Sunday, December 28, 2008

BLM Opens Nominations for Advisory Board

There has been much talk about the Bureau of Land Management's (BLM) Wild Horse and Burro Advisory Board. In 2007 the BLM accepted more than 50 nominations for the 2008 vacancies on the board. A year later and long after the current appointments expired, no appointments have been made. Not only that, but the Board has met and voted on controversial subjects with the former appointees voting as thought their appointments were valid and not expired.

Why this is happened is subject to some debate. When questioned the answers vary widely. One response was that all of the nominations were "lost". Another response was that the USDA was holding the files and hadn't released them back to the BLM. (The Advisory Board reports to the Secretary of the Interior, Director of the BLM, Chief of the Forestry Service and the Department of Agriculture.) Another answer is that all nominees were rejected and the sitting members have been reappointed. Still another answer is that the appointees sit on the board at the discretion of the Secretary of the Interior and the terms have been extended until new appointments are made. Whatever the excuse, and none of these are acceptable, the Board should not have met until proper appointments were made.

In late 2009 3 more appointments expire. The BLM is calling for nominations for the postions of Wildlife Mangement, Humane Advocacy and Livestock Management. The deadline for nominations is 17 February 2009 and individuals and organizations may nominate one or more individuals that they feel are qualified to fill the positions open.

To nominate an individual you must submit a nomination letter(s) plus resume that include the nominee’s name, address, profession, relevant biographical information, references, endorsements, and specific category of interest.

The key here is that they are asking for ENDORSEMENTS. This means that each nominee should be endorsed by a professional organization from the field in which they are going to serve. In the last round of nominations we recommended that several nominees be put forward and we again recommend this plan of action for the Humane Advocacy postion. However, these nominees should be supported by an organization which will make this a little more difficult. I (Shelley Sawhook) have been asked to be a nominee for the position and any organization or individual who would like to nominate me will need to email me directly at president@ahdf.org for my resume. If anyone would like to endorse me as a nominee please contact me as well so my resume can properly reflect that information.

If you choose to nominate another individual I highly suggest that organizations decide on their nominee quickly to ensure that your nomination is received in plenty of time. If you are an individual seeking a nomination that you seek out endorsement early to be seriously considered for the position. February seems like a long way off, but paperwork can cause delays and you don't want all your work to have been done in vain.

Nominations should be sent by February 17, 2009, to the National Wild Horse and Burro Program, Bureau of Land Management, Department of the Interior, P.O. Box 12000, Reno, Nevada 89520-0006, Attn: Ramona DeLorme, or fax: (775) 861-6618. Individuals who use a telecommunications device for the deaf (TDD) may contact Ms. DeLorme at any time by calling the Federal Information Relay Service at 1–800–877–8339.

Thursday, November 27, 2008

Thanksgiving and Helping the AHDF

I hope everyone had a great Thanksgiving day and that includes our four hooved friends as well. While mostly we talk about the negative, but honestly we have a great deal to be thankful for. The slaughter plants in this country are all closed, the wild horses have had a reprieve, more and more people are becoming aware of the issues facing our beloved equine and we are among people who care.

I know that tomorrow morning is the official start of the holiday shopping season. I know that many of us don't have the disposable income we have had in previous years. All non-profits are suffering right now and the AHDF is among them. But rather than asking for donations, although those are ALWAYS welcome, I am asking that if you are doing online shopping use the AHDF Mall or one of our other resources where AHDF gets a portion of your purchases. Many if not all stores are offering the same early specials online as in the stores and most are offering specials only available online. So visit us at http://www.mypowermall.com/mall/113800 and help AHDF with your purchases. You can also shop at iGive, http://www.igive.com and specify AHDF as your charity. The AHDF also has many cute and funny items for sale at our Cafe Press store at http://www.cafepress.com/*HorseDefense*. Finally, R9 Custom Horse Creations offer a program where you can buy custom saddle pads and the proceeds go toward feeding the horses in AHDF's care. So, simply by shopping for your holiday items you can help the AHDF, what could be easier?

Again, I hope everyone had a happy and full day with family and loved ones. I know I did.

Sunday, November 16, 2008

History Repeats

I am sure that everyone has heard the saying that "If you don't learn from history you are doomed to repeat it". That is why Save Our Wild Horses has been working so hard find the historical data to add to the site. During our search we have come upon a number of articles that show how the BLM has managed our wild horses illegally. Most of the stories are not news to those who have worked on the wild horse and burro issue since the beginning, but sometimes we need a reminder of the history so we can prevent repeating it.

