The Silence Is Deafening

This time they brought the issue to Washington. President Obama, you saw them in Reno, but made no response. You weren't in Washington while they were there, but how could you be unaware that they were there and what they wanted?

This brief statement by Paul Killington says it all. Did you hear him, Mr. President?

Did you see this on CNN, Mr. President? This is what's happening to our wild horses. We've been trying to tell you, but you don't seem to have heard us. The horses don't have much time left, Mr. President.

Here are some of the people who have been frantically writing to you, begging for help. Now they have come to Washington to plead the case for the horses. So what happened when they got to the Department of the Interior - these American Citizens exercising their right to peaceful assembly, paperwork all in order and nary a firearm in the entire group? They were met by armed guards - unfriendly armed guards - outside the door of the DOI. Then the Mounted Park Patrol joined the group, followed by Homeland Security and a motorcycle policeman. This for peaceful citizens carrying nothing but signs and information?

As they stood in front of the Mounted Patrol, facing the DOI, they could see people at the windows, but no brave soul ventured out amongst these horse hugging terrorists. Finally, someone did come down to get the packet of information from them, and probably ran all the way back up the stairs. It all made me so proud, Mr. President, of the Advocates. As for my country and its leadership - I don't believe I have ever been so sad and disappointed. Although, I suppose we should thank the DOI for providing those wonderful horses to help make the point.

On the other side of the Pond, our soul mates in London made their own demonstration in front of the US Embassy. We can never thank you enough, dear friends, for helping our precious wild horses. They obviously mean more to you than they do to their own government. The horses know. They always do.

The ball in in your court, President Obama. Do you remember your campaign promises that you were squarely for protecting our wild herds? But once elected, your ongoing silence has become a deafening roar as concerns and pleas for intervention continue to be meet with absolutely nothing.

The vast majority of us voted for you because of these campaign promises. You promised to protect our wild horses. Since you made that promise, so many horses have been removed from the ranges - or killed in merciless roundups - that there is real doubt as to how many are actually left in the wild.

We are waiting for you to keep your promise, Mr. President. The horses are waiting for your promised protection, Mr. President. They don't have much time.

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URGENT Alert From American Herds! URGENT!

American Herds: Two For One
Friday, March 19, 2010
Two For One
While juggling too many things at once, time slipped by and I never even opened the proposals until two days ago. With only just days left, here is what I found….

The U.S. Forest Service (USFS) simultaneously issued two press releases and two proposals, both related but neither mentions the other.

The first is a proposal to ram through the establishment of Appropriate Management Levels for 11 Wild Horse and Burro Territories (WHTs) that will be used forever more to round up any wild horses or burros that exceed these levels. The second is a notice that they will be preparing an Environmental Impact Statement to evaluate and re-authorize livestock grazing for much of these same areas.

Both are presenting skeletal information and ancient data at best and I have worked unsuccessfully for hours trying fill in the mountains of gaps these proposals are omitting from the public.

Before getting into the few specific details about the area I was able to glean during my research, it is imperative to explain how they are manipulating the public process here.

We have laws that mandate how the agencies must conduct themselves; laws that mandate quality data, accountability for agency actions, specific guidelines about what and how they must review proposals and how they must involve of the public in order to ensure our Nation doesn’t evolve into a dictatorship of secrecy and tyranny.

With that said, this is how they are trying to get around these laws….

First off, when the government proposes to do something, they must make an announcement in the Federal Register. This is the equivalent of the government’s newspaper and serves to conform to the requirements that the government must notify the public of an action. The Federal Register also serves as a legal record of the agency’s actions and establishes the legal parameters for the project.

Secondly, when a proposal is announced, the agency is suppose to follow set procedures on how they process the proposal, which include adequate opportunities for public involvement, honest evaluations of what they are about to do and must publish as current as information and data as they have available for sincere analysis.

Lastly, they are NOT suppose to issue proposals to the public that already contain foregone conclusions and completed decisions. In other words, the “evaluation process” is suppose to be just that: an ongoing analysis that includes public input and looks at options, tries to find alternatives that serve the greater good and reach decisions after they have analyzed all the data and input.

How this process evolves goes something like this…

First, they issue a notice to the public called a “Scoping Notice”. This is a very loose based overview of what they are going to do and they ask the public to provide comments to determine the scope of what the agency should consider, look at, include and develop alternatives in their preparation of the next phase of the process, which is the environmental assessment (EA).

