Monthly Archives: January 2013

UPDATED: 01/21/13

“Conservation is getting nowhere because it is incompatible with our Abrahamic concept of land. We abuse land because we regard it as a commodity belonging to us. When we see land as a community to which we belong, we may begin to use it with love and respect.”  ― Aldo Leopold

Allowing and even supporting abuse of Wild Horses, within our Public Lands and by government employees is unacceptable.  Even more disgusting is the BLM use of tax payer money to support abuse of America’s Wild Horse Herds!  And their excuses are simply lies, and just not good enough to cover-up the abuse!

The BLM has been taken too court, several times regarding abuse of the Wild Horses!  In ALL cases the Judge had Federally Court Ordered BLM to STOP the Abuse — the BLM Ignores the Federal Court Orders and Ignores the Federal Judge’s Orders!

The BLM, not included within this discussion, also ignores the Court Ordered mandate of the 1st Amendment Right to “Press Access” and Freedom of Information Act on all roundups, which continues and always has been a Constitutional mandate by the Federal Court — BLM assumes they do not have to abide by the Constitution of the United States nor a Federal Court Order!

Not only is it unacceptable within moral attributes’, but within a civilized society as well.  So why then, does our government support such activities from the people who work within the Bureau of Land Management (BLM)?  Why does the official oversight agency, the Department of the Interior (DOI) support such activity, which is beyond a doubt and well definable as Animal Abuse?

When nothing is done to correct animal abuse, or the animal abuse is ignored, or worse, excused, then we can outright conclude it is supported by those excusing or ignoring the situation.

“It is horrible that those people at the Bureau of Land Management would use Hot Shots on horses, or allow contractors to use those things.  I’ve rounded up horses for over 45 years, and never had a need for using one, or helicopters for that matter, especially with horses.  In my opinion that is just some dam psychopath being mean and nasty to a horse.” – Carl Stevens, Lead Wrangler and Cowboy-Retired

We spend taxpayer dollars yearly, millions of dollars, for the Justice Department to defend BLM and DOI employees in regard to their mismanaged horse roundups.  Ironically, also in such matters as animal abuse within these same agencies.  So much so that space prohibits the references to all the previous Federal Court cases documented within the last two or three years.

Animal Abuse Psychology

The first step is identifying what animal abuse is and what provokes the situation.  The subject is too lucrative to delve into a complete discussion here, so only highlights will be mentioned.  Please refer to the references given below if further informative material is required for more discussion, or legal references for future Court Hearings when bringing BLM or DOI employees to task for their abuse of, in this discussion, wild horses.

“In 1985, Drs. Alan Felthous and Steven Kellert studied 152 men, 102 of them serving time in federal penitentiaries for Animal Abuse. . . among the aggressive criminals. . . identified nine major motivations for animal abuse:

1. To control the animal;

2. To retaliate against the animal;

3. To satisfy a prejudice against a specific species or breed;

4. To express aggression through an animal;

5. To enhance one’s own aggressiveness;

6. To shock people for amusement;

7. To retaliate against another person;

8. Displacement of hostility from a person to an animal;

9. Nonspecific sadism. ^2-5

Intentional Cruelty

It becomes quite obvious that animal abuse takes place at many BLM wild horse herd roundups.  The excuses simply lies, also obvious to those with knowledge not only about horses, but to the uninitiated as well.  Such things as horses breaking their necks while being loaded into a large horse carrier, or while in a temporary holding corral, or while being rounded up by a helicopter, and much more, remain numerous.  Abuse and neglect for the animals safety remains the obvious factors here, and the excuses by BLM always inaccurate and false.

There always exists the nasty hidden secret, or underpinning of numerous psychological animal abuse behavior attached to each BLM roundup incident.  And yes, some of the people taking part in the wild horse herd roundups do have criminal records of animal abuse in their past.

The reality is, and ignored by BLM or DOI management and supervisors, the overwhelming fact that intentional cruelty is often more shocking than neglect, and most refuse to admit this.  Not admitted as well, as money far more important to these people than this harsh reality, that many abuse cases are frequently an indicator of a serious human behavior problem.  Taxpayers should not be paying for this what so ever!

Intentional cruelty is when an individual purposely inflicts physical harm or injury on an animal.  This also includes neglect or ignoring the safety of the animals well being.  The ASPCA, Humane Society, and other organizations with cruelty investigation authority have arrested individuals who have deliberately maimed, tortured or even killed animals.  BLM employees and their contractors’ also need to be arrested at each incident, and disqualified from future government employment situations, to say the least!  Because these people work for the government does not make them exempt from these same laws or ethical conduct toward our nations animals what so ever!

