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Recommendation By American Citizens and Experts Based On: Science, Sustainability, Humane Handling, Cost Effectiveness

Created at the Saving our Wild Horses and Wildlife Conference April 2024

Tracy Stone-Manning
Director, Bureau of Land Management
U.S. Department of the Interior
1849 C Street NW, Room 5665
Washington, DC 20240


Dear Director Stone-Manning,

The following are the recommendations crafted by American stakeholders from diverse regions of the country, along with the expertise of professionals who collaborated to address the comprehensive management of wild horses, burros, and wildlife at the Saving Our Wild Horses and Wildlife Conference in Reno, Nevada, held from April 17th to 19th.

The following was created utilizing the best available information regarding regulations and policy. Each recommendation made by the coalition of wild horse and burro advocates is currently within the authority of the Secretary to act.

Recommendations for Ethical and Effective Wild Horse and Burro Management

We respectfully submit the following:

1.   Herd Management Area Plans (HMAPs)

  • Initiate HMAPs promptly, with at least two started per district by year-end, as mandated by 43 CFR 4710.1 with a deadline of 1-year for completion.
  • Equity in the NEPA process must be facilitated. All current scoping practices that include disclosure of all relevant data, public meetings, etc. must be provided during the scoping for wild horse and burro HMAPs. In the vast majority of HMAs, advocates have waited nearly 40 years for BLM to craft these plans and disclose basic facts including how Appropriate Management Level (AML) is set.
  • Enforce strict adherence to HMAP requirements to maintain ethical, humane, and legal standards in wild horse management practices.

2.   On Range Management

  • Reevaluate Herd Areas (HAs) to identify potential repatriation.
  • We recommend accomplishing this goal through the HMAP process for HAs managed within complexes (for gathers) or as an independent evaluation. The regulations state no Land Use Plan revision is required for any change in AML.
  • Conduct thorough assessments to optimize HMA utilization and resource allocation effectively. Look into rewilding projects (studies) with universities for zeroed-out HMAs. (They are doing rewilding projects all around the world with horses and the United States is lagging far behind in utilizing wild horses as a beneficial rangeland component and wildfire fuel reducer) .
  • Implement CFR 4710.5 to prioritize the reduction and removal of cattle before horses, promoting sustainable grazing practices and for wild horse and wildlife habitat preservation. Cattle are the number one cause of rangeland standards not being met across all BLM land, per BLM’s own data. Livestock Grazing also costs American taxpayers millions each year by not charging Permittees standard grazing fees. (This evaluation is appropriate in the HMAP process.)
  • Incorporate current scientific knowledge to ensure genetic diversity and viability that promote natural herd dynamics in wild horse and burro management practices. Currently most HMA’s do not meet this standard. AMLs do not reflect genetic health and adjustments are overdue. Interim AMLs set in the 1980s cannot simply be “affirmed” without any data-based equation.

3.   Mitigate Damage to Water Sources and Habitat Loss from Mining Disturbance

  • Implement measures to mitigate damage to resources (water, acreage loss) for wild horses and burros during mining exploration and operations and other industrial uses.
  • Mitigation strategies should be addressed during site-specifi c NEPA (mining EIS and/or HMAP).

4.   Wildlife Protection

  • End the killing of predators and wildlife sharing ranges with wild horses and burros. This is done at the request of a few special interests to great detriment.
  • Prioritize ecosystem balance and protect biodiversity within wild horse and burro habitats.