From here, the agency collects everything they gathered during the scoping process and now assemble it in a more organized format that includes alternatives, what the issues are and - if there are problems - how to fix or mitigate them, as well as outlining as best they can the foreseeable consequences of what implementing these different alternatives will do.

Once assembled, the agency releases what is called a “preliminary EA” so the public has a more detailed document to review about what the proposal will really cover and how the different alternatives will achieve different results. The public is suppose to be provided another opportunity to provide input and comments, which generally extends for 30 days.

After the agency receives more public comments on the preliminary EA, they go back and write a “Final EA”, based on that input, and tweak the proposal further with the goal of refining it and making it the best possible plan they can. Again, the Final EA is released for public review, another round of comments and input is requested and finally, the agency, after having looked at all angles and incorporating as many concerns, finding solutions to problems that may arise, yada, yada, releases the final decision.

Now from here, there are two things that can happen. The first is, after all this review, the agency determines if the EA adequately addressed the action and concerns. They are required by law to go down a checklist of items of what has been deemed “significant”. If it is determined that the proposal will not significantly affect “the quality of human life”, they stop the analysis process and issue a Finding of No Significant Impact (FONSI), which essentially states the EA covered everything and its time to move on.

However, if this process revealed that the proposal was going to have a larger, more significant impact than they first suspected, then they are required to prepare an environmental impact statement (EIS) to examine the proposal more in depth.

The agencies loath to create EIS’s because they require a lot more data, analysis, take more time to prepare and grant the public even more time to review, ask questions and provide feed back in a mandated time frame of 90 days. Also, once a decision is issued that an EIS must be performed, the whole process starts again with a Scoping Notice, a Preliminary EIS and a Proposed EIS – all with adequate public involvement - and issuing a final decision is only possible after all of the requirements of the law, as described above, have been followed.

So with that background, here is what USFS is trying to do….

They issued two proposals, one for the WH&B AMLs and one for the livestock grazing.

The livestock grazing is being issued under a Scoping Notice to prepare an EIS, the big daddy of the proposals.

The WH&B proposal is being issued under a Scoping Notice to prepare an EA, the more minor version of analysis.

From this point on, they deviate from these legally mandated processes, as they blatantly announce in the WH&B AML proposal that:

“Preliminary analysis, displayed below, indicates that impacts to affected resources would be minor and short-term in nature (Table 4). The final results of the analysis will be displayed in the Environmental Assessment (EA) being prepared. If there is no potential for significant impacts, that finding along with the environmental assessment and a decision notice will be released for public information. If any comments are received on the proposed action then a 45-day appeal period will be provided after release of the environmental assessment and Decision Notice/Finding of No Significant Impact. If the environmental assessment concludes that there is a potential for significant impacts then an environmental impact statement would be prepared. Your comments will help us prepare an environmental impact statement”

The short version of this bureaucratic language is:

-Before USFS even released the very first Scoping document to the public, they have already made a decision that a decision will be issued at the same time the first preliminary EA is released.

-They have already decided that when it comes to establishing the WH&B AMLs, it is not a significant action and they will issue a FONSI – before the public ever even gets to see what they put together for the preliminary EA – the decision will already be issued.

-They have already decided that if the public has a problem with this, our only recourse is to take them to court during the appeal process. (And then they will cry later about how they are always getting sued by the “environmental fringe”, never mentioning how - if they weren’t riding roughshod over the laws they are suppose to be following - they might be able to cut down on these lawsuits significantly.)

Meanwhile, while analyzing wild horse and burro management and their impacts to the range is deemed insignificant and only worthy of a pre-decided EA, when it come to livestock grazing management, they are going to prepare a full blown EIS.

However, they are NOT going to consider both wild horses and burros and livestock in the same proposal. The current plan, as written, will ram the wild horse and burro AMLs through before they even look at the livestock grazing and so, the decisions on "appropriate" use by wild horses and burros will already be a done deal.

The reason they are doing this is so they won’t have to provide a document that analyzes wild horses, burros, wildlife and livestock grazing side by side - because if they do this, it provides two, very real problems they don’t want to have to address.

