures” (ORP’s).
- Fertility control is now “Population Growth Suppression” (PGS) to encompass surgical sterilization methods.
Roundups remain “gathers” in euphemistic BLM speak.
- Research on more effective Population Growth Suppression (PGS) techniques. BLM will spend $9 million to fund 8 studies:
- 7 of the 8 studies are on mares
- 4 of the mare studies are on surgical sterilization and 3 are pharmaceutical
BLM deputy division chief Dean Bolstad is working on funding these research projects, which have not yet been announced publicly.
- Moving more animals into private care. Launched America’s Mustang, video and campaign in conjunction with Mustang Heritage Foundation to promote adoptions.
- Securing high quality low cost pasture space – seeking proposals for new long term holding facilities and ecosanctuaries.
- Finalizing and incorporating Comprehensive Animal Welfare Standards
- Implementing new census standards. (77 of 179 Herd Management Areas (HMAs) surveyed in 2014 using updated census methodology).
Programmatic Environmental Impact Statement (EIS) is being considered to evaluate “new and traditional Population Growth Suppression (PGS) techniques.” The goal is to propose amendments to Resource Management Plans to allow BLM to use new PGS tools.
Prize Challenge: BLM is seeking “creative and innovative ideas” for delivery of PGS tools to mares on the range. Interestingly, BLM has spent money to hire consultants and organize a meeting on this topic, but it is has yet to secure private funding to underwrite the “prize” for this challenge.
Public Perceptions Research: BLM initiating focus groups to determine what values people place on public lands management and wild horses. Currently open for a 60-day comment period, will then need Office of Management and Budget approval.
Expanding “private care and holding space” - expanding prison programs for adoption, soliciting new long-term pasture space, “ecosanctuaries” (3 current that house 600 horses each). Every 100 horses moved from short-term to long-term holding saves $1 million according to D’Aversa.
Use of Fertility Control – Ms. D’Aversa revealed that BLM had only vaccinated 387 mares with PZP fertility control in 2014 and planned to vaccinate fewer than 700 in 2015. She also misstated the results of the National Academy of Sciences (NAS) review of the wild horse program, asserting that the NAS concluded that BLM had no adequate tools to manage wild horses on the range, when, in fact, the scientific panel stated specifically in its 2013 report that ”Tools already exist for BLM to address many challenges.” The primary tool available now, as recommended by the NAS, is the PZP fertility control vaccine. Ms D'Aversa also misstated that PZP vaccine is only useful in small Herd Management Areas (HMAs) with accessible horses, when, in fact, the BLM is actually using the vaccine in large HMAs with difficult-to-access herds in Wyoming and Nevada.
The new Veterinary Medicine representative, Dr. Weikel, used the fertility control discussion to promote spaying mares. First she recounted anecdotal reports that BLM field personnel in Oregon "were not pleased" with the effectiveness of PZP because there was “rebound growth” after the fist inoculation. (The mares allegedly reproduced at a higher rate than normal the year after the vaccine was delivered.) These anecdotal reports, however, are not supported by 25 years of published scientific research on PZP use in wild horses.
Dr. Weikel revealed that she was a consultant to the Sheldon National Wildlife Refuge between 2008 -2013 when 110 mares were spayed at all stages of pregnancy (most mid-pregnancy) and 250 studs were vasectomized, half chemically/half surgically. (Dr. Weikel was a consultant to the refuge, but did not perform the surgeries.) Citing as yet unpublished reports, she claimed that this approach decreased foaling rate from 26% to 8%. She also noted that the vasectomized studs were later captured, removed and gelded and their testicles were examined, revealing that chemical vasectomies failed in 100% of the cases. As stated above, Dr. Weikel has been advocating for the spaying of wild free roaming mares for several years.
BUDGET UPDATE - Renee Fuhrman, Acting Budget Analyst
Slides available here.
In Fiscal Year (FY) 2014, the BLM’s total budget was $77.2 million. The agency spent six times more on rounding up and removing horses from the range than it did on birth control to humanely lower population growth rates. In fact, the BLM’s expenditures on birth control didn’t even register as a fraction of one percent of the budget, while holding costs continue to consume 64% of the budget.