Why No Arrests of BLM Employees?

This leads to the overall question within this discussion — Why have BLM employees or their contractors not been arrested for their behavior, their outright cruelty combined with neglect toward, in this case, wild horses during roundups?  Ironically, many of their actions photographed, logged, and filed within Federal Court, and yet no prosecution of any BLM or their contractors arrested for such behavior!

The use of Helicopters is a different discussion, and assuredly yet another abusive means of rounding up horses that should not take place; and yet is justified only by monetary situations rather than humane treatment of animals, morals, or ethical definitions.

The excuse — cost factors equating to time factors — incentives by BLM/DOI contracts which contain time restraints’, which equates to more pay for the contractor — which causes irresponsible conduct of BLM contractors’, or defined categorically as Provoked Abuse.  Not so ironic, this is in reality, yet another definable, categorical, and well explained form of abuse toward animals, horses in this case — and is ignored entirely.

A short list of Witnessed and in some cases photographed Intentional Cruelty by BLM and their contractors:

1. Helicopters used to hit/bump horses, harass horses, or bump horses off cliffs;

2. Helicopters used to scare, and to then stampede horses, and while continuously  frightened they stamped over exhausted and stumbling horses, pregnant mares and foals, most often killing them;

3. Helicopters used to stampede horses and cause expiration and even death to horses due to prolonged chases toward and into temporary holding corrals;

4. Use of Electronic Shock or Hot Shots when leading horses to temporary holding corrals, loading, or just striking them with Hot Shots out of cruelty, to show-off for the other employees (witnessed) or to demean the animal (witnessed);

5. Use of white plastic flags or bags on the tip-end of whips, to frighten already stressed-out and fatigued horses, which has led to many broken necks and broken legs while horses held captive in temporary corral situations; and much more . . .

One of the less acceptable facts — although many individuals are arrested for intentional cruelty, people who commit even the most heinous crimes against animals are often not prosecuted to the full extent of the law.  In states where animal cruelty is considered a misdemeanor, individuals who commit intentional cruelty crimes against animals can receive, at most, one year in jail and a $1,000 fine. Often, perpetrators receive no more than probation.

Government’s Irresponsible Conduct

The BLM and DOI have a vast history of being sued, and loosing those lawsuits, mostly for mismanaged programs, or in many cases blatant incompetence and disregard for Ecological Systems or Wildlife.  Thereby, a foundation does exist of abuse, make no doubt.

The problem with animal abuse is the fact that it is allowed at all.  People often turn their heads and claim lack of knowledge.  Or worse, allow the animal abuse to take place, then attempt to make excuses.  Often it is ignored, in total, that the psychological attributes of the animal abuse is often Psychopathic in nature.  And yet, the animal abuse happens most often in front of others, and the “others” do nothing!

The very existence of Hot Shots (cattle prods) in a contractors truck or at a roundup remains extremely questionable and unacceptable in conduct, to say the least.  Shocking the wild horse’s while in corrals is a good example of not only irresponsible conduct, but others apparently looking the other way.  Shocking a small foal to get it loaded into a horse trailer is reprehensible and psychopathic!  The situation photographed, and the following question comes to everyone’s mind — Why are the individuals shown using a Hot Shot (the foal and other horses) not arrested?  Why are they still working as private contractors with the BLM?

Examples with the BLM and DOI abound, no doubt plentiful.  In another context, and shown to be factual and with BLM staff knowledgeable of these facts — When, for example, a Welfare Rancher complains about wild horses on Public Lands they lease from the BLM, they hire one of a few people available to go and shoot the wild horses roaming freely on that same Public Land.  The question here is who would be the worse offender, the Welfare Rancher hiring the assassination of wild horses, or the shooter — Well, in definable or legal terms, BOTH!

And what of the BLM employees who have knowledge of these events.  Certainly in one Nevada town it is an outstanding joke, that the BLM Police know exactly who the shooter’s are, as they drink with them at one of the local bars.

A case could also be made for each of them, mental instability and psychopathic behavior — witnesses have attested to the fact one horse-shooter actually has a wild horse (BLM cold branded) mounted and stuffed on display in his living room and as a trophy, just as a hunter would do with an Elk head or other wild animal.