The first series of articles is dated only 2-3 years after the passage of the Wild and Free-Roaming Horse and Burro Act. They were so horrific that they triggered a congressional investigation and became a part of the congressional record. Below is part of that record. It shows that the BLM has not acted and has never acted in the best interest of the horses within its care.

From the Chicago Tribune, June 9, 1974

The Roundup that Became a Slaughter

(by Robert Young)

“So that is what we did… I mean it was gruesome… we sawed that one Sorrell mare’s legs off with a chainsaw, and now that’s the truth,”--- Idaho rancher’s narrative of a range horse roundup

Washington,---The country around the Lost River and Lemhi mountain ranges in eastern Idaho is rugged and remote.

And it is country where a roundup of a herd of free-roaming horses near the town of Howe more than a year ago has attained nationwide notoriety.

Animal protectionists are outraged over the roundup’s bloody brutality as recounted by ranchers who took part. The government is accused of sanctioning a roundup in violation of a federal law protecting the West’s wild horses.

The roundup took place intermittently during January and February of 1973. In March of that year, the Interior Department’s Bureau of Land Management (BLM) and the Agriculture Department’s Forest Service started a joint investigation. Their probe was completed last January and a report turned over to the Justice Department---a report made public only late last month.

The federal inquiry into the Howe roundup followed protests from the Washington-based Humane Society of the United States and American Horse Protection Association that the 1971 Wild and Free-Roaming Horses and Burro Act was violated.

That law protects wild horses and burros on government-owned range lands in Western states under the jurisdiction of the Bureau of Land Management (BLM), and the Forest Service.

William B Robison, a local cattleman, in the late fall of 1972 began to organize a roundup of 50-60 horses which he claimed were owned by himself and other ranchers.

In December 1972 ranchers met with Walter (Ed) Jones BLM district Manager and former cattleman, to discuss government regulations issued under the wild Horse protection law, as well as Robison’s roundup. According to those attending the meeting, Jones took Robison’s word that the horses were privately owned and said if that were the case, they were in trespass on public grazing lands and should be removed.

A month later, helicopters were used in two unsuccessful attempts to drive the horse herd into a corral trap. A third attempt, this time using a small airplane to “haze” the animals, also failed. Only one horse, a white stallion, was captured. Federal statues enacted prior to the 1971 law prohibit use of aircraft or motor vehicles to harass, capture, or kill wild horses.

The roundup by then was attracting more than local attention. William Stauffer, a Howe resident, was convinced that the horses were wild. Stauffer both inquired at the BLM District office and wrote a letter to Sen. Frank Church (D) Idaho. Church’s office asked the BLM what was going on.

Robison meanwhile had enlisted the help of Bill Yearsly, a horse dealer from the nearby town of Blackfoot, and Max Palmer, a horse trader from Sugar City.

A party of ranchers on horseback made a fourth attempt to round up the herd, but only 6 animals were captured and taken to Palmer’s ranch. The government investigation showed that 5 of the horses were unbranded.

Yearsly later recalled that at this point, he wanted to abandon the roundup, but Robison urged him to continue, saying he was being pressured by Jones to get the horses off the public range. The horse dealer also quoted Robison as saying that if the horses could not be captured, they were to be shot.

Palmer led a party on a fifth attempt during the 3 days of Feb. 17 thru 19 and trapped 21 horses at the edge of a cliff. Yearsly and others went into the trap Feb. 19 with “hog rings”---metal devices clamped into a horse’s nostrils to hinder and make the animal more manageable.

According to the accounts of those there, 4 of the trapped horses by then had fallen over the cliff to their death’s and 3 others had wedged horses so deeply in rock clefts they could not be freed. The throats of the 3 animals were cut with a hunting knife and their legs cut off with a chainsaw so the carcasses could be pushed over the cliff.

By Feb 25, another 20 horses had been captured and taken to Palmer’s ranch. Three other horses broke their legs trying to avoid capture and Palmer shot them. Palmer later reported he also noticed the carcasses of two more horses, dead from unknown causes.

Robert Amy, one of the ranchers participating in the roundup, was questioned by BLM and Forest Service Agents on Jan. 9th this year and said Jones, the BLM district manager, had told the local cattlemen that “They had better do something” about the horse herd. Amy said the cattlemen agreed something had to be done about the horses running loose on grazing land, but felt they “couldn’t live” with the wild horse protection law.