The firstproblem is, they don’t want a comparison document to show that livestock are getting the lions share of the resources while in many cases, wild horses and burros are being given only enough forage to cover “incidental use” (this means they 1-3 animals can be sighted occasionally on the livestock allotment but if any band tries to set up camp, they will be removed).

The second problem is, if they examine wild horses and burros in the same document as livestock, then they have to examine and develop an alternative that sincerely looks at and considers reducing livestock grazing to support sustainable wild horse and burro populations – and we can’t have that, can we?

What else are they trying to do to circumvent laws and public involvement?

Here are some other things I noted during my research of the Wild Horse & Burro AML proposal:

-They only offer two alternatives; not setting AMLs, which is illegal, and setting the AMLs they have already proposed based on input from BLM.

-They clearly state that, “Monitoring and management of the wild horse resource is outdated or non-existent”. Setting AMLs without monitoring and resource information is also illegal but that doesn’t seem to concern them here.

-The AML established in 1983 for the Little Fish Lake Wild Horse Territory and co-joining BLM Little Fish Lake HMA was “mistakenly” interpreted to only include horses" (not burros) and there is NO effort to remedy this mistake in the current proposal!

For extra added intrigue, USFS states the current AMLs for the Little Fish Lake have already been established in 1983 at: “Minimal AML” 64; simmer and winter occupancy by at least 16-28 wild horses”. However, they are proposing to INCREASE the AMLs to 80-139. Except, they also state that these wild horses interact with BLMs North Monitor and Little Fish Creek HMA and they want to limit wild horse populations from “overstocking” the BLM HMAs in the winter. What makes this kind of funny is, BLM has a maximum AML of 47 wild horses for these two HMAs, so is the numbers USFS proposing now at these much higher levels really correct?

-In some cases, the AMLs they propose are pathetically low such as 15-30 wild horses on 144,599 acres for the Toquima WHT, 3-8 wild horses on 13,025 acres in Northumberland (yes, 9 horses will be considered an “overpopulation”) or 8-16 wild horses on 20,902 acres in Kelly Creek.

-The map they provide to the public of the proposal area is so old and outdated, it included a Herd Area once known as Willow Creek that was re-zoned and incorporated into the Stone Cabin HMA years ago - as well as entirely omitting North Monitor and Hickson HMAs.

-During removal operations, public notices will only be provided in Eureka, Austin and Tonopah as to the dates of the removal operations and where public access will be restricted, which will be limited to roads near corral sites and within areas where horses are actively being gathered (no mention of burros made even though one of the areas they are setting new AMLs on contains only burros).

There’s a lot more information I would like to tell people about but the bottom line is, they just aren’t including it for public review and truly, this is a travesty of the system and processes established to prevent just this sort of thing from happening!

With that said, the public has three days to try and change the course of history here and whether they are going to get away with this or not.

First, public comments need to be submitted to the USFS about their livestock grazing proposal. Quite simply put, we need to demand that they set the wild horse and burro AMLs in the Livestock EIS so that we can compare the forage allocations between livestock, review rangeland health data, see how much water is in the areas and look at alternatives that would manage the wild horses and burros in equal consideration.

Second, we need to tell USFS the same thing regarding their proposal to set the AMLs for the wild horses and burros; that this needs to be done in conjunction with the livestock grazing EIS, not separately.

It is also very important to remind USFS that it is not appropriate (or legal) to already have reached a decision about what they are going to do before they even release the first EA to the public. At the very least, they need to provide an additional 30-day comment period after releasing the EA to allow the public to see some relevant information and sincere alternatives before they issue the Final Decision.

Here is the contact information and deadlines for public comments for each proposal.

Livestock Grazing EIS
Hot Creek-Monitor Rangeland Project
Deadline: Monday, March 22, 2010, 4:30 p.m. pst.

Submit comments to:
Austin/Tonopah Ranger District
District Ranger Steven Wiliams
Email at:

Wild Horse & Burro AML Proposal
Deadline: Friday, March 26, 2010 4:30 p.m. pst

While an email address was provided for the livestock grazing proposal, USFS didn’t extend this courtesy for the WH&B Proposal (imagine that….) However, Barbara Warner of American Horse Defense Fund tracked down an email address for the responsible officer at:,

Heather Mobley hmobley@fs.fed.us
Or Fax: (775) 964-1451

Links to the relevant USFS Notices/Documents:

Hot Creek-Monitor Rangeland Project

Wild Horse and Burro Appropriate Management Levels
Posted by Preserve The Herds at 5:05 PM

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March for Mustangs!