CONCLUSION

It is quite obvious there exists a necessity to arrest and prosecute government, specifically BLM and DOI animal abusers, especially when working with the BLM, DOI, or any other government agency!  They are not exempt what so ever from America’s Laws!

The fact is Accountability and Responsibility, not only for the Wild Horses but with tax payer money as well, should no longer be ignored.  It is reasonable to equate the ignoring of such extreme circumstances to become very real, as long as we as American’s and taxpayers allow such agencies as the BLM or DOI to be the most litigated government agencies in America’s history!

“The last word in ignorance is the man who says of an animal or plant, “What good is it?” If the land mechanism as a whole is good, then every part is good, whether we understand it or not. If the biota, in the course of aeons, has built something we like but do not understand, then who but a fool would discard seemingly useless parts? To keep every cog and wheel is the first precaution of intelligent tinkering.”
― Aldo Leopold, Round River: From the Journals of Aldo Leopold

_______________________

Photo Credit: Laura Leigh, Photojournalist

1.  Petfinder, What Constitutes Animal Cruelty?  http://www.petfinder.com/helping-pets/animal-cruelty/aspca-animal-cruelty-fact/

2. Resnick, P. J. and Zuchowski, S. J. (2010) Malingering and Psychopathic Disorders, in The International Handbook of Psychopathic Disorders and the Law: Laws and Policies (eds A. Felthous and H. Saß), John Wiley & Sons, Ltd, Chichester, UK. doi: 10.1002/9780470516157.ch64

3. Felthous, A. and Saß, H. (eds) (2008) Front Matter, in The International Handbook of Psychopathic Disorders and the Law: Laws and Policies, John Wiley & Sons, Ltd, Chichester, UK. doi: 10.1002/9780470516157.fmatter

4. The International Handbook of Psychopathic Disorders and the Law: Laws and Policies Alan Felthous, Henning Saß, Pages: i–xxi, 2010 Published Online : 6 JUL 2010, DOI: 10.1002/9780470516157.fmatter02

5. Animal Abuse as a Sentinel for Human Violence: A Critique

Journal of Social Issues, Volume 65, Issue 3, September 2009, Pages: 589–614, Emily G. Patterson-Kane and Heather Piper Article first published online : 23 JUL 2009, DOI: 10.1111/j.1540-4560.2009.01615.x

6. LOSING SAMSON: Nature, Crime, and Boundaries

The Sociological Quarterly, Volume 51, Issue 3, Summer 2010, Pages: 355–383, Paul Colomy and Robert Granfield Article first published online : 5 JUL 2010, DOI: 10.1111/j.1533-8525.2010.01176.x

7. State Wildlife Policy and Management: The Scope and Bias of Political Conflict

Public Administration Review, Volume 64, Issue 2, March 2004, Pages: 221–233, Martin Nie, Article first published online : 18 MAR 2004, DOI: 10.1111/j.1540-6210.2004.00363.x

“State wildlife policy and management are often characterized by divisive political conflict among competing stakeholders. This conflict is increasingly being resolved through the ballot-initiative process. One important reason the process is being used so often is the way state wildlife policy and management decisions are often made by state wildlife commissions, boards, or councils (the dominant way these decisions are made in the United States). These bodies are often perceived by important stakeholders as biased, exclusive, or unrepresentative of nonconsumptive stakeholder values. As a result, unsatisfied interest groups often try to take decision-making authority away from these institutions and give it to the public through the ballot initiative. Cases and examples from Alaska, Arizona, Colorado, and Idaho are examined in this context. The article finishes by outlining four broad alternatives that may be debated in the future: the no change alternative, the authoritative expert alternative, the structural change alternative, and the stakeholder-based collaborative conservation alternative(s).”

8. Animal Abuse and Neglect, http://www.humanesociety.org/issues/abuse_neglect/

9. Reno Federal Judge Chalks Up Another Defeat for BLM Against Laura Leigh,   http://wildhorsepreservation.org/media/reno-federal-judge-chalks-another-defeat-blm-against-laura-leigh

10. Laura Leigh Cases Continue with Federal Court Filings,  http://horsebackmagazine.com/hb/archives/18815

11. Court actions continue against BLM wild horse roundup conduct  http://www.examiner.com/article/court-actions-continue-against-blm-wild-horse-roundup-conduct

The economic and biological landscape in America today is quite clear, the Welfare Ranchers program must STOP!  The terms glutinous, greed, criminal activity, and taxpayer rip off associated with Welfare Ranching are all true, and even more illicit and criminal terms can be attached as well.