5.   Wild Horse and Burro Management

  • Require wild horse and burro specialists to receive specialized and ongoing training in wild horse ecology and behavior.
  • Prohibit the use of sterilization ( both physical and via chemical contraception) and other population growth suppression methods that substantially alter natural behaviors or impact health and well-being.
  • Prohibit vague descriptions of “fertility control” in population management plans and approval of conglomerate and indiscriminate application.
  • If fertility control is justified after all variables are disclosed through the HMAP, we recommend prioritizing reversible fertility control (PZP native).
  • Cease GonaCon usage until further research validates its efficacy and safety, adhering to established scientific protocols. BLM’s current method of use has never been studied. Feed-through studies are needed to establish the safety of use on other species in the ecosystem. The current protocol for application would likely last longer than the lifespan of the animals treated, jeopardizing herd health and genetic stability.
  • Cease all sex skewing strategies due to their adverse effects on herd dynamics and natural herd structures. Promote stable population dynamics by implementing measures that preserve the natural balance of wild horse populations.
  • Refrain from IUD implementation due to potential health risks and lack of conclusive evidence supporting their efficacy.
  • Sterilization of stallions and jacks should not be done. The procedure's complication rates are too high, and efficacy is low as it also only takes one unaltered stallion to cover all mares. On ranges where geldings were released, artificial use patterns were documented as geldings do not roam as much, impacting herd distribution.

6.   Allocation for CAWP

  • Allocate funding from the BLM Budget for Rulemaking for an enforceable welfare policy.
  • The Comprehensive Animal Welfare Program (CAWP) is inadequate and provides scant monitoring and no enforcement for violations. Every operation should have monitors present. Every facility must be reviewed annually.
  • Rulemaking is needed to align BLM's internal CAWP standard with industry best practices, facilitating enforceable and transparent humane handling.

7.   Enforcement and Animal Welfare

  • Mandate background checks on all contractors involved in equine care, prohibiting those with a history of animal abuse from working with horses and burros. Implement stringent penalties for animal abuse, including the termination of contracts for non-compliance. These measures uphold ethical standards and deter mistreatment within wild horse management practices, prioritizing the welfare of these animals above all else.
  • Safeguard animal welfare and mitigate adverse weather conditions by providing adequate shelter at holding facilities for all wild horses and burros. This would be done by the installation of shade and windbreaks at all holding facilities.
  • Ensure water sources are suffi cient for wild horses and wildlife in the current climate change conditions.
  • Dredge existing waterholes, add guzzlers or wells as necessary.
  • Ensure that wild horses, burros and wildlife are not fenced out of water sources.
  • Cease the Adoption Incentive Program (AIP). It is expensive and there are no adequate safety nets in place to ensure the equines safety. Strictly enforce a permanent ban on individuals who abandon horses after being titled.

8.   Recognition of Species

  • Acknowledge burros as a separate species from wild horses and treat them accordingly. Ensure that management practices respect their unique behaviors and biological needs, promoting their welfare and conservation.

9.   Gather Operations

  • No roundups should proceed until a Herd Management Area Plan (HMAP) is established for each Herd Management Area (HMA). This ensures legitimate and updated Appropriate Management Levels (AMLs) based on science and current range evaluations for each area.
  • Immediately halt the use of helicopters in the management of wild horses and burros.
  • Develop more humane bait trap protocols for wild horse management to ensure the safety and well-being of these animals during capture and handling. They are being done by some private contractors.
  • Prioritize diversity in age groups when releasing horses back onto ranges to promote natural herd dynamics.
  • Minimize stress during captures and processing by following CAWP and having CAWP people at roundups, both public and BLM.
  • Immediately cease the euthanasia of horses with manageable conditions. Facilitate transfers to sanctuaries off ering specialized care, ensuring that these animals receive the support and treatment they need to thrive.