March for Mustangs

Rally for wild horses and burros in
Washington DC ~ March 25th 

Take Action for Wild Horses and Burros! Over 25 protests have taken place from coast to coast and now the hoofbeats are headed to Washington DC. Please join us on Thursday, March 25th in Washington DC: March for Mustangs. Take action today to save these incredible animals who are currently being managed to extinction on our public lands.
Cloud's Flag by Vivian Grant
Time: 1:00-3:00pm, Press conference and speakers at 1:30pm (Hope Ryden, author "America's Last Wild Horses," Filmmaker Ginger Kathrens, Author RT Fitch, Friends of Animals Director Priscilla Feral, In Defense of Animals President Dr. Elliot Katz, Filmmaker James Kleinert, mustang owner Jo De George and many more- including special guests to be announced!)
Where: Lafayette Park located directly across from White House at 16 Street and H Street, NW. Around 3:00pm protesters will march with homemade signs and large banners to the BLM office at 1849 'C' Street.
Friday: Mustangs on the Hill II - On Friday morning we’ll brief people on meeting with their Senators and Congressional Representatives to save the mustangs and burros. Please schedule an appointment with your US Senators and Representative for Thursday morning or Friday. More details will be posted on our events calendar soon.

Driving? Check out the Ride Share to connect with other advocates in your area to get to DC - Click here

Plus Disappointment Valley... A Modern Day Western  Special DC Screening of the new documentary on our wild horses and burros in the West by James Kleinert on Wednesday evening, March 24th from 6:00-8:00pm at Busboys and Poets. Ginger Kathrens will join James for a Q&A afterwards- please ask media to attend. Details here

DC Rally co-sponsored by The Cloud Foundation, the Equine Welfare Alliance, Friends of Animals, In Defense of Animals, Int'l Fund for Horses & many more with thanks to co-organizer Jo De George.
March for Mustangs images: Vivian Grant, Int'l Fund for Horses

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BLM Internet Adoption Starts March 10

This is absolutely the pits even for the BLM. They want you to send them a drawing of your facilities. I'm going to send them a drawing of my brand new barn and paddocks and my 8 foot fences.

I don't actually have any of these things, but I sure can draw them!

clipped from www.blm.gov
Buckskin Filly

The Next Internet Adoption Starts March 10

The March Internet adoption will be open March 10-24.   Electronic applications open March 8, bidding begins March 10.
If you are having trouble viewing the site, and use Internet Explorer, your browser may need to be updated.   On the Tools menu, click Internet OptionsOn the Advanced tab, under Security, make sure that the following check boxes are selected -  Use SSL 2.0, Use SSL 3.0, Use TLS 1.0.   Click Apply,  Click OK.


BLM's Final Solution for the Wild Horses and Burros

BLM's Final Solution for the Wild Horses and Burros

Originally Posted Dec 21, 2009 by Laura Allen

© Copyright Elyse Gardner

Horse Slaughter Information provided courtesy of Valerie James-Patton and Equine Welfare Alliance, http://www.equinewelfarealliance.org/

Internal documents from the Bureau of Land Management (BLM) shed light on the agency's motives and plans for the wild horses and burros.

Two reports issued by the BLM for internal use only, The Herd Management Option Plans from October 2008, and the Team Conference Calls Report from July-September 2008 contain astonishing proposals to manipulate the WFRHBA and NEPA, eliminate the wild horses and burros altogether from the wild, and until they can be euthanized or sold most likely for slaughter, sterilize them and place them in feedlots paid for by rescue organizations duped into thinking the animals are in private "preserves".

BLM is the agency within the U.S. Department of Interior that is tasked with protecting the wild horses and burros pursuant to the Wild Free Roaming Horses and Burros Act of 1971, 16 U.S.C. §1331 et seq. (WFRHBA) as free roaming animals in their historic herd areas and designated ranges. "All management activities are to be at the minimal feasible level." 16 U.S.C. Sec. 1333. Wild horses are not to be subject to "capture, "harassment" or "death". 16 U.S.C. Sec. 1331

BLM team members involved in these discussions included Jim Stratton, Rob Jeffers, Al Kane, DVM; Jim Johnson, John Neil, Lili Thomas, Gus Ward, Alan Shepherd, Bud Cribley, and Don Glenn.