The ignorance displayed by Welfare Ranchers, consistently, between the roundups and killing of our Wild Horse Herds and Wolves, demonstrates their complete lack of knowledge and foresight — although their capacity to mooch off of our government tax money is overwelming!

The Bureau of Land Management (BLM) of the Department of the Interior (DOI), debatably manages, or mismanages according to some, over 150 million+ acres of rangeland in the western United States.  Within the last thirty years, increasing demand for nonconsumptive use of natural resources has resulted in increasing conflicts among claimants to the public lands.

Such things as Wild Horse Herd removal, unnecessarily, has created enlightenment to the general public.  Yes, the Welfare Ranchers’ greed and behavior has pointedly, like a beacon from a lighthouse to a wayward ship during a storm at sea, highlights the fraud and criminal activity of Welfare Ranchers and all those involved.  This information and data increases almost daily — never good, and always reeks of illicit and illegal behavior.

The Element of Dishonest Ranchers

The Welfare Ranching program is in direct violation of many of the laws and Executive and Secretarial Orders¹ listed below.  Take your pick from either category, as it is that contaminated and so polluted with inconsistencies, outright lies, the ignoring of laws, constant cover-up of criminal activity, and compounded by being managed incompetently by the BLM.  Also keep in mind the BLM and DOI remains the most litigated government agency that has ever existed — due to their constant incompetent, illegal, and certainly questionable decision making.

The Justice Department defends them, at an extremely large cost to tax payers (ignored always in BLM bookkeeping practice) — ironically, the Justice Department was formed to protect the Public from criminal activity within our government.  Instead —

It is ranchers and former legislators who were ranchers, that administer and manage the DOI and the BLM.  These are dishonest ranchers.  The proof is within their constant bad or illegal conduct of the many years these ranchers, and their friends, have been in charge of both agencies.  To the amazement of many investigators, the list is long of misconduct and overlooked or even illicit cover-ups that do exit, constantly over the past two decades.³

The ugly fact is this — the Welfare Rancher program is not useful what so ever and these ranchers’ simply pocket tax payer money, which makes most of them quite rich.

The Actual Facts Are

“It has long been known that the federal livestock grazing program is run at a significant loss. Grazing fees collected by the land management agencies cover only a fraction of the direct costs of the program.”²

BLM will tell the American Public how they make billions of dollars in profits, then the honest legislators turn their heads thinking everything is okay — that is, until someone starts to peel back this lie of lies the BLM gives to the public.  GAO reports outline the BLM takes a heavy loss of money yearly, and without assuming legal expenses within their data and bookkeeping analysis.

Often the GAO becomes specific in their details on how the loss, in billions of dollars, is due to faulty, unuseful, and mismanaged programs within the BLM and DOI.  Ignoring the truth is undeniable, yet causes lack of tax payer dollars to become useful in other beneficial and honest programs, and the truth — the BLM does not make a profit!  The BLM has never made a profit!

If the BLM insists on making this statement, then it is time they prove it beyond any doubt, and show us, the tax paying public exactly how they derived that profit, and all the while assuming all costs and liabilities — i.e. legal costs of courts, funding programs such as Welfare Ranching, losses taken by “not” collecting appropriate fees from their friends or special interest groups, etc. . .

We can also keep in mind the most recent 2010/2011 GAO Report, for example, “. . . $168 billion uncollected by BLM within the minerals management situation on Public Lands.”⁴

A 2005 GAO report points out $4.2 billion not collected from Welfare Ranchers at that time, and is estimated to increase at least 18% to 26% yearly on uncollected fees, and directly in regard to both BLM agency programs.  When we discuss Welfare Ranchers and Corporate Welfare, this is two of many instances we point out that is burdensome to tax payers, and the general public receives NO benefits from these programs what so ever.

Benefits of Taxpayer Supported Programs

Who does receive the benefits?  Welfare Ranchers and Corporations who maintain special lobby group interests, those who have paid campaign costs of legislators, and legislators and corporate entities and friends / lobbyists who hold interest — or outright own ranches and grazing permits on and for Public Lands.  This is similar to taking a kid to a candy store and telling him he can take whatever candy he wants, with no limits and free of charge because the tax payers are covering the cost.

As a matter of fact tax payers cover the maintenance and below-the-line expenses for Welfare Ranchers while they operate their cattle or sheep ranches.  Then it is the tax payer who pays twice for that same beef or sheep.

