October 10, 2024, Pacific Southwest region wild horse gather planned – motorized equipment hearing:

Testimony of Colette Kaluza, Wild Horse Education welfare team assistant director:

We know that usually what USFS does is to essentially copy BLM’s procedures and policies.

But when it comes to animal welfare, motorized vehicles, trailers, etc., could you please do what BLM has failed to do:  Craft clear-cut standards, put them out for public comment on what is humane and adheres to current veterinary standards, research and practice. Please finalize them as policy. This will create means of enforcement and consequence that is woefully lacking in the (better funded) BLM

Forest Service does not currently have an animal welfare program, but can lead the way on animal welfare and create a real policy through the policy-making process of rulemaking, which offers transparency and public feedback.  Our team has observed the following things at forest service roundups.

I have frequently observed and documented these events at gather and removal of wild horses by BLM.  These are some, but not all, of the repetitive and reoccurring events causing unnecessary injuries and death:

-Foals, pregnant mares, weak horses are helicopter-driven in conditions of mud, heat, cold, smoke and are not taken into consideration. Foals are being left behind on the range.  Helicopter is drive-trapping during foaling season.

-Helicopter pilot drives bands to trap even though a foal is under three months of age.

-BLM has failed to consider current veterinary standards, adopted a decade ago, for Heat Index and Air Quality Index.

-Helicopters come too close to wild horses and risk hitting horses.  Pilot crashed a helicopter while driving horses with horses under the chopper.  FAA investigation found pilot at fault for flying too low to the terrain.

-Helicopters drive horses to exhaustion and repeatedly press and evoke erratic behavior.

-Trap sites are not placed close to animals’ locations when possible to minimize the distance animals need to travel to prioritize safety.

-Helicopters land too close to trap and/or corrals holding wild horses.

-Traps are chosen that use unsafe roads.  Horses fall down in stock trailers and injure themselves.  Trailers are being driven carelessly and too fast.

– The drivers do not always stop and unload horses to allow assessment of the downed animal.

-Stock trailers are overloaded and floors are dirty.

-Horses are driven by helicopter into a trap and/or loaded onto a stock trailer with a recumbent animal present.

-Rival band stallions are loaded in the same trailer compartment and fight, particularly when adjoining mares.

-ATVs are being used to transport and/or rope horses.

-Gates are used as the prime tool to drive and move horses and paddles are used to hit the horses.

-Gather operations go too late in the day and parts of gather operation are not being conducted in daylight.

-Ramps leading into trailers have gaps.

This is in addition to comments submitted by Wild Horse Education for this hearing.