September 9, 2014

Stacy Davies
Beatys Butte Grazing Association
P.O. BOX 66
Adel, Oregon 97620
Dan Morse
Oregon Natural Desert Association
50 SW Bond Street, Suite 4
Bend, OR 97702
Email: dmorse@onda.org
Re: Compromise Proposed by Wild Horse Advocates
To the Beatys Butte Mediation Group:
On behalf of the American Wild Horse Preservation Campaign (AWHPC) and The Cloud
Foundation (TCF), we would like to thank you for inviting us to participate in the Beatys Butte
mediation sponsored by the Beatys Butte Grazing Association (BBGA) and the Oregon Natural
Desert Association (ONDA). We share your desire to work together to resolve differences and
find common ground in order to address issues of concern to all stakeholders in the
management of public lands. True mediation addresses all of the parties interests and involves
compromise by all participants.
At the last meeting, the group decided to pursue meeting with the Bureau of Land Management
(BLM) to secure roundups and captive holding; this apparently took place when the wild horse
advocates were separated from the main group. We were surprised to learn of these decisions
which had been made in our absence given that we were not permitted to participate in this
decision-making process. Our primary interests regarding the re-allocation of Animal Unit
Months (AUMs), fertility control, etc either have not been taken into account by the group or
were intentionally omitted from the groups decisions. As we outline below, we made numerous
compromises in our proposal yet there has been no identifiable compromise on the behalf of
the other parties with regards to our interests (re-allocation of AUMs, fertility control, etc).
Without compromise from all parties, we are unclear how this process moves forward with
regards to the wild horse issue.
At the August 2014 meeting, we detailed our concerns, which are shared by Americans across
the country, about the management of wild horses on public lands, including in the Beatys Butte
Herd Management Area (HMA).
As we outlined in our presentations, our concerns are focused on two specific areas:
(1) the current inequitable allocation of AUMs to livestock vs. wild horses on the Beatys Butte
Herd Management Area (HMA). (We noted that allocation differs from actual use.)

American Wild Horse Preservation Campaign, P.O. Box 1048, Hillsborough, NC 27278

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(2) the current inhumane, costly and failed approach to wild horse management which relies on
rounding up and removing wild horses from the public lands and stockpiling them in holding
facilities. As the National Academy of Sciences noted "Management practices are facilitating
high rates of population growth.Thus, population growth rate could be increased by removals
through compensatory population growth from decreased competition for forage. As a result, the
number of animals processed through holding facilities is probably increased by management."
We also detailed how our interests in participating in the mediation process would be met
through proposals that would result in:
(1) A fairer allocation of resources to wild horses within the Beaty's Butte HMA, and
(2) The use of proven PZP fertility control to humanely manage the Beaty's Butte wild horses on
the range.
We further explained in great detail how both goals could be achieved while addressing other
parties interests including ensuring healthy ecosystems, adequate forage for wildlife,
maintaining the ranching lifestyle and economic benefits to the local community, etc.
Background
During our presentations, we outlined that in the past 40 years, Oregon has zeroed out more
than 25 percent (25%) of all wild horse/burro habitat designed in the 1971 Wild Free-Roaming
Wild Horses and Burros Act from 3,608,660 acres (on BLM-managed lands) to 2,733,577
acres. An example of where wild horses are not permitted to live on Congressionally-designated
wild horse habitat is east of the Beatys Butte HMA in the South Catlaw and Pueblo Lone
Mountain Herd Areas where the BLM permits livestock grazing but prohibits wild horses. Yet,
even on the lands where the BLM does manage wild horses, the agency only allocates a small
fraction of Animal Unit Months (AUMs) of forage to horses compared to privately-owned
livestock. The Beatys Butte Herd Management Area (HMA) and allotment is a case in point.
The BBGA members clarified, at the August meeting, that there has never been a time when all
of the 25,000 AUMs permitted have been actually used. The BBGA members stated that a
maximum of 15,000 AUMs have ever been utilized in a one-year period. Nevertheless, with a
high Allowable Management Level (AML) for wild horses set at 3,000 AUMs or 250 year-round
horses this is only 20% of the 15,000 AUMs which are available to livestock.
Our presentations outlined that wild horses are a re-introduced native species, stressed the
importance of their social structures, and attempted to impart why Americans and people
around the world love wild horses and want to see them protected and humanely managed. We
provided details on the fertility control method that we support -- Porcine zona pellucid (PZP)
which has been used successfully for decades to humanely manage wild horse populations.
Our Proposal
Our proposal incorporated key interests that were noted as important to the other interested
parties: protecting the environment, ecological balance, providing for healthy fauna and flora
and wildlife and continuing the ranching lifestyle and economic benefits from public lands
ranching. We highlighted this at the meeting and would like to reiterate it now: ensuring

