Note from Laura:
I am going to make a few brief statement about the “handling statement” in the Decision Record on Jackson Mountain.
AS we discussed specific parameters and not one specific except the CFR’s (that are already specific and continually violated) and not ONE of them made the document my feelings are as follows:
The lack of any specific simply gives the distinct impression that they know they are not going to “do it right” and are afraid of the ramification of getting caught.
The language in this attachment demonstrates (in my opinion) that the idea of the appearance of a policy is important but any specific action, besides kicking an animal in the head or hitting with a helicopter, is up to the “discretion” of those that fail in that capacity.
I have tried all options open to me to create a productive discussion that leads to ANYTHING that gives a specific outcome that can create accountable ACTION. I am instead holding a document that does not restrict the livestock (that has resources outside the HMA) while horses forced off the HMA will be RUN BY HELICOPTER during foaling season. I am holding a document that in no way reflects any comprehension of the consequence of that action.
SEVEN miles as a parameter to run a newborn foal? We discussed, and there appeared to be agreement, that three miles was the upper limit and any band with a foal that lagged would be dropped from pursuit immediately. We discussed, and there appeared to be agreement, that NO single animal would be pushed by helicopter. We discussed, and there appeared to be agreement, that if wet mares came in with no foal that a search would be conducted immediately for a left behind facilitated by GPS coordinates immediately relayed when a band was spotted. We discussed so may things that are NOT reflected in this document.
My expectation is that access to observe will be highly restricted with fictitious justification to stop documentation. We are in it for the duration… and we will catch it.
Maybe I need to bring Q-tips to the next meeting and require that they clean their ears before we speak?
Jackson Mountain Gather June 7, 2012
To Ensure Safe and Humane Handling of All Gathered Wild Horses
Based on the Bureau of Land Management’s (BLM) experience with previous wild horse/burro gathers and the need to adapt some gather practices to specific local conditions, the following information will be discussed with all gather personnel before gather operations begin. This discussion will serve as a reminder that the humane handling of wild horses and burros (WH/B) during gather operation is always a primary concern. The Contracting Officer’s Technical Representative (COTR) will address any actions or issues that seem inhumane promptly and within contract specifications. Some guidelines include the following:
- The helicopter will not be operated in a manner where internal or external forces could cause it to come into contact with an animal. Hovering by the helicopter over the WH/B is acceptable so long as there is no risk of contact.
- Handling aids (including body position, voice, flags, paddles, electric prods will be used in a manner that is consistent with domestic livestock handling procedures. Flags and paddles will be used as signaling and noise making devices first with only light contact of the flag or paddle end allowed. Animals will not be whipped or beaten.
- Flagging and paddles will be used strategically to guard against desensitizing the WH/B.
- Kicking or hitting of WH/B is not acceptable.
- Electric prods (hotshots) will not be used routinely on WH/B. Electric prods will only be used to shock animals, not to tap or hit animals. Electric prods will not be applied to sensitive areas such as the face, head, genitals or anus. Electric prods may only be used when WH/B or human safety is in jeopardy or other handling aids have been tried and are not working.
- Gates and doors will not be deliberately slammed or shut on WH/B. Gates can be used to push WH/B but will not be used in a manner that may catch legs.
- Pursuing single WH/B should be a rare event and not standard practice. Only the COTR will identify and request the contractor to pursue single WH/B.
- The contractor will make every effort to ensure that foals are not left behind or orphaned in the field. If a foal has to be dropped from a group being brought to the trap because it is getting too tired or cannot keep up for any reason, the contractor/pilot will document the location of the foal and the description of the mare to facilitate “pairing- up” at temporary holding. In this case, the contractor will provide trucks/trailers and saddlehorses for the retrieval of the young foal(s), and transport the foal(s) to the gather site or temporary holding. The method of capture will be authorized or requested by the COTR.
