As the Clan Alpine Roundup nears completion we take a minute to talk about our lawsuit to gain “rulemaking” and enforceable policy. (The government uses one word “rulemaking,” it is not a typo.)
You can view team reports from the ongoing roundup HERE.
Many have asked “What does that mean? BLM says they have a “policy?”
Why do we need rulemaking?
If you look at the pictures above they illustrate something very simple: cleaning trailer floors and checking for sharp or anything that can cause injury during trailering.
Some current CAWP standards.
- All partitions and panels inside of trailers must be free of sharp edges or holes that could cause injury to WH&Bs. (major)
- The inner lining of all trailers must be strong enough to withstand failure by kicking that would lead to injuries. (major)
- Partition gates in transport vehicles should be used to distribute the load into compartments during travel. (minor)
- Surfaces and floors of trailers must be cleaned of dirt, manure and other organic matter prior to the beginning of a gather. (major)
Some people from BLM interpret the internal “policy” as meaning at the start of the day, some interpret as at the start of the entire operation and some “if we feel like it because there is no one really watching and no consequences anyway.”
Above: Horse down in trailer. BLM moves the the trailer (and puts another in front). We cannot tell if the horse rose, but BLM said it did.
If you are a horse owner, do you check your trailer before each load and at least run a push broom down to knock out the “horse apples” and at least let any urine evaporate or put shavings on top?
If you were going to trailer up to 50 horses a day in multiple trips, for over a month, how often would you clean it?
Above: Same contractor and many of the same agency personnel were at other operations throughout the year. Horses captured with no injuries, after trailering there were injuries.
When observers take photos of trailer floors, BLM will often claim that the flooring of a livestock (cattle) trailer that is ridged, does not need to be cleaned daily…. because it has ridges. If you trailer horses, what do you think about that?
Trailers are one simple example of an inadequate internal policy. BLM alternates between uses the words “policy, program, standard” to describe their Internal Memorandum for welfare standards.
Everything from how electric shocks are used, how close a chopper can fly, when barbed wire and gates need to be taken down or flagged, gaps between loading ramps and trailers, etc. are all under this same type of compliance only when convenient and inconsistent answers.
In fall of 2015 (the start of fiscal 2016) BLM adopted what they called a “Beta” version of standards to see how they could work and monitored. It caused an uproar in the livestock community and we have never been sure why.
BLM said they would do annual reviews, make them public and then work on finalizing a permanent policy. BLM never did step 1 or 2. In 2021, they finally put someone in charge of animal welfare and the current Wild Horse and Burro Chief (Holle Waddell) simply changed the Beta version into a permanent “Instruction Memorandum.”
Learn more about the long fight to gain an enforceable welfare policy.
That is not how policy is made.
You need to have a say. Current veterinary practices and information. need to be provided and the beta revised in an open process.
When that happens, we have “enforceable rules to comply with law.”
No more vague “he said, she said” and standards that go through an open public analysis process to actually prevent abuses and injury. An enforceable rule could also carry the consequence of “no compliance, no contract or demotion.”
This is why we are back in court.
From the horror of a summer roundup like Antelope where new babies are run in blistering heat, to operations like Clan Alpine where things like when a trailer gets cleaned are vague, we need formal enforceable rules.
End of year funding is critical to all nonprofits.
Thank you for keeping us in the fight to protect and preserve our wild ones.
Categories: Wild Horse Education
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