Thank you for providing the opportunity to speak today.  My name is Tom Allen.  I am here representing the Public Lands Foundation whose members have thousands of years collective experience managing natural resources.  No one in the Foundation receives pay for Foundation work.

Twelve years ago we prepared a position statement regarding wild horses and burros stating that substantial changes need to be made in how horses and burros are managed.  Our belief, then   and in our position statement updated last year, is that wild horses and burros should be managed on a limited number of federally designated Ranges in the West.  All WHBs would eventually live on these Ranges, exclusive of livestock and all Herd Management Areas (HMAs) would be retired.  Ranges would be managed for the benefit of WHBs and wildlife.  This position should not be confused with the Secretary’s proposal to acquire land for preserves, which is altogether quite different.

The Horse and Burro Act resulted in the creation of nearly 200 HMAs scattered throughout ten states involving 44 BLM offices. 

After nearly 40 years of experience, it is clear that this happenstance, patchwork of HMAs has contributed to both the high cost and the difficulty of managing WHBs.  With the benefit of hindsight, it is inconceivable that Congress would, today, create such a patchwork of areas in an effort to meet the purpose of the Wild Horse and Burro Act.

My purpose here today is not to ask you to endorse creation of Ranges as we have suggested; however, that would be o.k. if you chose to do that.  Instead, I am asking this Board to consider making a recommendation to the BLM that they cooperate with the Foundation to provide information necessary to better develop the option of establishing federal Ranges.  We are not asking for funding or access to other than public information.  Work would be done by volunteer resource professionals accessing information in BLM offices.  We simply need BLM help to point us to the information.  The Foundation has what it believes to be a good relationship with the BLM but would benefit from your endorsement to facilitate our work.

The Foundation knows well that the devil is in the details.  Our interest is in developing the kind of information necessary for creation of Ranges to be fully considered; either now or in the future.  If further work on our position suggests that the devils are too many and too difficult to overcome, we will be the first to tell everyone just that.

The Foundation has made a preliminary review of the recently released strategy proposal and intends to provide detailed comments by the end of the month.  At this time, we only offer our concern that management is at risk of going forward with only minor variations on the status quo while substantive  decisions and actions are deferred for two or more years.

Thank you.  Copies of my remarks have been made available to staff.