Continuing the trend of misplaced budget priorities, so far in 2015, the BLM has spent 0% of its budget on fertility control and nearly $1 million to roundup and remove wild horses from the range.
FOREST SERVICE UPDATE: Barry Imler, Rangeland Program Manager
Program Overview & Updates:
The Forest Service (FS) does not have a separate wild horse program. “Our view is that we should be managing the animals and the habitat as part of the ecosystems in which they reside. That’s why we don’t have a separate program.”
The FS is changing its approach to wild horses and will no longer be requesting BLM to remove wild horses from its Wild Horse Territories and due to the holding situation, will no longer be sending wild horses removed from the range to BLM holding facilities.
The FS is not prohibited from selling excess wild horses without limitation and is currently evaluating how to define “excess.” The FS hopes not to trigger unlimited sale authority; envisions working with local groups to place horses before selling without limitation.
20% of FS Wild Horse Territories are at some stage of NEPA Analysis. Claim that some areas are 1,000 horses over the allowable levels.
The FS is not planning any removals for 2015.
The FS is doing some adoptions and using PZP in some areas (NM, OR).
OFF RANGE UPDATE – Holle Hooks
Slides available here.
Looking to acquire additional long-term holding and ecosanctuary space and to expand prison training programs.
Still in process of incorporating Comprehensive Animal Welfare Standards for holding facilities and transport
Doing a shade research study in conjunction with UC Davis to determine whether horses prefer shade in hot sunny weather. Currently analyzing over 600 hours of data collected with remote cameras and dosimeters on collared horses to determine whether horses like shade.
Not yet making public its report on the death of 75+ wild horses who were moved from a long term holding pasture to a feedlot in Kansas.
Suzanne Roy, Ginger Kathrens, and Libby Nowicki. Photo on right - Judith Fader
Approximately 25 citizens and organizations addressed the Advisory Board during the public comment period. Speaking up for more humane, in-the-wild management of wild horses were AWHPC and our coalition partners and colleagues, including Ginger Kathrens and Lisa Friday of The Cloud Foundation, Gillian Lyons and Heidi Hopkins of the Humane Society of the United States and Jim Schnepel of the Wild Horses of America Foundation.
Several citizens travelled hundreds of miles to attend the meeting and speak up for wild horses, including Judith Fader, a retired professional writer who traveled from Boston to advocate for humane and cost-effective reform of this government program. Libby Nowicki, a 19-year old musician who traveled 4.5 hours to the meeting with her mom from their hometown in Michigan, summed up public sentiment when she eloquently stated:
“I stand with a large majority of Americans who value the wild horse as an irreplaceable part of our culture, and call attention to the dire situation in which they’re placed, falling victim to habitat decrease due to livestock priority, and torturous, unsustainable, and all too-often lethal conditions within helicopter roundups and holding facilities. … I strongly encourage you to keep wild horses wild and treat them as the public values them.”
Read Libby’s full statement here.
AWHPC presented the names of over 14,000 citizens who sent emails to the Advisory Board urging humane management and opposing permanent sterilization of horses on the range, and used the opportunity to address some of the misinformation about PZP and spaying mares that had been presented earlier in the meeting.
ON RANGE UPDATE – Bryan Fuell, On-Range Branch Chief
Slides available here.
- 179 HMAs
- 26,684 AML
- 49,209 horses on the range (2014 estimates)
- 20% average growth.
- 25,525 over AML.
- 2015 population estimates will be available “next week.” The delay is due to one state that “has been reluctant to provide numbers” because they face litigation and have been “working to get those numbers down.”
Helicopter Roundups 2015 (completed):
- Conducted in 12 HMAs
- 1,827 horses removed
- 179 horses treated with PZP
Helicopter Roundups 2015 (planned - begininng in July)
- 3 HMAs targeted
- 277 horses to be removed.
- 0 horses vaccinated with PZP.
Water Bait Trapping 2015 (completed):
- 87 horses removed
- 0 PZP applied.