10. Transparency and Oversight

  • Implementing these measures will signifi cantly enhance transparency, accountability, and public trust in the BLM’s management of wild horses and burros.
  • Establish a public portal on the BLM website to provide transparency measures for all aspects of the Wild Horse and Burro program.
  • Make data from gather operations accessible to the public in real time. Ensure that all shipping manifests, both incoming and outgoing, as well as reports on deaths (including those from preexisting conditions), injuries, and veterinary reports, are published on a BLM web portal, making data easy to fi nd and accessible to the public.
  • All holding facilities should allow public observation at least monthly.
  • Prioritize Public Oversight: Public observation during wild horse and burro gathers must take precedence over confl icting interests. Implement measures to ensure impartial selection of viewing areas, prioritizing public meaningful access and transparency in gathering operations, including the round-up, sorting, loading, and all actions at temporary holding. Public access on private land should be guaranteed at all times.
  • Install cameras on helicopters and at bait trapping sites during operations. Real-time video footage should be accessible to the public, both during operations and afterward. This footage should be added to the roundup page for each gather. An independent third party should have control over this program.
  • Make BLM leadership, including district-level offi cials, easily accessible by providing direct contact information on the BLM’s Wild Horse and Burro webpages.
  • Involve all interested stakeholders representing wild horses and burros in decision-making processes, ensuring balanced representation in all BLM actions. Reform the BLM Advisory Board to prevent control by special interests and include diverse perspectives. 
  • Address the FOIA backlog: Clear the backlog of Freedom of Information Act (FOIA) requests and make the requested information readily available to the public through the BLM website. Prioritize timely responses to FOIA requests to ensure transparency and accountability.

These comprehensive recommendations aim to address pertinent points, promoting ethical and eff ective management of wild horses and burros while enhancing transparency and accountability within BLM operations. They are supported by leading experts and citizen stakeholders dedicated to preserving our public lands for generations to come.

By endorsing this initiative, these organizations and American taxpayers assert their strong support for these crucial measures to protect our wild horses, burros, and wildlife on public lands. We stand at a critical juncture in the fi ght against climate change, making these actions imperative for the survival of these species and the health of our ecosystems. Implementing these recommendations also aligns with and supports the government's 30/30 plan, aimed at conserving 30% of our lands and waters by 2030. We call for immediate attention and action.

                                                                          -----

Endorsement Statement

This document is proudly endorsed by the following organizations and citizen stakeholders.
To sign on to the doc please follow the instructions below.


Please add your information as follows:
Please email the info to LGSOWH@gmail.com. Saying you would like to be added to the Document.
Your support is greatly appreciated.

Downloadable PDF version

Saving our Wild Horses and WildLife

 

Recommendation By American Citizens and Experts Based On: Science, Sustainability, Humane Handling, Cost Effectiveness

Created at the Saving our Wild Horses and Wildlife Conference April 2024

Tracy Stone-Manning
Director, Bureau of Land Management
U.S. Department of the Interior
1849 C Street NW, Room 5665
Washington, DC 20240


Dear Director Stone-Manning,

The following are the recommendations crafted by American stakeholders from diverse regions of the country, along with the expertise of professionals who collaborated to address the comprehensive management of wild horses, burros, and wildlife at the Saving Our Wild Horses and Wildlife Conference in Reno, Nevada, held from April 17th to 19th.

The following was created utilizing the best available information regarding regulations and policy. Each recommendation made by the coalition of wild horse and burro advocates is currently within the authority of the Secretary to act.

Recommendations for Ethical and Effective Wild Horse and Burro Management

We respectfully submit the following:

1.   Herd Management Area Plans (HMAPs)

  • Initiate HMAPs promptly, with at least two started per district by year-end, as mandated by 43 CFR 4710.1 with a deadline of 1-year for completion.
  • Equity in the NEPA process must be facilitated. All current scoping practices that include disclosure of all relevant data, public meetings, etc. must be provided during the scoping for wild horse and burro HMAPs. In the vast majority of HMAs, advocates have waited nearly 40 years for BLM to craft these plans and disclose basic facts including how Appropriate Management Level (AML) is set.
  • Enforce strict adherence to HMAP requirements to maintain ethical, humane, and legal standards in wild horse management practices.

