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Editor’s Note: The Western Governor’s Association sent this letter to Bureau of Land Management (BLM) Director Neil Kornze on Jan. 27 regarding the BLM’s administration of the Wild Horse and Burro Program.

Director Kornze:

We are writing to request additional information and clarification regarding the U.S. Bureau of Land Management’s (BLM) administration of the National Wild Horse and Burro Program. As stated in Western Governors’ Association (WGA) Policy Resolution 2015-01, Wild Horse and Burro Management, Western Governors believe that burgeoning wild horse and burro populations along with the inability of federal agencies to adequately manage these populations presents an urgent concern for western rangelands and ecosystems.

Western Governors firmly believe that:

Wild horse and burro populations should be managed within established Appropriate Management Levels (AMLs);

AMLs should be developed, monitored and adjusted using a transparent and science-based process that uses the best available population estimates;

Collaboration should be increased between state agencies, federal agencies and private stakeholders regarding population data and monitoring, public education and adoption programs; and

New and innovative management options should be utilized, including fertility control methods and alternative food sources at short-term animal holding facilities.

Attached please find Western Governors’ substantive questions regarding these issues. A similar list was provided to BLM staff in advance of the WGA’s Winter Meeting, held in Las Vegas on Dec. 4-5, 2015.

We are committed to responsible wild horse and burro management on western rangelands and look forward to working more closely with BLM towards that end. We hope that the BLM’s detailed and substantive answers to these questions are a first step toward that goal.

Sincerely,

Matthew H. Mead

Governor of Wyoming

Chairman, WGA

Steve Bullock

Governor of Montana

Vice Chair, WGA

Editor’s Note: This attachment was provided in the letter to BLM Director Neil Kornze.

While the list below is not intended to represent the entirety of western states’ concerns or input, unresolved questions relating to the BLM’s Wild Horse and Burro Programs include:

The total AML for all western states is set at 26,648 animals. As of March 1, 2015, there were an estimated 58,150 animals on western rangeland – more than double the BLM-determined level. Relative to AML:

What are BLM’s plans to reduce herd sizes to prescribed AMLs?

Given existing and expected budgets, what is the timeframe to implement plans that reduce herd sizes to prescribed AMLs?

How can states be more involved in annual gather planning discussions?

Wild horse and burro populations above prescribed AMLs can cause negative environmental and rangeland impacts. How can these impacts be better acknowledged, measured and incorporated into management decisions?

What are the impediments to BLMs plans to reduce herds to prescribed AMLs and implement fertility control treatments?

What other resources does BLM need?

Does BLM have necessary authority to direct funding based on a prioritization of needs?

The total capacity of all BLM off-range holding facilities is 54,549 animals. As of November 2015, these facilities held 47,303 animals. Given the rapid growth of wild horse and burro populations, is BLM considering adding temporary off-range pastures and corrals?

Wild horse and burro herds can impact the management and conservation planning of other species, such as the Greater sage grouse. How will BLM work with states to expedite the development of herd management area plans for wild horses and burros occupying sagebrush habitat?

What is the status of BLM’s efforts with the U.S. Geological Survey’s Fort Collins Science Center to develop methods to achieve greater accuracy in wild horse population estimates?

The BLM has proposed a knowledge and values study regarding the management of wild horses and burros. What is the status of that study?

What does BLM do to actively manage wild horse and burro populations, excluding roundups of excess populations pursuant to lawsuits or experimental fertility control efforts in some areas?

Does the BLM consider or implement sterilization for populations where fertility control has proven ineffective?

In the past two appropriations cycles, congressional report language has encouraged BLM to implement the recommendations of the National Academy of Sciences (NAS) 2013 study, Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward. The NAS recommends the implementation of fertility control programs to limit the uncontrolled growth of wild horse and burro populations. What is the status of these fertility control programs, and what steps has the agency taken to implement the NAS recommendations? How can states assist in the development and expansion of such programs?

Relative to BLM’s adoption program:

What is BLM doing to expand adoption efforts?

Is BLM exploring alternatives to adoption to reduce numbers of wild horses in off-range facilities? If so, what are those alternatives?

Horses placed in an adoption program were recently sold for slaughter. How can BLM and states work to ensure adopted horses are not sent to slaughter?

Many states perform their own wild horse and burro monitoring. How can the data exchange between state and federal agencies be improved?

To the Editor:

The federal government controls nearly 50 percent of Wyoming’s land and 50 percent of the land in the West. Since the West was divided into states, one problem after another has surfaced because of this fact. The latest and sad case was the death of Lavoy Finnicum, a rancher who protested the cruel and unfair punishment of his fellow ranchers in Oregon. Story after story has been archived through the years of the BLM, Forest Service, EPA, U.S. Fish and Wildlife and National Park Service unjustly managing the public lands. 

However, if their intent ever was to allow multiple land use, all pretenses have been dropped in recent years with an outright attack on grazing, mining, logging and other economic uses. Make no mistake about it, the environmentalists want the public lands to be off limits to livestock producers, miners and loggers. They are now unabashed in their assault on the use of public lands, which leaves no recourse for westerners other than all out war. I am not speaking of a violent uprising but a well coordinated constitutional states’ rights fight.  