Water Bait Trapping 2015 (planned):
- 269 horses to be removed in the summer
- 10 to be treated with PZP
PZP Treatment via Darting (no gather/removal)
- 402 proposed
PROGRAMMATIC Environmental Impact Statement (EIS):
Fuell described this initiative as an “umbrella over the program that would give the field a selection of tools they could use to manage horses.”
This is awaiting full BLM approval. If approved, they will solicit and select a contractor to prepare the EIS in 2015, hold scoping meetings (visit at least 10 or more cities in the West and maybe the East). Then they will prepare a Draft EIS that would be released in the Spring of 2017.
EIS would evaluate:
- A wide array of population growth suppression techniques (spay/neuter and contraception)
- Establishing nationwide AMLs
- Management of wild horses and burros as meta populations
- Amending RMPs to eliminate or modify decisions that are barriers to adapting proposed strategy.
Anticipated management concerns
- WHB heath, welfare, reproductive, physiological, genetic diversity, population dynamics.
- Threatened and endangered sensitive and other special status species conservation and recovery
- Impacts to other wildlife populations and habitat
- Coordination with sage grouse conservation efforts
- Prevalence and expansion of non-native species
- Riparian/wetland impacts
- Soil conservation
- Watershed health/landscape restoration
- Socio economic factors
RESEARCH UPDATE – Dr. Kate Schoenecker, Ecologist, US Geological Survey (USGS) and Colorado State University
Slides available here.
BLM and USGS partnering to implement new census methods based on two techniques:
1. Simultaneous double counts
2. Photo mark resight method
USGS lead – Paul Griffin is planning flights, training observers preparing data for analysis by statistician, helping with recordkeeping and results.
USGS has prepared Standard Operating Procedures (SOPs) for aerial surveys that will be published sometime this year. Goal is to bring reliability and consistency to BLM population surveys by using the same flight pattern and the same methodology for each census.
BLM surveyed 67 HMAs with new methods in 2014 and plans to do 78 in 2015.
Ongoing Research – USGS conducting these projects for BLM
1. Population Estimation Using Fecal DNA
Evaluating methods to estimate population numbers through DNA analysis of fecal samples. This method could offer advantages over aerial counts – will be defensible and accurate, less expensive, less stressful, less disruptive, involves “citizen scientists.” Samples could also be used to determine genetic structure of the population without requiring a roundup.
They are also using fecal samples to determine whether wild horses spread non-native plant seeds. (Tim Harvey rightly asked whether they would also look at whether horses spread native plant seeds, which is not apparently the point of the study, although Shoenecker noted that they would be able to determine that as well from the samples.)
Research was conducted in a herd with known population size (Little Book Cliffs).
2. Radio marking collaring – pen trial
Telemetry collars used for over 30 years in other ungulates to show habitat selection, movement ecology, population estimation mark-resight, and locate treated animals, etc.
Objective of the studies is to measure, fit, and determine behavior of collared vs. uncollared horses in a pen trial at BLM Paul’s Valley holding facility in Oklahoma.
Key is to design a collar with an expandable neck for stallions. (Their necks expand when they put their heads down when they graze, etc.)
Testing 4 different collar designs as well as 3 radio tags that are braided into horses’ tails or manes and then secured with epoxy glue.
Testing on 12 mares, 12 stallions and 4 jennies (female burros)
Collecting individual behavior compared to control - bringing animals into chute 1 x per month and checking for developing sores, etc.
Study is one year in duration, to be followed by field testing.
3. Carrying Capacity Model
Status: USGS approved; awaiting BLM approval
Developing a model to evaluate changes in carrying capacity in response to changes in vegetation production. Based on Yellowstone ecosystem work by Woekner, et. al, 2014.
- Start with base vegetation production map. How much must remain on the range after consumption.
- Subtract livestock, bison and other wild ungulates
- Calculate amount of forage that remains on the range and how many mouths can you feed with that.
Can also add a climate change scenario. Goal is a simple model that everyone can understand.
4. SPAY VAC
Evaluating efficacy of SpayVac fertility control vaccine. 2015 is 4th foaling season for mares treated in 2011 and the first for mares treated in 2014.