2.   On Range Management

  • Reevaluate Herd Areas (HAs) to identify potential repatriation.
  • We recommend accomplishing this goal through the HMAP process for HAs managed within complexes (for gathers) or as an independent evaluation. The regulations state no Land Use Plan revision is required for any change in AML.
  • Conduct thorough assessments to optimize HMA utilization and resource allocation effectively. Look into rewilding projects (studies) with universities for zeroed-out HMAs. (They are doing rewilding projects all around the world with horses and the United States is lagging far behind in utilizing wild horses as a beneficial rangeland component and wildfire fuel reducer) .
  • Implement CFR 4710.5 to prioritize the reduction and removal of cattle before horses, promoting sustainable grazing practices and for wild horse and wildlife habitat preservation. Cattle are the number one cause of rangeland standards not being met across all BLM land, per BLM’s own data. Livestock Grazing also costs American taxpayers millions each year by not charging Permittees standard grazing fees. (This evaluation is appropriate in the HMAP process.)
  • Incorporate current scientific knowledge to ensure genetic diversity and viability that promote natural herd dynamics in wild horse and burro management practices. Currently most HMA’s do not meet this standard. AMLs do not reflect genetic health and adjustments are overdue. Interim AMLs set in the 1980s cannot simply be “affirmed” without any data-based equation.

3.   Mitigate Damage to Water Sources and Habitat Loss from Mining Disturbance

  • Implement measures to mitigate damage to resources (water, acreage loss) for wild horses and burros during mining exploration and operations and other industrial uses.
  • Mitigation strategies should be addressed during site-specifi c NEPA (mining EIS and/or HMAP).

4.   Wildlife Protection

  • End the killing of predators and wildlife sharing ranges with wild horses and burros. This is done at the request of a few special interests to great detriment.
  • Prioritize ecosystem balance and protect biodiversity within wild horse and burro habitats.

5.   Wild Horse and Burro Management

  • Require wild horse and burro specialists to receive specialized and ongoing training in wild horse ecology and behavior.
  • Prohibit the use of sterilization ( both physical and via chemical contraception) and other population growth suppression methods that substantially alter natural behaviors or impact health and well-being.
  • Prohibit vague descriptions of “fertility control” in population management plans and approval of conglomerate and indiscriminate application.
  • If fertility control is justified after all variables are disclosed through the HMAP, we recommend prioritizing reversible fertility control (PZP native).
  • Cease GonaCon usage until further research validates its efficacy and safety, adhering to established scientific protocols. BLM’s current method of use has never been studied. Feed-through studies are needed to establish the safety of use on other species in the ecosystem. The current protocol for application would likely last longer than the lifespan of the animals treated, jeopardizing herd health and genetic stability.
  • Cease all sex skewing strategies due to their adverse effects on herd dynamics and natural herd structures. Promote stable population dynamics by implementing measures that preserve the natural balance of wild horse populations.
  • Refrain from IUD implementation due to potential health risks and lack of conclusive evidence supporting their efficacy.
  • Sterilization of stallions and jacks should not be done. The procedure's complication rates are too high, and efficacy is low as it also only takes one unaltered stallion to cover all mares. On ranges where geldings were released, artificial use patterns were documented as geldings do not roam as much, impacting herd distribution.

6.   Allocation for CAWP

  • Allocate funding from the BLM Budget for Rulemaking for an enforceable welfare policy.
  • The Comprehensive Animal Welfare Program (CAWP) is inadequate and provides scant monitoring and no enforcement for violations. Every operation should have monitors present. Every facility must be reviewed annually.
  • Rulemaking is needed to align BLM's internal CAWP standard with industry best practices, facilitating enforceable and transparent humane handling.

7.   Enforcement and Animal Welfare

  • Mandate background checks on all contractors involved in equine care, prohibiting those with a history of animal abuse from working with horses and burros. Implement stringent penalties for animal abuse, including the termination of contracts for non-compliance. These measures uphold ethical standards and deter mistreatment within wild horse management practices, prioritizing the welfare of these animals above all else.
  • Safeguard animal welfare and mitigate adverse weather conditions by providing adequate shelter at holding facilities for all wild horses and burros. This would be done by the installation of shade and windbreaks at all holding facilities.
  • Ensure water sources are suffi cient for wild horses and wildlife in the current climate change conditions.
  • Dredge existing waterholes, add guzzlers or wells as necessary.
  • Ensure that wild horses, burros and wildlife are not fenced out of water sources.
  • Cease the Adoption Incentive Program (AIP). It is expensive and there are no adequate safety nets in place to ensure the equines safety. Strictly enforce a permanent ban on individuals who abandon horses after being titled.