I grew up in the shadows of the mighty Tetons in Teton Valley, Idaho just six miles from the Wyoming line, a fifth generation Rammell who has witnessed first hand this assault on the West by environmentalists. In 2008, I had had enough and decided to do something about it. I entered the political arena by running for the U.S. Senate. Unsuccessful, but undeterred, I moved forward with a run for Governor of Idaho in 2010. In both races my campaign was “It’s Time to Take Back Our Land.” My message was well received as evidenced by over 42,000 votes in the Republican primary. However, the majority of the people were not prepared to take on the federal government at the level I was advocating. 

Discouraged and broke after waging an intense campaign to break up the monopoly of power in Idaho, my wife and I moved to the Cowboy State in search of a better future. Thanks to Lex and Shawn Madden and Michael Schmidt, I was given a job as the chief veterinarian at Torrington Livestock Markets. After preg checking 30,000 head in 18 months and suffering from a bad shoulder, I moved back to Jackson to see if my dislike for environmentalists had dissipated. Unfortunately, it had not, so I moved to Gillette to work for Animal Medical Center of Wyoming. 

Keeping my head in the sand, I tried to ignore the escalation of the “War on the West.” Gillette, however, proved to be the wrong city to do that in. Upon Congresswoman Lummis’ retirement announcement, I felt compelled to get back in the fight. So here I am again, like a moth drawn to the flame, ready to walk the coals in this seemingly ageless battle. Except this time, I hope the cowboys, the miners and the loggers of Wyoming will have my back. What I started in Idaho eight years ago I intend to finish in “wonderful” Wyoming with your help. 

For more information and to join the cause please go to voteRammell.com.

Sincerely,

U.S. Congressional Candidate Rex Rammell, DVM, MS

Gillette

To The Editor:

  I noticed a mistake in the predator kill story in the Jan. 30 edition of the Roundup. Mike Boyce of the Wyoming Game and Fish Department (WGFD) was quoted as saying that WGFD pays “seven-to-one for wolf kills.” I would like everyone to understand that wolf compensation only occurs within the former “trophy” zone. If the predation occurs in the former “predator” zone there is no compensation. 

When Judge Jackson put wolves back under federal control in September 2014, the state of Wyoming no longer had any authority over wolves. However, since the state had legislation in place regarding wolf management and compensation, they decided to continue their compensation program just as if they still had management control. So, as the situation now stands, the state of Wyoming is compensating some livestock producers and not others based upon some arbitrary “zones” that are currently useless, since a producer in the predator zone has no more ability to deal with the problem than the producer in the trophy area. 

I don’t know if Mr. Boyce was misquoted for the article or if he doesn’t understand the program.  I don’t understand how the State can run their compensation program in this manner when the wolves are under federal control.     

 Sincerely,

 Kelly Graham

Meeteetse

Note from the Editor: We appreciate Mr. Graham for pointing out this oversight in the article. Thank you for clarifying this important distinction. No compensation is provided for wolf losses in the former “predator” zone.

To the Editor:

Wyoming agricultural producers welcome genetically engineered (GE) crops.  We all enjoy the economic and environmental benefits of GE crops.  We grow GE alfalfa, sugarbeets and corn.  Soon, more Wyoming crops will be GE.

In the upcoming session of the Wyoming Legislature, a resolution, HJ0001, “Labeling for genetically engineered items,” is sponsored by the Joint Agriculture, State and Public Lands and Water Resources Interim Committee.

This is a resolution “requesting Congress to enact legislation reaffirming the United States Food and Drug Administration as the primary authority in uniform food labeling related to genetic engineering.”

You can find HJ0001 at the Wyoming Legislature Service Office website, wyoleg.gov.

Should food from GE crops be labeled as such?  I say no. The truth is that all crops are genetically modified in many ways and often using technology much less precise than GE.

HJ0001 is simply a resolution.  It has no power of law.  Yes, HJ0001 is well-intentioned.  But it must not be passed because it will make Wyoming look ignorant, stupid, or both. The anti-GMO crowd will jump all over the HJ0001 errors, inconsistencies and bad grammar.

HJ0001 states that it has to do with “labeling for genetically engineered items.”  But really, HJ0001 is about “food” or “crops” or “plants,” not “items.”  HJ0001 should have nothing to do with GE pharmaceuticals or industrial products.

HJ0001 is “requesting Congress to enact legislation reaffirming the U.S. Food and Drug Administration as the primary authority in uniform food labeling related to genetic engineering.”

But there is nothing to “reaffirm.”  The Food and Drug Administration (FDA) has nothing to do with GE labeling and never did.

The rationale for a resolution is built into its “Whereas” statements.  Let us consider the 11 “Whereas” statements in order.

Whereas 1: This refers to a “biogenetic organism.” This is a term that no agriculturist or biologist would ever use in this context.

Whereas 2: This Whereas does not go far enough.  It does not say that that GE plants are probably “safer than safe.” GE is so much more precise than classical plant breeding.

Whereas 3: The phrase “genetically engineered technology” is grammatically incorrect. The “technology” is not “genetically engineered.” Plants are. Otherwise, this is a fine Whereas.

