Budget allocated to Calculating AML (Appropriate Management Level) is wasted and should be re-allocated
The methodology used by the Wild Horse and Burro program does not use simple science nor does it account for current data in its execution. AML levels established for wild horses and burros on public lands does not properly use scientific method to determine management practices.
The current calculation misrepresents the true capacity of these lands for grazing, leading to overpopulation and detrimental consequences for both the horses and the ecosystems they inhabit.
Our concerns are as follows:
• Lack of transparency and scientific rigor: The BLM's methodology for determining AMLs remains largely opaque and lacks sufficient scientific backing. Key factors influencing grazing capacity, such as plant community composition, soil health, and water availability, are often inadequately addressed or oversimplified in the calculations. This lack of transparency and thoroughness raises serious concerns about the accuracy and objectivity of the resulting AMLs.
• Overestimated grazing capacity: The current system often overestimates the grazing capacity of public lands, failing to account for the cumulative impact of wild horses alongside other permitted uses like livestock grazing and recreational activities. This overestimation leads to unsustainable herd sizes and contributes to rangeland degradation, ecosystem imbalance, and threats to sensitive species.
• Negative consequences for horses and ecosystems: Overpopulated herds result in competition for scarce resources, leading to malnutrition, foal mortality, and increased susceptibility to disease among horses. Additionally, overgrazing can damage vegetation, deplete soil quality, and disrupt natural ecological processes, harming other wildlife and plant species.
We urge the House Budget Committee and Fiscal Accountability Committee to investigate these concerns and take steps to ensure that the DOI BLM Wild Horse Program operates with transparency, scientific integrity, and accountability. Specifically, we recommend:
• Conducting a comprehensive review of the current AML methodology. This review should be conducted by independent experts and address all aspects of the calculation, including data collection, modeling techniques, and the consideration of key ecological factors.
• Developing a more transparent and evidence-based approach to setting AMLs. This approach should prioritize scientific data, incorporate stakeholder input, and ensure long-term sustainability for both horses and ecosystems.
• Improving accountability for the BLM's management of wild horses and burros. This includes implementing rigorous monitoring protocols to track herd populations and rangeland health, as well as establishing clear performance metrics and consequences for mismanagement.
We believe that these actions are necessary to ensure the responsible and sustainable management of wild horses and burros on public lands. We appreciate your attention to this critical issue and urge you to take swift action to address the concerns we have raised.
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