According to the BLM-Forest Service report, 34 of the horses surviving the whole roundup were shipped to Robison on March 1, 1973, to North Platte, Neb, to be slaughtered for dog food. The animals were cleared for shipment from the stockyards at Rexburg, Idaho by a state brand inspector even tho they were not branded and Robison had no bill of sale to show he had acquired them from private owners. The inspector said he was not familiar with the state law dealing with unbranded livestock.

As soon as hey learned of the roundup and shipment of the horses to North Platte, the Human Society of the United States, the American Horse Protection Association, and Mrs. Velma (Wild Horse Annie) Johnston of Reno, NEV., president of Wild Horse Organized Assistance (WHOA), protested to BLM officials in Washington. BLM interceded and 17 of the horses and 2 colts were shipped back to Idaho Falls where they are still being stabled and fed at BLM expense.

Palmer, the Sugar City Horse dealer, said that most of these animals belong to him. But, Sen. James Abourezk (D), S.D. and Rep. Gilbert Gude (R), Md. have filed a counter-claim that the horses belong to the American people.

Robison also told government investigators that the horses were near starvation and wouldn’t survive the winter because the range couldn’t support them.

BLM officials concede that Jones, who retired last month, encouraged the Howe roundup and failed to observe proper procedures when he made the judgment on his own that the horses were neither wild nor unclaimed and thus not protected by the wild horse law.

The American Horse Protection Association and the US Humane Society are relentless in their determination that a horse roundup will not happen again, that the law will be enforced, and those who violate it will be punished.

In April, 1973, the two organizations filed suit in the District of Columbia Federal Court against the Interior and Agriculture Departments, the BLM and Forest Service, and 13 individual officials. The complaint charged that the defendants failed to enforce the wild horse protection law and not only allowed, but encouraged, the illegal, “grisly and inhumane” horse roundup. The suit asks $10 million in damages, with any money awarded by the court to be placed in trust for the protection of wild horses and burros and the enforcement of existing protective laws.

The civil suit was filed after the Justice Department decided there was not enough evidence for criminal prosecution.

Mrs. William L. Blue, vice-president of the American Horse Protection Association, and Frank J. McMahon, the Humane Society’s Investigation director, scoffed at the Justice Department’s assertion that there is not enough evidence for prosecution.

Mrs. Blue accuses federal officials of “total indifference” in enforcing a law Congress intended to be a National Heritage and living symbols of the old American West. Mrs. Blue asserts that even tougher protective legislation is needed because wild, free-roaming horses have been fast disappearing. Their number is estimated to have declined to 17,000 to 20,000 from 2 million at the beginning of the century.


The next series of articles was the highly publicized articles written by Martha Mendoza from January 1, 1997.

Roundup is Beginning of End for Herds.

By Martha Mendoza

Reno, Nevada--A multimillion-dollar federal program created to save the lives of wild horses is instead channeling them by the thousands to slaughterhouses, where they are chopped into cuts of meat. Among those who might be profiting from the slaughter are employees of the Bureau of Land Management (BLM), the agency that administers the program. These are the conclusions of an Associated Press investigation of the U. S. Wild Horse and Burro Program, which has rounded up 165,000 animals and spent $250 million since it was created by Congress 25 years ago.

The program was intended to protect and manage wild horses on public lands, where they compete for resources with grazing cattle. The idea: Gather up excess horses and offer them to the public for adoption. Nothing in the law prevents anyone, however, from selling horses to slaughterhouses once they gain ownership. While it is common for old or lame horses to go to slaughter, nearly all former BLM horses sent to slaughter are young and healthy, according to slaughterhouses.

The program’s rules let anyone adopt up to four horses per year, paying $125 for each healthy animal. If the adopters properly care for the horses for one year, they get title to them in the form of BLM certificates bearing a number freeze-branded into each horses hide. Using freeze-brand numbers and computer records, the AP traced more than 57 former BLM horses sold to the slaughterhouses since September. Eighty percent of them were less than 10 years old and 25% were less than 5 years old. Horses are often ridden well into their twenties. At the Cavel West Slaughterhouse in Redmond, Ore., for example, the proprietor, Pascal Derde, displayed a sheaf of BLM certificates for horses he recently butchered and sent to Belgium for human consumption. Asked about the AP’s findings, Tom Pogacnik, director of the BLM’s $16-million-a-year Wild Horse and Burro Program, conceded that about 90% of the horses rounded up go to slaughter. Has a program intended to save wild horses, as a symbol of the American frontier, evolved into a supply system for horse meat? "I guess that’s one way of looking at it,""Recognizing that we can’t leave them out there, well, at some point critters do have to come off the range."

