Thank you for the opportunity to virtually speak today.. I am Marie Milliman M A R I E  M I L L I M A N and speaking on behalf of WHE as a volunteer and field representative.

I have personally observed Wild Horses on the range and during gather operations.

Wild Horse Education has documented roundups for over a decade. Our Documentation and litigation have been utilized to require the implementation of CAWP and access, engage federal personnel, and educate the public.

I appreciate the accepted practice in this meeting to present direct/blunt communications for expediency. For clarification to the board and public:  The BLM ONLY reports injuries in their gather reports that result in DEATHS exclusively within the gather process and the processing/temp holding facilities, the public is not informed of the overwhelming majority of other injuries and those that result in a death at a short/long term facility or in transit to them. The statistics are NOT complete. This is about a Humane standard of care practice, and for the Public to be fully informed via transparency. Per the comments from earlier today I would like to establish that The BLM is NOT training wild horses, they are HANDLING them. I heard reference of the need for information that was limited with the purpose to: calm folks down on what would be upsetting for observers or the public. This is about validity and accountability within the WHB program. CAWP’s intent is not only applicable for the capture process, it should also extend to the range and facilities…

WHE’s documentation and knowledge on Humane Handling is second to none. If everything was hunky dory, a judge would not have ruled against the BLM and in favor of WHE and the Wilds on Humane Handling and Access issues. WHE was left with no option but to litigate relentlessly and won. BLM’s actions represent that the only way to engage the policy is to litigate, which results in complaints about the cost of litigation from the very same agency that has failed to follow their established mandates and policies. BLM is skirting the mandate to manage humanely and abusing its authority. Our horses ultimately pay the price.

The BLM seems to cherry pick what standards/recommendations from organizations to use. Could you please clarify why the AVMA recommendation for sterilization is acceptable, but not their livestock smoke inhalation safety guidelines, nor accept the NAS review stating that spaying is not appropriate?

Out of the 117 pages of handouts: the word Humane was mentioned 8 times to sterilization, 3 times to transport, once to humane transfer, and once to safely and humanely handle wild horses. This is not a favorable representation of an agency that is serious about the Humane Handling Policy.

CAWP is a policy framework for compliance with the law. Personal opinion, expediency or simply being uninformed is not justification for one single wild horse to be captured without every effort being made to ensure its safety. All gathers should be conducted with complete public transparency, safety of the WHB’s and the adherence to CAWP and the WFRH&B act.

I ask that the board recommend:

• All BLM personnel that may serve as COR, IC, PI, and contractors during gather operations must be trained/retrained and on an annual basis demonstrate an acceptable level of comprehension in the parameters and importance, of CAWP (IM2015-151) and the confirmation of the initial/annual training be made public.
• The BLM is to develop an acceptable process for accountability on behalf of its employees and contractor’s actions that involves the management, Humane handling, and safety of WH&B’s.~~~~Help us stay in the fight.