Whereas 4: We’ve been growing GE crops for 20, not 25, years.  The first GE crops were grown in 1996.  It was a bit later that GE crops first appeared in Wyoming.  Since 1996, nearly 5 billion acre-years of GE crops have been grown world-wide, with excellent results, and excellent results in Wyoming.

Whereas 5: Okay. So much of our food comes from GE plants directly consumed by human beings or indirectly via livestock that consume GE feed.

Whereas 6: Excellent!  This is the core of HJ0001.  A “patchwork of state and local mandatory labeling laws” would be a disaster for both American producers and consumers.

Whereas 7: Regarding a “national solution,” it already exists in the U.S. Constitution. The “Commerce Clause” is found in Article I. The “Supremacy Clause” is found in Article VI. So many agriculture advocates, like me, observe that the several state and local mandatory labeling laws that were recently enacted, but not yet enforced, will be voided as unconstitutional.  Also, note that beyond a “national solution,” we need an “international solution.” It’s no secret that some other nations are using “anti-GMO” laws to impede American exports of food, feed, and seed.

Whereas 8: Here the proposed resolution would “affirm the Food and Drug Administration as the nation’s authority for the use and labeling of genetically modified foods.”

Nonsense! The Wyoming Legislature must not resolve to “affirm” an “authority” that FDA does not have and has never had.  Once FDA has determined safety of a GE plant or any genetically improved plant FDA requires no labeling. Yes, FDA has authority for oversight of labeling of ingredient composition and nutritional content of processed foods. But, no, FDA has no authority regarding labeling of GE content of foods and never did.

It is important to acknowledge that not only FDA has responsibility for determining safety of GE plants in America.  USDA-APHIS and EPA are involved too.

World-wide, we have grown nearly 5 billion acres with overwhelmingly positive results.  GE crops save our soil and reduce our carbon footprint.  Yes, GE biotechnology must be deployed judiciously to avoid evolution of weed, pest and pathogen resistance. We can do that.

Whereas 9: Here HJ0001 proposes that a national solution will require the FDA “to conduct a safety review of all new genetically engineered ingredients before they are introduced into commerce.” But FDA already does this.  And no labeling of safe ingredients is required. Here HJ0001 invites federal overregulation. Why do that?

Whereas 10: Pointless.  Companies are already free to voluntarily label their products as GE or non-GE.

Whereas 11: Bad. Surely, the Wyoming Legislature does not want the FDA to define the word “natural,” do they?

The missing whereas: It is unfair that food labeling laws would disadvantage GE foods and food ingredients when many classical plant breeding and plant biotechnologies are more likely to result in unexpected and undesirable outcomes in terms of human health, economy, and environment.

In the early days of GE, 20 years ago, it was we in the plant genetics, breeding and biotechnology community that insisted on intense scrutiny of newly emergent technologies for crop improvement.  Job done.

Now we know. GE biotechnology is safe. Safer than some traditional technologies for plant genetic improvement. Safer than some other emergent biotechnologies.

Years ago, in 2004, a thorough evaluation of plant genetic improvement by the National Academy of Sciences concluded that GE plant biotechnology is safe.  And safer than many traditional technologies and emergent biotechnologies.Now, 10 years later, as GE biotechnology has become more precise, we must conclude that plant GE technology is “safer than safe.”

Today, GE is heavily overregulated at the federal level. An invitation from Wyoming for even heavier federal regulation makes no sense.

OK. Now let us move on to the four sections that would “Now, therefore, be it resolved by members of the Legislature of the State of Wyoming:

Section 1: “That the Congress of the United States enact bipartisan legislation that reaffirms the Food and Drug Administration as the primary authority in uniform food labeling related to genetic engineering, based on scientific standards regarding health, safety and nutrition.”

But, as I have emphasized, FDA has no authority regarding GE labeling.  Why would Wyoming invite FDA overreach?

Section 2: “That existing Food and Drug Administration labeling rules and guidance, as well as the U.S. Department of Agriculture’s National Organic Program, provide sufficient standards to address consumer interest in food production practices through the use of truthful and non-misleading voluntary labeling.”

Regarding processed food ingredients and nutrition, FDA has great responsibilities.  But the FDA has no authority to label food regarding genetic modification, whether GE or non-GE, or whether by the vast diversity of classical plant breeding or ultra-modern biotechnologies. Also, FDA has no authority to label food regarding “food production practices.” Moreover, the USDA’s Organic Program is antiquated.

Section 3: “That the Commissioner of the Food and Drug Administration adopt policies, regulations and rules setting standards to address consumer interest in food production practices through voluntary labeling.”

My question: Is labeling “voluntary” when it must meet FDA “policies, regulations and rules?”

Section 4:  This last section of the HJ0001 would transmit the joint resolution to the President, the Senate and the House of Representatives of the United States.

Again, I ask, why would Wyoming invite federal overregulation of proven genetic technology for improvement of our state’s crops?

Sincerely,

Robin W. Groose, PhD

Retired Professor of Genetics, Agroecology and Plant Breeding

Laramie