8.   Recognition of Species

  • Acknowledge burros as a separate species from wild horses and treat them accordingly. Ensure that management practices respect their unique behaviors and biological needs, promoting their welfare and conservation.

9.   Gather Operations

  • No roundups should proceed until a Herd Management Area Plan (HMAP) is established for each Herd Management Area (HMA). This ensures legitimate and updated Appropriate Management Levels (AMLs) based on science and current range evaluations for each area.
  • Immediately halt the use of helicopters in the management of wild horses and burros.
  • Develop more humane bait trap protocols for wild horse management to ensure the safety and well-being of these animals during capture and handling. They are being done by some private contractors.
  • Prioritize diversity in age groups when releasing horses back onto ranges to promote natural herd dynamics.
  • Minimize stress during captures and processing by following CAWP and having CAWP people at roundups, both public and BLM.
  • Immediately cease the euthanasia of horses with manageable conditions. Facilitate transfers to sanctuaries off ering specialized care, ensuring that these animals receive the support and treatment they need to thrive.

10. Transparency and Oversight

  • Implementing these measures will signifi cantly enhance transparency, accountability, and public trust in the BLM’s management of wild horses and burros.
  • Establish a public portal on the BLM website to provide transparency measures for all aspects of the Wild Horse and Burro program.
  • Make data from gather operations accessible to the public in real time. Ensure that all shipping manifests, both incoming and outgoing, as well as reports on deaths (including those from preexisting conditions), injuries, and veterinary reports, are published on a BLM web portal, making data easy to fi nd and accessible to the public.
  • All holding facilities should allow public observation at least monthly.
  • Prioritize Public Oversight: Public observation during wild horse and burro gathers must take precedence over confl icting interests. Implement measures to ensure impartial selection of viewing areas, prioritizing public meaningful access and transparency in gathering operations, including the round-up, sorting, loading, and all actions at temporary holding. Public access on private land should be guaranteed at all times.
  • Install cameras on helicopters and at bait trapping sites during operations. Real-time video footage should be accessible to the public, both during operations and afterward. This footage should be added to the roundup page for each gather. An independent third party should have control over this program.
  • Make BLM leadership, including district-level offi cials, easily accessible by providing direct contact information on the BLM’s Wild Horse and Burro webpages.
  • Involve all interested stakeholders representing wild horses and burros in decision-making processes, ensuring balanced representation in all BLM actions. Reform the BLM Advisory Board to prevent control by special interests and include diverse perspectives. 
  • Address the FOIA backlog: Clear the backlog of Freedom of Information Act (FOIA) requests and make the requested information readily available to the public through the BLM website. Prioritize timely responses to FOIA requests to ensure transparency and accountability.

These comprehensive recommendations aim to address pertinent points, promoting ethical and eff ective management of wild horses and burros while enhancing transparency and accountability within BLM operations. They are supported by leading experts and citizen stakeholders dedicated to preserving our public lands for generations to come.

By endorsing this initiative, these organizations and American taxpayers assert their strong support for these crucial measures to protect our wild horses, burros, and wildlife on public lands. We stand at a critical juncture in the fi ght against climate change, making these actions imperative for the survival of these species and the health of our ecosystems. Implementing these recommendations also aligns with and supports the government's 30/30 plan, aimed at conserving 30% of our lands and waters by 2030. We call for immediate attention and action.

                                                                          -----

Endorsement Statement

This document is proudly endorsed by the following organizations and citizen stakeholders.
To sign on to the doc please follow the instructions below.


Please add your information as follows:
Please email the info to LGSOWH@gmail.com. Saying you would like to be added to the Document.
Your support is greatly appreciated.

Downloadable PDF version

Saving our Wild Horses and WildLife