These reports are almost certainly the precursor to BLM's current proposal issued by Interior Secretary Ken Salazar in October, 2009. The plan as announced is essentially to:

(1) work with non-profits and  wild horse enthusiasts to create "preserves" in the Midwest or east, an idea that runs counter to the  WFRHBA mandate to maintain free-roaming behavior and avoid zoolike settings for these wild animals,

(2) designate additional ranges that under WFRHBA are to be "devoted principally" to the wild horses and burros, but under BLM they have been afforded the same or even less preference than grazing cattle and sheep and other uses of the land, and

(3) work to restore the "sustainability" of herds and public lands which, translated  from BLM-speak, means more slaughter and euthanasia of wild horses and burros and extinction of the herds through continued removal of  wild horses from their herd areas and ranges, aggressive "fertility control", monitoring of sex ratios, and introduction of non-reproducing herds.

This proposal is floating around Congress and the Obama Administration. There has been no indication there will be a hearing or any changes made to the laws or authorization of appropriations that may be necessary to implement the plan. The full plan has never even been made generally available to the public.

Indeed, BLM has already begun to implement this plan.  The removal or gather schedules for 2009-2010 are aggressive, and BLM has shown no signs of reconsidering these plans despite increasing calls for a moratorium on gathers and a pending request for a preliminary injunction on a large gather of 2,432-2,736 wild horses in Nevada set to begin December 28.  Indeed, just a couple of days ago, BLM announced plans to roundup 1,977 wild horses and remove 1,506 from the Antelope Complex in Nevada. The BLM has yet to issue the Environmental Assessment for this action.

And, earlier during the first week in December, without any public announcement, BLM rounded up 217 wild horses on the Nevada-California border. This gather of what are known as the Buckhorn wild horses had been scheduled for the summer, 2010. The roundup was conducted in secret, and it is not known how many horses were injured or killed or what happened to them.

Currently, allegedly "excess" horses, those deemed necessary to remove from designated herd areas or ranges basically because of overpopulation or to "maintain a thriving natural ecological balance", are generally held in short-term (STH) or long-term holding facilities (LTH) on private lands. 16 U.S.C. §§1332, 1333 As of May 31, 2009 there were 8,532 horses and 57 burros in short-term holding facilities that have a total capacity of 15,645 animals. As of that date there were 22,126 horses in long-term holding facilities that have a total capacity of 22,100. The long-term holding facilities are full. BLM claims there are 10,350 excess wild horses and burros that must be removed from herd areas and ranges. Since 2000, BLM has removed more than 74,000 wild horses and burros from the wild, 40% of the population.

Manipulating the WFRHBA

In these 2008 reports BLM employees and consultants discussed placing the wild horses and burros in LTH facilities on public lands by converting grazing rights for cattle. To do this legally, requires changing the status of the horses and burros from wild to titled or owned livestock. The WFRHBA protects wild horses on public lands, meaning they can't be corralled in LTH there.  BLM team members discussed that to keep the animals in LTH on public lands, they would create non-reproducing herds:  "One could argue that a non-reproductive herd is not self-sustaining. Also refer to [43 CFR 4700.0-6  (c]) which states: "Management activities affecting wild horses and burros shall be undertaken with the goal of maintaining free-roaming behavior." By managing for sterile animals we may be taking away their "free-roaming" behavior by altering the social interactions."  If the animals are no longer ‘free-roaming", they are not wild and arguably could be considered livestock and kept in LTH on public lands.

In effect, BLM proposed to manipulate the WFRHBA by actually intentionally destroying herd behavior, free-roaming behavior, which as an agency they are supposed to protect, so that they could get around another provision of WFRHBA to allow the horses to be kept in LTH on public lands.

BLM team members also considered ignoring the WFRHBA prohibition on"relocat[ing] wild free-roaming horses and burros to areas of the public lands where they do not exist" but noted,  "However, a solicitor's interpretation concludes BLM is not prohibited from moving excess wild horses to LTH areas on public lands because no case law implies such a prohibition. Should BLM elect to move excess horses to LTH areas on public lands, appeals or litigation would be likely and could take years to resolve."