Clifford Hansen, a former U.S. senator from Wyoming who introduced the bill to create the program, said he now wishes he could remove his name from the legislation. "The law was intended to recognize the significance of wild horses and burros," said Hansen, now 84, "but talk about a waste of public funds!"

The government spends up to $1,100 to round up, vaccinate, freeze brand and adopt out a horse. Although adopters pay $125 for each healthy horse, a lame or old horse can be bought for as little as $25, or even acquired free. After holding the horses for a year, adopters are free to sell them for slaughter, typically receiving $700 per animal from the slaughterhouse. The sellers find no shortage of horsemeat buyers. The demand for American horsemeat has long been strong in Asia and Europe.

Government officials offered conflicting opinions on whether it is legal or ethical for BLM officials to adopt and sell wild horses.

The AP matched computer records of horse adoptions with a computerized list of federal employees and found that more than 200 current BLM employees have adopted more than 600 wild horses and burros. Some of these employees, when contacted, could not account for their animals. Others acknowledge that some of their horses were sent to slaughterhouses.

In Rock Springs, Wyoming, the BLM corrals are run by Victor McDarment, whose crew rounds up horses from open ranges in Wyoming and arranges adoptions. According to BLM database records, McDarment has adopted 16 horses. His estranged wife adopted nine. His children adopted at least six. His girlfriend adopted four. His ex-wife adopted one. His co-workers in the corrals and their families adopted 54. McDarment said he could not account for the whereabouts of all the horses. "I don’t keep track," he said. Some ended up with Dennis Gifford, a Lovell, Wyoming, rancher and rodeo contractor who said he has tried to breed them for rodeo stock. He said he is sure some of McDarment’s horses were slaughtered. They have to end up somewhere, Gifford said.

Federal law prohibits U.S. government employees from using public office for private gain. The U.S. Office of Government Ethics said this means BLM workers are not allowed to profit from BLM programs. But Gabriel Paone, the Interior Departments ethics official in Washington, said there is nothing wrong with BLM employees adopting wild horses and then selling them for profit. "They’re not doing this as public officials." Paone said. "They’re doing this as private citizens."

The federal government is conducting several reviews of the Wild Horse and Burro Program, with two audits and two reports to Congress expected to be completed in 1997. "I welcome the scrutiny," Pogacnik said.
Pogacnik said. "It can only help."


The last is more recent and it is copyrighted so I cannot post it here. It comes to us from the Quarter Horse News and is about the Jackson Mountain Horses. The BLM failed to act appropriately and 185 horses died during and after the horses were removed. You can read the story by going here.

The Secretary of the Interior is supposed to oversee our wild horses. Instead over 19 million acres have been removed from the program, in violation of the law. The population level of horses, otherwise known as Appropriate Management Level (AML), is arbitrarily set with little or no scientific data to support it and most data has been manipulated. In fact, the law requires that each herd area should be self-sustaining, and since 90% of the herd areas are set below genetic viability, the law isn't being followed.

The BLM is not appropriately managing our wild horses and they never have. We MUST take action to protect them before they no longer exist. Please call your Senators and your Congressperson and ask that Congress investigate the management of our Wild and Free-Roaming Horses and Burros. To find your Senators and Representative visit the Save Our Wild Horses website. The site also offers sample letters to jump start your communications, but remember letters, emails and phone calls are most effective if they are in your own words.

Action Needed

On Monday 10 November I posted about the GAO report. In that post I talked about how to protect the horses. However, the call for action was deep in the post, so some may have missed it. I know they have because today I got an email asking about the bill mentioned, which will probably get a vote tomorrow. The bill, which is an appropriation bill (governmental budget bill), WILL pass. It is up to us if it passes with bad things in it or if it passes the way we want it to. Below is the relevant part of the post.

For these reasons and many more it is imperative that EVERYONE contact their Congressperson and Senators and ask for answers. Nothing will answer these questions other than independent assessment of the wild horse and burro population and a full Congressional investigation. The American Herds report should be cited as a comprehensive investigation that shows that the BLM census numbers are not accurate, but not because they underestimate but because they are inflating the number of horses in the wild. Since there are such widely differing census numbers it is important to determine what the correct population is. Until such an assessment is done and until a Congressional hearing is held the BLM should be prevented from killing a single healthy animal in holding facilities. Wording should be included in the Omnibus Public Lands Management Act, S 3213 to prevent the BLM from using any of their budget to "euthanize" healthy animals. Please pass this along to your friends, relatives and anyone in your address book. The lives of over 30,000 horses depend on our voices, please do not let them die because the GAO failed to do its job properly or because the BLM improperly manages the program.