Testing pregnancy rates via testing and palpitation.
Will make decisions on future monitoring based on palpitation results.
Proposals being developed by USGS at request of BLM
- Burro population estimation techniques
- Looking at 3-4 HMAs and 25-30 radio-collared burros per HMA.
- Sentinel demography of burro – ecology of burros.
- One in-depth study on one herd used in the burro population estimate study - survival, fertility, fecundity, recruitment, movement, etc.
- IUD studies in mares (pen) - Evaluate efficacy and unintended effects (chronic inflammation, infection) of O-ring IUDs.
- Location TBD.
- 30 mares in the study (15 treated/15 untreated) and 4-5 stallions.
- Look at 3 IUD breeding seasons and 1 post IUD breeding season.
- Start date April 2016.
- Domestic mares will be used because of handling requirements.
- Evaluating the behavior of spayed free-roaming mares
- Study will focus on behavior, social interactions, body condition, movements and treatment-related mortality of spayed mares.
- Collecting pre-treatment data now. Will do post treatment studies when they develop a procedure.
- Mares will be tracked with radio collars.
- Will also conduct modeling to determine how many mares will be spayed. (“If you do 60% of the mares what would the outcome be?”) Proposal still in development.
- Evaluating behavior and ecology of geldings among a breeding herd.
- Social behavior, movements, congregations, body condition, habitat selection of gelded males.
- Track individuals with radio collars (presently no radio collar for stallions)
- Proposal in development pending approval of proper radio collar.
- Sentinel demography of free-roaming horses
- Fertility, fecundity, recruitment, age-specific mortality and survival, habitat selection, home range and movement ecology.
- Win Equus II Population modeling – using the demographic and ecology data to re-do the model.
- Project cost/benefits and population growth for various management alternatives including PZP, removal, spaying, gelding, etc. If you treat this number of horses with fertility control and spay and/or neuter this number, what effect does it have on the population?
- Testing immunocontraception in burros.
- Pen trial followed by field study.
- Just discussing – no proposal yet.
- PZP has been given to burros – physiologically the same effect.
OTHER PRESENTATIONS OF NOTE
Wild Free Roaming Horse and Burro Act – Mary D’Aversa
This presentation outlined the Act, the amendments to the Act since 1971 and the BLM implementing regulations.
The discussion addressed the Act’s designation of ranges for use “principally but not exclusively" for wild horses. The BLM continues to interpret the definition of range as specific only to the four specially-designated wild horse and burro ranges, but Humane Advocate Harvey noted that there is nothing in the language of the law limiting the “principally but not exclusively” designation to those four ranges.
Kenneth Visser, BLM Rangeland Management Specialist clarified the term “multiple use” as defined in FLPMA: The land must be “managed for a variety of uses, not necessarily all uses in all areas, and not necessarily all uses that provide for the greatest economic output.”
D’Aversa noted that the Act is very specific in terms of horses being considered “natural components of the land.”
Rangeland Policy and Management - Kenneth Visser, BLM Rangeland Management Specialist
Slides Available here.
Mr. Visser discussed the history of public lands livestock grazing and the various laws relating to it, including the Taylor Grazing Act, for at least 45 minutes, but left the crucial issue of how the BLM establishes wild horse and burro Allowable Management Levels (AMLs) for the 10-15 minute question-and-answer period. Nevertheless, a number of interesting points arose from that Q & A discussion
- BLM does not evaluate carrying capacity of horses by HMA or complexes, but rather sets AML by livestock grazing allotments (further confirming the fact that the agency manages wild horses like livestock instead of a federally protected wildlife species.)
- AMLs are based on the number of horses that existed at the time the Wild Free Roaming Horses and Burros Act was passed. This is a time when there were so few horses that Congress determined they were “fast disappearing” from the American West. “That’s the reference point for managers,” BLM’s Fuell told the Board.
Humane Advocate Tim Harvey noted the gross inequity in forage allocations to wild horses vs. livestock in HMAs, with horses receiving just 2 – 20 % of available forage allocations depending on the HMA. He noted that BLM is “hanging its hat” on reaching AML, but all past National Academy of Sciences reviews found no scientific basis for these AMLs. He pressed BLM on what process is available for the public to weigh in on forage allocations, and D’Aversa, the new acting BLM chief, responded that the opportunity to have that dialogue is during the Resource Management Plan process.