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healthy plant communities, healthy riparian areas/hydrology and soil stability and
protecting wildlife is important to us. With that in mind we made the following proposal:
1. Redistributing AUM allocations. This is one of our fundamental interests. As members of
the public and organizations representing hundreds of thousands of Americans, we have a
primary interest in our how public lands and wild horses are managed. We strongly believe that
wild horses should be given a fair share of the resources on our public lands. Fair is something
that goes both ways for example, if the wild horse AML and livestock grazing AUMs were
switched, would the ranchers think that is fair?
Current allocation of resources: 19,000 AUMs were identified during the meeting as currently
allocated by BLM in the Beatty's Butte HMA.
15,000 AUMs for livestock BBGA stated that this is the maximum actual use by
livestock in one year
1,000 AUMs for wildlife based on BLM statement
3,000 AUMs for wild horses based on wild horse high AML of 250 annual horses
Proposed allocation of resources:
8,800 AUMs for livestock
3,000 AUMs for wildlife
7,200 AUMs for wild horses (based on 500-600 AML)
This proposal for the allocation of resources would achieve the majority of the stated interests of
the participating parties it would increase three-fold the allocation of AUMs for wildlife which
should reduce grazing pressure on the ecosystem and maintain the livestock lifestyle and
economic benefit of public lands grazing. Given the reduced economic benefit for the BBGA, we
suggested exploring opportunities to compensate BBGA for the reduced livestock AUMs,
including voluntary retirement or potentially reassigning AUMs in a different allotment.
2. Addressing the immediate situation.
BBGA repeatedly stated the need to immediately address the situation on the range. It is most
unfortunate that the situation on the range has been so neglected that there is an immediate
situation. It must be noted that the BBGA grazed approximately 15,000 AUMs just last year.
Clearly the BBGA did not think there was an "immediate" situation last year when it released
thousands of cows to graze on the public lands.
However, to address the immediate situation on the range, we proposed a compromise and
agreed to an immediate helicopter roundup of wild horses with the application of fertility control
utilizing the Trap-Treat-Release (TTR) Standard Operating Procedure (SOP) we submitted to
the group on BaseCamp. This SOP (see attached) outlines humane standards for the use of a
helicopter. The TTR roundup should capture 90% of the horses in order to apply PZP fertility
control to as many mares as possible. While PZP does not negatively impact any fetuses it
would prevent mares from conceiving the following Spring/Summer.
As an additional part of our compromise, we proposed to removal of 250 horses aged one to
three years. We proposed that future administration of PZP should be conducted at bait/water
trapping (as proposed by BBGA) where additional young horses could be captured and
removed (number of horses to be removed to be determined). Our proposal outlined that BBGA
members could be compensated through the BLM program for the bait/water trapping of the

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horses this would help offset the non-use of AUMs while wild horses remained over the new
AML.
We agreed to continued incremental removals for the next few years to bring the population
down while simultaneously reducing population through natural attrition and fertility control with
the target AML of 500 to 600 horses. The goal of our proposal is to minimize and eventually
eliminate removals and to humanely manage the population using PZP.
3. Compromise.
We support having livestock and horses receive equitable use of our public lands. However, in
the spirit of compromise our proposal allocated more than half of the AUMs to livestock.
In addition, we do not support the removal of wild horses from the range as a management
strategy. The BLM has done this for decades it has been proven to be ineffective and the
National Academy of Sciences reported it actually increases reproductive rates. It does not work
for the horses or the American taxpayer. Yet, in order to attempt to appease the immediacy to
remove horses expressed by the other parties we included horse removals in our proposal.
Lastly, we do not support the use of helicopters for the roundup of wild horses. However, as is
necessary in negotiations, we were open to compromise on this and the other points if the other
goals we outlined were met.
4. BBGA economic impact.
Given that, under our proposal, it will take time to reduce the horse population to the new AML,
we proposed to address BBGAs reduced economic benefit resulting from reduced usage of
AUMs by working with the BLM to identify methods of compensating BBGA permittees for nonuse of any of the re-allocated AUMs.
Conclusion
The feedback we received on our proposal was minimal with only a few persons commenting,
including the BLM range person stating that our proposal was ridiculous.
Based on the feedback and direction of the group in pursuit of other proposals presented, which
fail to address our concerns, we conclude that the group is not interested in a true mediation
process in which all stakeholders are equal parties whose positions are meaningfully
considered. This lack of interest by the group to address the interest of wild horse advocates, as
we outlined above, has helped us to better determine the role we can and should play in the
ongoing meetings. We look forward to joining the meeting via conference call and hope the
group will consider the opportunity to work with us to mediate a solution that meets all parties
interests.
In summary, the group is preparing to discuss livestock grazing and it will undoubtedly
acknowledge that livestock impacts to the range are significant. Livestock grazing on public
lands is well-documented as a leading cause of destruction of riparian areas, reduced water
quality, increased soil erosion, reduced plant diversity, exotic plant invasions, reduced wildlife
habitat, the spread of diseases and the list goes on. Indeed, livestock grazing is called one of
the primary causes of native species endangerment in the American West including the muchdiscussed sage grouse.

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As you may know, the American public is very concerned about the management wild horses
and our public lands in general. Recent national polls document that 72 percent of Americans
want wild horses protected on our public lands, while only 29 percent want to ensure that public
lands are available for livestock grazing.
Due to widespread public concern, we request that the Beatys Butte mediation group consider
the compromises we outlined in our proposal. Should the group be interested in addressing the
proposal we stand ready to work together. We look forward to joining the September meeting
via conference call and hope to attend future meetings pending our schedules.
Thank you again,

Deniz Bolbol
American Wild Horse Preservation Campaign

Ginger Kathrens
The Cloud Foundation

P.O. Box 5656, Redwood City, CA 94063

Telephone: 650-248-4489
Email: deniz@wildhorsepreservation.org

107 South 7th St, Colorado Springs, CO 80905

Telephone: 719-633-3842
Email: ginger.kathrens@thecloudfoundation.org

cc: Jon Lange lange@sou.edu, Theresa Jensen tjensen@mediate.com