BLM team members discussed that the LTH facilities could be nothing more than feedlots. "BLM (or others? ie horse advocacy groups? would buy livestock permits with the objective of managing the allotments for a non-reproducing herd. Due to trouble finding additional pastures for excess horses, we may need to have feed lots. If the humane organization did take over payment of feeding excess horses they would need to pay for whatever type of facility is available."

Note that BLM's current plan as described by Interior Secy. Salazar, calls, in part, for humane groups to take over the cost and care of wild horses and burros placed in "preserves" in the midwest and eastern states. "Preserves" is presumably a euphemism for "feed lot".

In this way, BLM would also manage the animals to extinction. The BLM team member discussed, though, "This alternative may require a change in regulations based on 43 CFR 4700.0-6 (a), which states: "Wild horses and burros shall be managed as self-sustaining populations of healthy animals in balance with other uses and the productive capacity of their habitat."

Actually, for this plan to be legal, Congress would be required to repeal the WFRHBA requirements that BLM manage wild horses and burros as free-roaming "components" of the public lands at the "minimal feasible level" and avoid "capture", "harassment" and "death". 16 U.S.C. § §1331, 1332, 1333.

© Copyright Elyse Gardner

Aggressive sterilization and manipulation of herd ratios

Other plans discussed by the BLM team to reduce the wild horse and burro populations included adjusting herd ratios from 50/50 to 70/30 male/female ratios with some of the horses returned to the wild after being gelded and an increased use of PZP, as well as using other unauthorized fertility drugs called Gonacon and SpayVac.

Team members acknowledged Spayvac was "barely available" for research, let alone approved for use as a contraceptive.

With PZP the BLM Instruction Memorandum requires field officials to consider using fertility control and justify when it is not used. During a June 15, 2009 meeting the Wild Horse and Burro Advisory Board noted the liquid the longer term effectiveness of the pelleted form of PZP is unproven. It is also well known that PZP may cause out of season foals.

In the 2008 team reports, BLM team members noted, "This alternative may require a change in regulations based on 43 CFR 4700.0-6 (a), which states: "Wild horses and burros shall be managed as self-sustaining populations of healthy animals in balance with other uses and the productive capacity of their habitat.  ...One could argue that a non-reproductive herd is not self-sustaining.  Also refer to (c) which states: "Management activities affecting wild horses and burros shall be undertaken with the goal of maintaining free-roaming behavior." By managing for sterile animals we may be taking away their "free-roaming" behavior by altering the social interactions."

Despite the clear language of WFRHBA and some of its own regulations, the BLM team asked,  "Do we have an obligation not to affect horse herd behavior?...Does it affect behavior and do we care? Burger stated in the late 80's that you should aim at a ratio favoring females, but BLM thinks a 50/50 ratio is natural. Would having more stallions change the band structure, will mares and colts be beaten down at water bottlenecks? Since we do not have any evidence [changing the sex ratio] is bad, the BLM should be allowed to do this on a large scale. We do not know if it is bad so should we wait until we know?"

BLM team members discussed options such as filling herd areas with only geldings or sterilizing all mares. BLM also discussed placing wild horses in non-reproducing herds and wanted to look in each state for possible places for these herds.

In one discussion team members proposed it would be easier to "justify" a non-reproducing herd rather than zeroing out herd areas.

The idea was to eliminate a herd management area for every non-reproducing herd area that was created.
The team noted, "When making changes on HMAs (sex ratio, gelding, etc) the implementation would be a trial and error".

BLM knew the aggressive sterilization of mares would mean an increased death rate of at least 10% and admitted that "herd behavior would be out the window". BLM admitted, in effect, these aggressive sterilization plans would not only be potentially dangerous to the wild horses and burros, destructive of their herds and families, but also illegal and ultimately cause their extinction.

Euthanasia and Slaughter

The BLM team's favorite ideas for eliminating wild horses and burros appear to be euthanasia preferably in the field and also by reducing restrictions on sales.
The team considered, "How many could be euthanized at a gather without having a NEPA?" The BLM is required by National Environmental Policy Act ("NEPA"), 42 U.S.C. §§ 4321, et seq., to prepare Environmental Assessments or EAs or, if indicated, Environmental Impact Statements (EIS) or Finding of No Significant Impact (FONSI), for any proposed changes to public lands that may have a significant environmental impact.  The law directs the agency to identify environmental concerns, consider alternatives including no action at all and take a "hard look" at the problem and minimize significant environmental impact. A significant environmental impact includes actions that are likely to be highly controversial or have uncertain effects on the quality of our lives and that affect cultural and historical resources. 40 C.F.R. §1508.27(b).)

