BLM is having another Advisory Board meeting.
The meeting is scheduled for Jan. 7-9 at The Officer’s Club (Ballroom) located at 3410 Westover Street, Sacramento (McClellan), Calif. from 8 a.m. to 5 p.m. Pacific Time each day.
We first notified you about the meeting on December 6th.
Spoken comments to the Advisory Board can be made in person or virtually via Zoom (audio only) on Tuesday Jan. 7, from 1 p.m. to 2 p.m. PT and on Wednesday, Jan. 8, from 9 a.m. to 10 a.m. PT.
Registration is required by Jan. 3 to provide comment via Zoom.
In-person speakers may register on-site up to one hour before the comment period commences
IMPORTANT NOTE: In order to have comments considered by the board, they must be emailed 3 days before the meeting. Comments made in person or given to the board during the meeting are not considered. The email to use: blm_wo_advisory_board_comments@blm.gov
If you do not have time to craft and submit your own comments, we have a short public comment letter you can sign onto. Click HERE to sign the comment letter. WHE will have representatives onsite and will be submitting in-depth comment letters in addition to handing in the shorter version the public can sign onto.
The public may attend the meeting in person or watch via live stream at www.blm.gov/live
You can find more at the BLM website HERE.
Glimpse down an alley at Blue Wing burros trying to reach feed under what looks like a section of highway guardrail used as fencing. Axtel, 2024
The agenda for the meeting can be found HERE.
Checking the agenda prior to the meeting can assist those of you at home to determine when you might want to click on www.blm.gov/live to listen in. The entire meeting is live streamed over the course of two days, the third day is a field-trip to a correctional center and the field trip is not live streamed.
For instance: If welfare issues are something you want to hear the board talk about on January 7 at 4 p.m. PT, BLM will give their update and answer questions from the board. On January 8 at 11 a.m., the United Stares Forest Service (USFS) will give their update. We do find it odd that the two agencies will not be discussing welfare issues on the same day.
For those of you interested specifically in burros, on January 8 at 10 – 10:15 am to 11:00 am PT: Burro Ecology- Increasing our understanding of disease and migratory patterns of donkeys in Death Valley. (note: Death Valley burros are part of the National Park System, not covered by the 1971 Act or under the jurisdiction of the Advisory Board). Those of you that follow burros in the U.S. know that these burros have been maligned for decades and are too often shot. Research not being presented has also shown that burros in the Park are targeted by Mountain Lions and benefit other species. It is important to remember that none of this research is being applied to any BLM burro herd through any management planning (and management planning and updates have been illegally delayed in the vast majority of U.S, herd for both horses and burros, as our litigation has demonstrated in two court rulings in 2024 and expected to glean more confirmation of the neglect in 2025).
If you are thinking of listening in, check the agenda to determine when you want to tune in.
Crafting comments
When crafting comments to the Advisory Board it is essential that you phrase your comments in a way that fits the boards authority. The board has no actual legal authority. In other words: the board is not a decision making body. The only decision the board can make is how to craft a list of recommendations to either BLM or USFS. “Please recommend that BLM/USFS do…. ” and then state your reasoning for whatever it is you want the board to recommend.
The board can make recommendations on studies, policy and even on the way federal agencies structure advisory board meetings.
Samples of comments within the Advisory Boards purview:
- The board should recommend that BLM and USFS immediately create a designated task force to address the increase in shooting deaths of federally-protected wild horses and burros. BLM and USFS should prioritize increasing Law Enforcement presence in herds where shootings have occurred. The lack of prosecution of these egregious offenses is giving an impression that the law is meaningless, federal agencies do not care and increase the risks to the safety of members of the public that go out on the range to enjoy wild horse and burro herds.
- The board should recommend that BLM complete the process of formalizing welfare rules so they are enforceable. BLM created a draft, began a review phase and then simply said the draft was “final” and “policy.” The draft and review never went for public comment and then formalization as policy. The board itself will refer to the Comprehensive Animal Welfare Program (CAWP) as “policy.” However, in practice, even agency employees will stumble when discussing CAWP and not know what to call it: standard, program, policy? In our litigation it is still not clear what BLM considers CAWP. Please recommend BLM complete formalization of concise and enforceable welfare rules by putting out the standards for public comment and finalization.
- The board should recommend that BLM and USFS include facility reports as part of online gather updates. The backlog in unanswered Freedom of Information Act (FOIA) requests has been unacceptable for years. The majority of FOIA requests agencies receive have to do with disposition of horses and burros post-capture. Listing which facilities receive animals on a daily basis, how many, vet reports and death reports during active operations out to three months would cut down the FOIA backlog and save considerable taxpayer funding on the FOIA program and in litigation involving the FOIA program.
- The board should recommend the Adoption Incentive Program (AIP) be suspended. The board has recommended additional safeguards that BLM has said it would implement. The safeguards have done nothing to slow down the numbers of wild horses and burros being sent to sale barns immediately after title, indicating that the AIP still functions as a subsidy to the trade to slaughter of federally-protected wild horses and burros. Furthermore, the board should consider recommending that BLM suspend titling of wild horses and burros altogether so the animals maintain protection as “wild” for their lifetimes closing the loophole in this one simple act. Instead, recommend that BLM bring back the label of fostering an animal and provide a certificate that would allow the BLM to reclaim any horse or burro found in any kill-lot.
- The board should recommend that BLM prioritize creating and updating Herd Management Area Plans (HMAPs). Although no litigation update is part of the agenda, BLM has lost two lawsuits in 2024 and is facing more in 2025 on this very serious subject. The courts have clearly stated that removal/fertility control (population growth suppression) planning is not management planning nor are gathers. The board should soundly reprimand BLM for decades of ignoring this foundational management document. Prior to creating new gather assessments, the board should recommend that BLM craft HMAPs to tier those gather assessments in order to create sound management decisions (a mandate of the law). Simply perpetuating removals that do not tier to actual management planning is irresponsible.
You can use the samples above as a template to start creating your own comments if you are having trouble crafting your own.
Remember, if you want your comments considered at this meeting, you need to get them in 3 days before the start of the meeting on January 7. Email your comments to: blm_wo_advisory_board_comments@blm.gov
Wild Horse Education team members will be onsite at the board meeting and commenting in-person and virtually.
Our onsite team members will be addressing the fact that the board has never recommended BLM/USFS formalize welfare rules or addressed issues involving transparency such as creating online data portals for facilities specifically for post-capture statistics. Our offsite team will be addressing data, HMAPS and habitat loss. WHE will also submit written comments.
If you do not have time to craft your own comments, you can support our team onsite by adding your name to a letter that Colette Kaluza will submit onsite in Sacramento.
Click HERE to sign the comment letter
Thank you for helping WHE stay on the frontline in the fight to protect and preserve our wild horses and burros.
Categories: Wild Horse Education
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