S 3213 also includes language that will remove the protections that Wild Horse Annie gained for the horses, by allowing the unlimited use of aircraft, including helicopters, to remove horses. It also changes their determination from Wild and Free-Roaming to "feral". Legally this is devastating to the protections of our wild horses and burros. This is found on page 107. An amendment can and should change this.

To find your Congressperson and Senators visit the Save Our Wild Horses website or the House and Senate websites.

I don't normally beg, but in this case I am BEGGING everyone to act, the fate of our wild horses depend on it. Remember that you can't ask that the bill not pass, you must ask for AMENDMENTS to the bill.

Monday, November 10, 2008

GAO Report

For the last month many of us have eagerly awaited the public release of the GAO's report on the Wild Horse and Burro Program. We just knew, based on their previous investigations, that they would do an incredible and in-depth report based on their previous investigations. In our minds we just knew that while it might not come down fully on the side of the horses, it would be fair and truthful. The BLM must have had such a hard time not to laugh in our faces.

While we had to wait more than 30 days after its release to Congress, the BLM knew what it was going to say before it came out. The GAO took surveys of BLM field offices and the report reads as if it came directly off the BLM website, and I believe that parts of it did. There was no real investigation of facts and documents provided by humane groups were ignored, especially if there was anything that conflicted with the BLM's "official" position. Of course the worst part of the report, the one that basically demanded that the BLM begin the wholesale killing of healthy wild horses in holding facilities, wasn't even expressed on the BLM site.

If you haven't yet read the report you can find it on our website or the GAO's site. Everyone should read it, our taxpayer dollars paid for it. But after reading it one has to wonder why it took months to prepare since it is full of BLM quotes many of us have heard before.

One of the things one has to wonder about is why the report repeatedly spoke about the BLM's census methods. According to the report, the census methods used by BLM are not only not accurate, but are under-estimating herd sizes astronomically. The method can only UNDER estimate, not over estimate. The method used by BLM are direct count plus a percentage for unseen animals and increased each year by a percentage to account for foals. This is the method the BLM stood behind for years saying that it was accurate + OR - anywhere from 15-20%. Now the GAO report says that the method is so inaccurate that it may account for hundreds of uncounted horses. They fail to follow with the logic that if it is so inaccurate the BLM should reevaluate the AMLs as the range has shown that it could support more horses than originally thought.

The report cites the Jackson Mountain HMA as an example. During the Jackson Mountain fiasco over 185 horses died during the removal and holding. The report erroneously cites 150. The claim is that the BLM grossly underestimated the number of horses on the range by 640 horses. They fail to mention that the BLM claimed that they were closely monitoring the herds in the Jackson Mountain HMA due to numerous reports that the water sources were not properly filling and horses were frantic to find water. They also failed to note that the neighboring Sheldon Wildlife Refuge "lost" over 400 horses that may have been migrating between the two areas. When humane groups and individuals repeatedly asked Sheldon and BLM where over 400 horses could have disappeared to, their requests for information went unanswered. By the way, during the time the horses disappeared fences were repaired between Jackson Mountain and Sheldon, so if the horses had traveled onto BLM land they would have been trapped there with no water. One single incident cannot prove that the entire BLM census method underestimates EVERY single time.

On the contrary, it is not only possible but statistically probable that they could just as easily OVER estimate census numbers. If one looks at the report prepared by the American Herds, it is not only possible but probable that the population still roaming our public lands is 20,000 fewer than the BLM estimates. American Herds looks at the way BLM calculates the population of horses and using their own methods comes to much lower number than the BLM and below their arbitrarily determined Appropriate Management Level (AML).

The determination of AML is important because it determines how many horses are removed from the range. If the AML is set too low, as it is in many areas where the AML is below 40 horses, horses are removed unnecessarily and put into holding facilities. If the GAO is looking at how to handle the horses in holding facilities they should have looked at the fact that they may or may not have been gathered improperly. This is especially true when they are basically saying these horses should be euthanized. That should be the last resort as the law states, not the answer to issues that are as yet unresolved. It is possible that these horses should be returned to their rightful place on the range and not held and certainly not killed.