- If during the gather any wild horses being brought in by helicopter (including foals or horses that may be aged, lame, injured or otherwise appear weak or debilitated) appear to be having difficulty keeping up with the group being brought in, the contractor will slow down to accommodate the individuals having difficulty, pause to allow those animals to rest before proceeding, drop those individuals from the group or drop the entire group. It is expected that animals may be tired, sweaty and breathing hard on arrival at a trap, but they will not be brought in by the helicopter in a manner that results in exhaustion, collapse or distress.
- The need to rope specific WH/B will be determined by the COTR on a case by case basis. The COTR will identify what WH/B need to be roped.
- While gathering, there may be WH/B which escape or evade the gather site while being moved with the helicopter. In these cases there may be multiple attempts to recapture and push the WH/B to the gather site. In these instances, animal condition and fatigue will be evaluated on a case by case basis to determine the number of attempts that can be made to capture/recapture. Animals will not be pursued to a point of exhaustion.
- Any foals that are not weaned and have been maintained with their mares at the gather temporary holding corral will be transported to the BLM preparation facilities as soon as practical. Mares with dependent foals will be separated from other animals and moved to a designated mare/foal pen until they can be shipped to the BLM preparation facility.
- All sorting, loading, or unloading of WH/B will be performed during daylight hours.
- Screening on panels will be provided where loading operations occur as a visual barrier and to block holes, gaps, or openings where WH/B could attempt to escape or be injured.
- As determined by the COTR, appropriate dust control measures will be implemented as noted in the gather contract.
- When possible, the contractor will have the trailer floor at ground level to ease the loading of WH/B at the gather site.
- If the pilot is moving WH/B and observes an animal that is clearly injured or suffering, the animal should be left on the range and its location noted. The BLM COTR or Project Inspector with APHIS veterinary assistance if necessary will then go to the area to determine the condition of the WH/B and the appropriate actions necessary to address the welfare of the animal including euthanasia if needed.
- All gather personnel; including contractors will be monitored for fatigue.
- Injuries that required veterinary examination or treatment, deaths, and spontaneous abortions that may occur will be noted in gather reports and statistics kept by the COTR.
- At the discretion of the COR, if an wild horse or foal is injured during gather operations, gather operations may be temporarily suspended if necessary to provide care for the animal and safe transportation to the temporary holding corrals or BLM preparation facility as indicated.
- The contractor, per the gather contract, shall provide animals held in the gather corrals and/or holding facilities with a continuous supply of fresh clean water at a minimum rate of 10 gallons per animal per day. Animals held for 10 hours or more in the gather corrals or holding facilities shall be provided good quality hay (grass hay) at a rate of not less than two pounds of hay per 100 pounds of estimated body weight per day. Hay will be distributed around the pens such that each animal can eat at one time without overcrowding.
- When extreme environmental conditions exist (temperature) during this gather, the overall health and well-being of the animals will be monitored and the COR will adjust gather operations as necessary to protect the animals from climatic and gather related health issues. There may be days when gather operations cease based on temperatures.
- The success of gathering and safely and humanely caring for or handling WH/B will be based on contractor and BLM staff’s patience, expertise and experience.
- The IC, COR and contractor will ensure that the distance animals are brought to the gather site is based on the terrain, environmental conditions, and animal health. With foals, pregnant mares, or horses that are weakened by body condition, age or poor health the appropriate trailing/gather distance will be determined on a case by case basis considering the weakest or smallest animal in the group and the range and environmental conditions present. The maximum gather distance will depend on the specific animal and environmental conditions on the day of the gather, and direct dialogue with the pilot/contractor and COR/PI will take place for each ‘run” to provide important information as to numbers, number of foals, locations distance and/or overall animal and/or environmental conditions. Ten miles will typically be the upper limit for gather distances under normal conditions. Under the current conditions anticipated in the southern part of the Jackson Mountains (young foals and animals potentially weakened by drought) 5-7 miles will be the goal for the upper limit. The trap locations will be moved closer to horse locations as much as possible to ensure the humane treatment of the animals.