Regarding forage distribution and the “principally for” argument, Mr. Harvey concluded, “The intent of the law is to manage the horses for the sake of the horses. It seems like the horses are on the short end of the stick an awful lot. I don’t think it’s intentional. There are a lot of pressures.”
WORKING GROUP REPORTS
The meeting ended with reports from the Advisory Board’s working groups. Of note:
The Public Comments working group reported a huge amount of public support for using PZP birth control as an alternative to removals. Only 3-4 comments against PZP were received vs. hundreds supporting its use. Dr. Sue McDonnell who fills the board’s Wild Horse and Burro Research slot, expressed concern about repeated inaccuracies, such as the claim that PZP is a pesticide, and how to get people the correct information. (It’s interesting to note that the BLM stated that PZP had been classified by the EPA as a “pesticide” because that was the closest designation EPA could find for it since there is no designation for “birth control” vaccines/immunocontraception methods in EPA regulations.)
Mr. Harvey also noted public concern about the deaths of horses at the Kansas feedlot and the BLM’s sale of horses to kill buyer Tom Davis. He pressed BLM to release the reports on these matters, noting, “A perception of an impropriety is just as real as an impropriety.” He urged the BLM to deal forthrightly with the public on these issues, “Get it done and get on with it. Let’s get it over with,” he urged. The BLM responded that it had no idea when these reports would be released.
The Population Growth Suppression working group chair, Dr. McDonnell, suggested that the BLM explore more modern behavior modification methods as an alternative to roundups or trapping for application of fertility control “Why aren’t we using these techniques that will result in the horses coming in positively?” she asked, noting that a well-designed protocol can minimize horses’ acclimation to humans and concerns about horses becoming tame.
The Herd Area Repopulation working group noted that BLM had accepted the concept of reintroducing non-reproducing herds to zeroed out Herd Areas but that there had been no forward movement on identifying appropriate HAs in several years. June Sewing noted that there might be several HAs in Utah that could be appropriate for a pilot HA reintroduction plan.
The meeting concluded with the board’s approval of these recommendations:
- BLM should consider having the Division Chief position an optional position in the west based on preference of selectee and program needs
- BLM should assess horses to predict adoption potential (perhaps by qualified horse trainers who may be volunteers) with the aim of moving horses expeditiously to long-term situations.
- Provide funding to allow board members to attend, assist in and obtain first hand knowledge of the various components of the WHB program.
- Continue to develop and implement programs like America’s Mustang, which provide factual education and info to the American public.
- BLM should increase dedicated funding for developing methods of population growth suppression and consider all methods of population control.
- Increase length of regular Advisory Board meetings to 3-days, the first of which will be dedicated to allow working groups an opportunity for face-to-face interaction.
- Encourage BLM to proceed with WHB programmatic EIS.
- BLM should encourage state, county and local governments and agencies to participate as cooperating agencies in all NEPA processes.
- Develop a training module/program to allow all qualified volunteers to be an asset to the BLM WHB. BLM should consider training for volunteers to assist in range monitoring, e.g. through site-specific photography – citizen science.
- BLM should work in conjunction with other federal agencies to establish collaborative groups regarding the management of specific HMAs.
- BLM to provide periodic updates to the Advisory Board prior to meetings on progress of USGS research.
- BLM should explore using more modern behavior and least-stress methods.
- Enticement and positive reinforcement methods of gathering
- Refinement and increased use of water and bait trapping methods. Encourage use of water and bait trapping where they can be effective.
- BLM should pilot reintroducing non-reproductive herd into zeroed out HA (UT?) or HMA. Explore partnership with National Mustang Association or other reputable, non-governmental wild horse advocacy/welfare group.
- Detailed report at next board meeting on HMA population levels, their effects on Greater Sage Grouse and the strategies BLM is using to address these effects.
- The Advisory Board should meet three times a year in April, August, December.