The GAO also failed to recognize that the BLM has zeroed out herd areas in violation of the law that states that the horses are to "be managed WHERE THEY ARE FOUND" (emphasis added). For them to have decided for convenience sake that herd areas should be closed or horses not returned after disaster is not within their jurisdiction. The law trumps policy. In addition, the BLM has removed around 30 MILLION acres from the wild horse and burro program. Certainly the 30,000 horses in holding, or at least a large majority, could be returned to the range if this land is once again added to the program. Then the taxpayer wouldn't be footing the bill for their care at these facilities and the horses would be where they belong. Since most if not all stallions are castrated when they enter the holding facilities, it isn't likely that they would be genetically viable, but it is far better than their death.

For these reasons and many more it is imperative that EVERYONE contact their Congressperson and Senators and ask for answers. Nothing will answer these questions other than independent assessment of the wild horse and burro population and a full Congressional investigation. The American Herds report should be cited as a comprehensive investigation that shows that the BLM census numbers are not accurate, but not because they underestimate but because they are inflating the number of horses in the wild. Since there are such widely differing census numbers it is important to determine what the correct population is. Until such an assessment is done and until a Congressional hearing is held the BLM should be prevented from killing a single healthy animal in holding facilities. Wording should be included in the Omnibus Public Lands Management Act, S 3213 to prevent the BLM from using any of their budget to "euthanize" healthy animals. Please pass this along to your friends, relatives and anyone in your address book. The lives of over 30,000 horses depend on our voices, please do not let them die because the GAO failed to do its job properly or because the BLM improperly manages the program.

To find your Congressperson and Senators visit the Save Our Wild Horses website.

The BLM Wild Horse and Burro Advisory Board is meeting next Monday, 17 November 2008 at the Silver Legacy Resort Casino’s Reno Ballroom, 50 East Fourth Street, Reno, Nevada from 8am to 5pm local time. Comments should also be submitted to them asking that they NOT approve any motions to euthanize healthy animals in holding facilities. Those who would like to comment but are unable to attend may submit a written statement no later than November 12, 2008, to: Bureau of Land Management, National Wild Horse and Burro Program, WO-260, Attention: Ramona DeLorme, 1340 Financial Boulevard, Reno, Nevada, 89502-7147. Comments may also be e-mailed to: Ramona_DeLorme@blm.gov . Those submitting comments electronically should include the identifier "WH&B" in the subject of their message and their name and address in the body of the message.

The Commission for the Preservation of Wild Horses is also meeting 14 November 2008 at the Winnemucca Convention Center at 50 West Winnemucca Blvd in Winnemucca, Nevada from 9am to 11am. They should also receive comments.

Thank you for your time and dedication and PLEASE forward this far and wide.


Friday, October 31, 2008

Time off- What's that?

Congress is not in session and the bills to ban horse slaughter and to restore the protections for our nation's wild horses are not going to be heard until they are reintroduced next session. So, one would think I wouldn't have much to do right now and could take a break. WRONG!

It seems as busy today around AHDF as it does during a Congressional push. Not with the same things, but nothing is ever quiet in the horse welfare world. We are heading into winter the time when horses are most at risk for neglect. The BLM continues to remove horses at an alarming rate, although they have for a short time (because of budget constraints) stopped "emergency" removals. I have worked during holidays, children's birthdays and anniversaries. It is never quiet and people should never forget the issues and that this is the hardest time for all of us, winter. And certainly this downturn in the economy isn't helping at all. Besides, we need to prepare for the next Congressional session so we are at our most effective so we can finally see our bills passed.

I am in the process of writing a booklet to help others when the new Congressional session begins. It is a sort of "how to" booklet on how Congress works and how to make your voice heard. The most questions I get are on these issues. I guess it isn't hard to tell that this is an area that I love and follow, but our government can be confusing to the average person. Hopefully, it will help those with questions and make us even more effective when the bills are once again up for vote.

Also, I noticed that some really good people were suffering. They are losing their homes, jobs and just about everything else. These people, who normally would do anything for their horses, are facing tough decisions. They know about slaughter and they know about abusive owners because we are getting pretty good about getting the issues out there. These people need to know about the Alternatives to Auction and Slaughter book. The book isn't just for those who are considering selling their beloved horses this route, it offers ideas and suggestions that can help any owner facing tough decisions. In the book is a Protective Bill of Sale and a Protective Lease Contract, ideas of what to do with your horse if you can no longer keep it, how to raise the funds to euthanize and lots more. The book is available for purchase on AHDF's website for $5 (to cover the cost of hosting and updating). However, if someone is facing financial difficulties and cannot afford the cost of the book if they just email me I will provide them the link for the download for free. Unfortunately we no longer have the book available in printed format.