In other words, BLM hoped to be able to kill as many wild horses and burros in the field as possible without implicating NEPA.

BLM also discussed drastically reducing the time wild horses and burros are available for adoption or sale before they would then be euthanized.

The team observed, "People willing to put down healthy horses at gather sites could be a problem....Having vets put down healthy horses at preparation facilities could be a problem...Provide counseling due to stress for employees and contractors that have to euthanize healthy horses".

Team members also asked how many more horses could be euthanized without affecting disposal practices. It was noted that Reno Rendering, for example, "will take as many as could be sent". They checked on the capacity of other rendering plants to take more wild horses.

One team member questioned, "Are we euthanizing horses to save money to complete gathers?"

Under the WFRHBA,  "[a]ny excess animal or the remains of an excess animal shall be sold if--
      (A) the excess animal is more than 10 years of age; or
      (B) the excess animal has been offered unsuccessfully for adoption at least 3 times." Currently, a wild horse or burro must be offered for adoption at 3 specific satellite or adoption events before qualifying for sale under subsection (B). Wild horses and burros sold in this way are called 3 strikes horses. Animals sold under this provision lose the protections of the WFRHBA. 16 U.S.C. §1333(e).

Adopters can take possession of 4 wild horses or burros at a time and title is not transferred for at least one year. 16 U.S.C. §1333(c) Only then do the wild horses or burros lose the protections of WFRHBA.

The team notes indicate, "The team needs to address selling horses without limitation....We need to make horses easier to [sell] by changing our policy on the criteria for what constitutes a three strikes horse."

The team discussed selling eligible horses at the gather site.

The team discussed that a horse would get a "strike" after each adoption event and also each 30 day period where a facility is open to the public by walk up or by appointment. In that way, BLM could say the horse had been offered unsuccessfully for adoption at least 3 times for a period of 30 days, even if no one ever even looked at the horse let alone considered the animal for adoption. After the third 30 day period of unsuccessful adoption offers, the horse would be euthanized on day 31.

A note from a team member states, "Sally had an e-mail from a person in Canada who wants 10,000 horses that he would slaughter the horses and send them to a third world country.  Don is going to send the email....Making horses easier to sale by changing policy on the criteria for what constitutes a 3 strike horse, which could be horses that have been in facility for 90 days or 3 weeks. Jim said he has a demand for horses going to Denmark, but they are having a problem getting titled horses."

Another note advises, "Address the need for congress to change the adoption law and allow instant title."

Notes from a June 15, 2009 Wild Horse and Burros Advisory Board meeting indicate "that BLM [should]advertise and market sale eligible animals (with the intent clause) in foreign countries with known good homes by offering "select sales" for sale eligible animals 11 years of age and over, and for younger animals that have been offered for adoption three times during a 90 day period and that BLM continue to explore opportunities to foster foreign aid by providing sale eligible animals (with the intent clause) to foreign countries for agricultural (nonfood) use."

Only BLM would call a slaughter house a "known good home". The BLM is obviously in contact with kill buyers, those that buy horses and transport and sell them to slaughter houses. Despite the mandate of the WFRHBA, BLM, the agency charged with protecting wild horses and burros as free roaming components of the public lands at the "minimal feasible level" is clearly attempting to smooth the way for their slaughter.

During its discussions in the past year BLM considered ways to keep the public away from round ups and the killing and sales of healthy horses and burros and planned to brand protests as "eco-terrorism".  This was all to be done in secret. Unless Congress or the courts step up and stop this rogue agency, it looks like BLM's plan may succeed.

© Copyright Elyse Gardner

© Copyright Craig Downer

Go here for information about the WFRHBA and how BLM has eroded the protections for the wild horses and burros
Go here to find out how you can join the call for a moratorium on BLM roundups of wild horses and burros.

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"From my earliest memories, I have loved horses with a longing beyond words." ~ Robert Vavra