We pay taxes (which constantly rise due to these types of programs through this and other government agencies) and also pay the premium price at the store for these same meat products from Welfare Ranchers.  It is portrayed — as if these Welfare Ranchers compete with commercial ranchers — Make no doubt they do not! Make no doubt they cannot!  We pay for their ranches, that is a fact!

We pay billions of dollars to Welfare Ranchers yearly, and their product yield remains less than 2% of the meat products placed into commercial markets.  Again, our cost is double, in taxes and at the grocery store!

It is time to Stop the Welfare Ranching Program!

It is simply time Welfare Ranchers compete on the open market as a commercial entity, without tax payer money funding their business!  It is time for Welfare Rancher programs to be discontinued immediately!

One concern of many more, was the fact of $445 million in Administrative Support directly associated with the Welfare Rancher program yearly, for the program to exist.  What was also pointed out was the fact this same cost has never been associated with any benefit directly toward the tax paying public, whose money is used to cover this expenditure, and spent when the BLM “Does Not” do their oversight and proper jurisdictional management, for which they are paid.

BLM contracts are also flawed, and not in accord with responsible conduct in accord with and accomplished by private government contractors’.  The best example here is the constant and consistent Wild Horse Herd Roundup abuse and conflicting statements from contractors’, BLM staff, and legislators!  It is a circus of lies!

The Permits

One can peruse the list of ownership of Public Lands grazing permits, and start to understand why it remains today; that is, the names the public can actually review are heavily burdened with billionaires, corporations, and yes there exist plenty of Congressmen, Senators, and State Assemblymen.  Families have also handed-down these grazing permits for Public Lands usage to their children, and on and on, often without scrutiny from the BLM or DOI.

The BLM has recently rebuffed a court decision (via the Department of Justice and quite costly to taxpayers) for transparency of those owners and permit holders involved in Grazing Permits and Welfare Ranches.  Yes, the court case centered around the fact of showing the public at large — owners and grazing permit holders.  It is believed it would create a more honest program.

This was done when discovering there existed corporate ownership on lands that hold grazing permits, that have no ranching or other principle farm or ranch capability or existence what so ever — and yet the BLM pays them $2.5 million yearly.  The Problem?  This is not unique at all.  As well, make no doubt there is so much more in question.

There does exist, under Secretarial Orders and defined quite precise, the qualifications and continued scrutiny by the BLM of Grazing Permit Holders.  Most often this is ignored and ecological areas are ruined by cattle and sheep grazing. Wild Horse Herds are rounded up without proper explanation, and when a reason is given, it is most often proven in error, or simply data that has been tampered with and manipulated.  The overall reason for the roundups, quite costly to both tax payers and wildlife, is simply the reason to make more room for cattle to graze on Public Lands, and basically obtain more Welfare Rancher program tax money.  This is the only AML Welfare Ranchers appeal toward, no others.

Ethical violations exist as well, and plenty, in regard to legislators and government employees holding or owning cattle and sheep ranches and use Public Lands for their grazing.  They receive tax money under the Welfare Ranch program, and continue to pass laws, or make Public Lands decisions, that do not conflict with them receiving the tax money!

Some legislators in Nevada and Utah for example, even go so far as assisting BLM in the demographics and logistic plans for the removal of Wild Horses in order to make room for more cattle on their land and within their grazing permit status.  This is accomplished in order to receive more benefits, i.e. tax payer money, from the Welfare Rancher program.  This is also in direct conflict with the Wild Horse and Burro Program as well as ethical and other special interest laws that state clearly this type of direct involvement in the decision making process of our government is unacceptable, in total!

CONCLUSION

There is no place for Welfare Ranching programs in today’s landscape of government management of our taxed dollars.  Welfare Ranching may have been useful as a temporary situation in the 1930’s to the 1950’s; but has gone beyond any useful purpose within the markets of today and in a capitalist society.  Now it is simply a drain to our economy, and provides non-essential monetary support to those who cannot compete in a currently thriving commercial market — in another words it is unneeded and a useless program.