Please consider donating to AHDF so we can keep the book available to those who need it the most. There are so many reasons to donate to AHDF, the resources we offer like Horse Care Online, Save Our Wild Horses; the work we do legislatively and legally and the assistance we offer to rescues. We would like to also start other programs to assist owners like those who simply cannot afford euthanasia, but cannot with our donations at their current level. If you would like your dantion used for a specific purpose please note that on your check or your Paypal payment and we will see that it is used for that program. The AHDF is a 501(c)3 recognized non-profit organization meaning your donations are tax deductible.

No matter what we continue to be busy. I look forward to a day when I can take a break, not because I like to lay around eating bon-bons but because it would mean horses are no longer at risk for slaughter or abuse. But it isn't likely to happen anytime soon, if ever.

Monday, September 15, 2008

New Website Opens

The American Horse Defense Fund (AHDF) announces the new website www.SaveOurWildHorse.com is now live!

The website is designed to be a resource for information on wild horses and burros for the average person or for those looking for information on responding to the Bureau of Land Mangement's (BLM) public comment requests. The site serves as a repository of information no longer found on the BLM's website and other resources that users may find useful.

The site launch is especially important considering the recent announcement of the BLM that they are considering euthanasia as an option for wild horses and burros in holding facilities and on the range. The BLM is still considering removing even more horses from the range despite budget difficulties that they claim resulted in the need to consider euthanasia. Public comments are currently being accepted in a few herd areas and those wishing to comment may wish to research their responses on the new site.

The site includes information on how the public can help protect the horses, a section for children an extensive resources.

The launch is the culmination of months of work by the AHDF volunteer staff. The staff plans on adding more resources to enhance the use of the site in the coming weeks.

Wednesday, September 10, 2008

The Depths some people will stoop to

Periodically I get reports on what happens at auctions. I like to know what is going on at various parts of the country. However, I was shocked this morning at a report I got from an auction held yesterday in Cannon Falls, MN at the Simon Horse Company. The first terrible issue was the fact that the auction accepted and was auctioning off foals. I am not talking about young horses about 6 months old, we are talking FOALS some with umbilical cords still attached. These little guys should still be with their mothers. They were tiny babies 1,2 and 3 months old.

I guess I shouldn't be too shocked, the owner of the auction house is a known KB (kill buyer) and trader. However, from a business standpoint selling these animals is a bad idea. If the foals go to the wrong person who doesn't know how to care for "orphans" they will die. (These guys got lucky they ended up with a rescue group.) In this economy it is also a bad idea because these babies aren't going to bring in much either, they are too far away from being ridden. These little ones are not going to bring the prices to make an auction any money. They knew that.

Then the real agenda becomes apparent. During the auction the auctioneer stops the auction to give a "lesson" on horse slaughter. His lesson included falsehoods and outright lies. Of course what do you expect from a guy who has been cited by the USDA for violations of the Commercial Transport of Equines to Slaughter laws? This man and his sons who run the Simon Horse Company were noted in the reports FOIAed by Animal Angels 11 times with numerous violations for each citation. However, he also had a little help. In the audience was a lobbyist who collected signatures against HR 6598. If they were at this auction we can assume they were at others in the area as well.

Their lies included that horse slaughter was banned by federal law. It was not, the states where the plants were located banned them and closed them. There is NO federal law banning horse slaughter. They said that South Dakota wanted a horse slaughter plant but couldn't because of the federal ban. This is not true. SD considered a bill to allow the opening of a horse slaughter plant on tribal lands, but the bill was defeated. They said that the only outlet for horses going to slaughter was transport to Canada and Mexico and that is threatened by HR 6598 which was coming up for a vote. This is true partially, the only outlet for slaughter horses is through transport to Canada and Mexico and HR 6598 would threaten that. But the vote is a committee vote, not a full vote. I am sure there will be plenty of debate on it both today and later when it goes to the House floor for a full vote.

The lobbyist and the auctioneer whipped the crowd into a frenzy talking about how horses have no value any more because of the ban on slaughter. They told them that the prices of the horses sold at auction were proof of that. Then they collected signatures on a petition to be used in the fight of HR 6598.

It isn't often that we have a chance to correct wrongs in our lives, but this time we do. Please take a moment to write a letter to the editor of the local papers in the area. I will post their information below. In the letters the truth has to come out. We MUST let those people know that they were lied to. What happened at that auction is inexcusable. They sacrificed those foals for a political purpose. At their age they couldn't have been legally transported to slaughter. Of course as we know the Simons family doesn't put much stock in what is legal based on their record with the USDA. But the good people of MN usually do care and they shouldn't be misled by the lies of people who make their living off the deaths of horses.

