EDIT: This article was written prior to the implementation of CAWP in fall 2015. In late 2015 a written policy was added to roundup contracts.
The Bureau of Land Management (BLM) will conduct a public hearing on the use of motorized vehicles including aircraft in the monitoring and management of wild horses and burros on public lands in Nevada. The hearing will be held on Wednesday, June 18, at 6 p.m. at the Bureau of Land Management Winnemucca District Office, 5100 East Winnemucca Blvd. Winnemucca, Nev.
BLM press release states: If you cannot attend the hearing, written comments must be mailed to the BLM Winnemucca District Office, Attention: Mandy Deforest, 5100 East Winnemucca Blvd, Winnemucca, Nevada 89445and be received by June 27, 2014 to be considered.
The BLM uses helicopters for survey work and roundups. In order to be able to use any “motorized” vehicle for wild horse and burro management law requires them to hold an annual meeting for public input.
As always we urge you to write your own letter. We urge you to use all available information (and not selective) to create the strongest response you can. Comments generally should be geared at pointed out a deficiency of analysis or proposed protocol.
Wild Horse Education comments are below:
Public Comments on the use of Motorized Vehicles 2014
It is recognized that in modern times the use of motorized vehicles can create a safe and efficient method to achieve several objectives. When used appropriately the tool is acceptable. When used inappropriately the consequences include injury, death and additional expenses from litigation negating any benefit from their use.
We have no objection to motorized vehicle use for purposes of census or range monitoring. In these instances the use of such tools is a necessity.
We have no objection to the use of motorized vehicles for the purpose of transporting wild horses or burros.
We make objections to the use of motorized vehicles, specifically the use of helicopters, during wild horse or burro roundups under the current customary practices.
Our organization bases these objections on the following:
1. The most comprehensive photo and video library in the world on current BLM helicopter roundups over the course of the last four years.
2. Multiple court orders our organization has gained to conduct at wild horse roundups that include the use of helicopters.
Subsection 2(B) of the Wild Free Roaming Horses and Burros Act states specifically that “excess wild free- roaming horses and burros to be humanely captured.” A directive for “humane” management is mentioned no less than seven times in that document.
We are aware that in February of 2011 BLM began to explore what it has called a comprehensive welfare program it dubbed “CAWP.” However simply stated this “program” simply allows those that perpetrate the offensive conduct to make a determination of the appropriateness of their own conduct. The oversight is limited to BLM Wild Horse and Burro Specialists, BLM “COR,” and the Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) who are the exact individuals that allow the practices the public, and courts, find objectionable. The entire “policy” is conceptual with no measurable determining factors.
Since the beginning of the “implementation” of this program (and under Interim Memoranda from state and federal BLM leaders) our organization has gained court orders against conduct. “Pilot conduct” is contained in both Temporary Restraining Orders and a Preliminary Injunction. This is a clear indicator that “CAWP” has created no change in the manner in which BLM utilizes the “helicopter” as a tool for “humane capture.”
In addition continued studies on whether wild horses and burros need shade, or having APHIS “specialists” advise on “humane care” appears to be no more than procrastination on creating a humane handling policy.
Helicopter use should be restricted, in all but extreme emergency (fire), from October through December. The vast majority of fatal injuries we have documented occur during foaling season. Foals run before their legs have had a chance to strengthen are often casualties of the roundup. At this time many of the injuries can cause death or permanent damage months later. These deaths are not included in any BLM data base but have been repeatedly documented. In January and February we see late term miscarriages in heavily pregnant mares that are also not included in any BLM database but have been repeatedly documented. Hoof injuries (such as the foals documented that suffered from literally having their hooves run off) are more common on frozen hard ground.
Until BLM adequately protects wild horses and burros from the type of conduct demonstrated in the past the use of helicopters during capture is irresponsible.
Attached please find a pdf (link: http://wildhorseeducation.files.wordpress.com/2014/03/action_wip_humanel.pdf) This document outlines the need for an actual humane handling policy. Helicopter use is addressed in the document. The last two pages of this document outline a draft handling policy.
Please note our objections for the record and include a copy of the linked pdf.
We would welcome the opportunity to discuss this issue further and provide any information to assist with the creation of a suitable protocol.
President and Founder, Wild Horse Education
~~~ We urge you to send in your comments today!
Below is the Triple B in Ely/Elko Nevada (TRO and Preliminary Injunction)
Wild Horse Education is devoted to gaining protections from abuse, slaughter and extinction for our wild horses and burros. Please help us stay in the fight. http://WildHorseEducation.org