_________________________

¹ LAW

• Federal Land Policy and Management Act of 1976 (FLPMA), as amended, 43 U.S.C 1701 et. seq., provides authority for BLM land use planning. Regulatory guidance is at 43 CFR 1600 et seq. The RMP process is in 43 CFR 1610.4.
• National Environmental Policy Act of 1969 (NEPA), as amended, 42 U.S.C. 4321 et seq. Bureau guidance on NEPA process is in the Bureau Manual 1790 and Manual Handbook H-1790-1. Other guidance is the, “Overview of BLM’s NEPA Process” from Course #1620-02, and Council on Environmental Quality’s “40 NEPA Questions,” March 16, 1981.
• Endangered Species Act (ESA) of 1973, as amended, 16 U.S.C. 1531 et seq.
• Antiquities Act of 1906, as amended, 16, U.S.C 431-433
• National Historic Preservation Act (NHPA), as amended, 16 U.S.C. 470 et seq.
• American Indian Religious Freedom Act (AIRFA) of 1978, as amended, 42 U.S.C. 1996 et seq.
• Recreation and Public Purposes Act (R&PP) of 1926, as amended, 43 U.S.C. 869 et seq.
• Federal Coal Leasing Amendments Act of 1976, as amended, 30 U.S.C. 201(a)(3)(A)(i).
• Surface Mining Control and Reclamation Act of 1977, 30 U.S.C. 1201 et seq.
• Mineral Leasing Act of 1920, as amended, 30 U.S.C. 181 et seq.
• Mineral Leasing Act of 1942 (for acquired lands)
• Onshore Oil and Gas Leasing Reform Act of 1987, 30 U.S.C. 181 et seq.
• General Mining Law of 1872, as amended, 30 U.S.C. 21 et seq.
• Mining and Mineral Policy At of 1970, as amended, 30 U.S.C. 21(a)
• Archeological Resources Protection Act (ARPA) of 1978, as amended, 42 U.S.C 1996 et seq.
• Migratory Bird Conservation Act of 1979, as amended, 16 U.S.C 715 et seq.
• Native American Graves Protection and Repatriation Act (NAGPRA) of 1990, as amended, 25
• U.S.C 3001 et seq.
• Energy Policy and Conservation Act Reauthorization of 2000, as amended, P.L. 106-469. Energy Policy Act of 2005
• Clean Air Act of 1963, as amended
• Coastal Zone Management Act of 1972
• Clean Water Act of 1987, as amended
• Comprehensive Environmental Response, Compensation, and Liability Act of 1980
• Resource Conservation and Recovery Act of 1976
• Color of Title Act of 1928
• Recreation and Public Purposes Act of 1926
• Federal Water Pollution Control Act of 1948
• National Ambient Air Quality Standards of 1990

EXECUTIVE AND SECRETARIAL ORDERS

• Executive Order 12898 (Environmental Justice in Minority and Low-Income Populations)
• Executive Order 13007 (Indian Sacred Sites)
• Executive Order 13084 (Consultation and Coordination with Indian Tribal Governments)
• Executive Order 13112 (Invasive Species)
• Executive Order 11988 (Floodplain Management)
• Executive Order 11990 (Protection of Wetlands)
• Secretarial Order 3175 (Incorporated into Departmental Manual at 512 DM 2)
• Secretarial Order 3206 (American Indian Tribal Rights, Federal-Tribal Trust Responsibilities, and the Endangered Species Act)
• Executive Order 13186 (Migratory Birds)
• Executive Order 11514 (Protection and Enhancement of Environmental Quality)
• Executive Order 11738 (Administration of the Clean Air Act and the Federal Water Pollution Control Act with Respect to Federal Contracts, Grants, or Loans)
• Executive Order 12088 (Federal Compliance with Pollution Control Standards)

C-1 Appendix C-Relevant Statutes, Regulations, Orders, and Guidelines Draft EIS – August 2007

 ²  David K. Lambert and J. S. Shonkwiler, Property Rights, Grazing Permits, and Rancher Welfare, Journal of Agricultural and Resource Economics, 20(1):146-164 Western Agricultural Economics Association.

Horses Led To Slaughter, Anatomy of a Cover Up in the Wild Horse and Burro Program, PEER White Paper, Number 14, Public Employees for Environmental Responsibility, Washington D.C. 20009-1125, http://www.peer.org/pubs/whitepapers/1997_horses_to_slaughter.pdf , 1997.

4  Letter from Government Accountability Office on November 15, 2012 The Honorable Raúl M. Grijalva Ranking Member Subcommittee on National Parks, Forests, and Public Lands Committee on Natural Resources House of Representatives – GAO Report enclosed — Internet — http://grijalva.house.gov/uploads/GAO%20Report%20on%20Mineral%20Extraction%20on%20Federal%20Lands.pdf