BTW, no fines have been levied against the Simons family for their violations of the Commercial Transport of Equine to Slaughter.

Cannon Falls Beacon 120 South 4th Street, Box 366 Cannon Falls, MN, 55009; Local Phone: (507) 263-3991, Toll Free: (800) 263-3991, News Fax: (507) 263-2300; email the editor dick@cannonfalls.com

Minneapolis Star Tribune Editorial Department, Star Tribune, 425 Portland Ave., Minneapolis, MN 55488; fax to 612-673-4359, phone 612-673-4343 or 1-800-775-4344; online form

Pierce County Herald 126 S. Chestnut St. Ellsworth, WI. 54011; Local News: 715-273-4334, Fax: 715-273-4335; email pcheditor@rivertowns.net or webform

Minnesota Daily (univeristy paper) webform

Points to make
  1. There is no federal ban on horse slaughter
  2. Horse slaughter is inhumane and Congress is considering HR 6598, the Prevention of Equine Cruelty Act of 2008
  3. The price of horses is contingent on the economy, horse slaughter doesn't set a "floor" for prices. Even when slaughter plants were processing they didn't buy every horse
  4. Healthy, young horses go to slaughter (average age of 5), not the very old, they very young, sick, blind and lame because it is illegal and the plants are processing for high price point sales and they want the very best meat possible or their sales go down
We really need to inform and educate the people who were lied to so blatantly. Please take a few minutes to do so ASAP.

Thanks!!

Tuesday, September 9, 2008

Heartbreak

Sometimes things hit me and more often than not, it is because they break my heart. I go to DC alot and meet with powerful people. Most are elected to office and what prompted them to run? They really and truly want to do something good, they want to make the world a better place. However, a few years down the road somehow they lose their way. They start out by making a few deals to do what they think is the "good" thing. Then it becomes easier and then they start making deals for money, donations to their campaigns, whatever. Some sell themselves so cheaply that you have to wonder about their self-esteem. It breaks my heart.

Now I want to make it clear that I am not opposed to our system of government. I am probably the most patriotic person anyone could meet. My father retired from the military, my father-in-law retired from the military, my sons have served, heck I even enlisted but I got pregnant and couldn't report. I vote, my whole family votes. I believe that we have the best form of government in the world, but it isn't perfect. That is why it evolves and changes and it could use some tweeking on special interest and term limits.

Why am I off on a rant on the government? Because of the horse issues. There has been a horse slaughter ban bill pending in Congress for 8 YEARS. Every session there has been a great deal of support for the bill, but a handful of people have prevented its vote, changed their vote beacuse of deals or just flat out lied to block it. It is insane!! A simple bill with huge bi-partisan support cannot pass. If you trace it back it is because of special interest because otherwise nobody would do what has been done if they didn't get money for it, it isn't worth what those people have gone through. Bob Godlatte isn't opposed to the bill because he honestly thinks that horses really do enjoy slaughter. Senator Larry Craig didn't block the bill because he thinks that all horses should die. Both have close ties to the cattle industry. I can guarantee that Larry Craig will be working alongside Charles Stenholm for a lobby firm when he leaves office. It is money.

Then we have the wild horse issue. The BLM is opening the doors to "euthanizing" tens of thousands of healthy horses. It isn't euthanasia, it is murder. The range supposedly can't support them. It can support 4.6 million cattle, it can support 700,000 elk, it can support 60,000 big horn sheep, but it can't handle 60,000 horses (those on the range and those in holding). That is bulls**t. Normally I am not so blunt, but I am in tears right now and I refuse to pull punches when someone is seriously breaking my heart. Those horses have been sold out and for so very little.

When Newsweek published an article (http://www.newsweek.com/id/42723) a few weeks ago I read it as I do as many articles about the horses as I can. However, tonight someone sent me the link again. I went to make sure I had read it and this time I read the comments. People were talking about how we (the people who want the horses on the range) seriously didn't care about the horses. That the range was so bad that these "large" herds were destroying the land. That there are no predetors so the BLM should kill them. Others asked where the environmentalists were and why they weren't speaking out to help the horses. Why? Because the BLM and OUR GOVERNMENT has done such a great job of hiding scientific proof that the horse originated in North America and the great PR on how these aren't really wild animals, but are feral. Track it all back and it goes to money and a VERY long history of it. Horses were here when the first white settlers crossed the plains.

Other comments said the wild horses and burros were "worthless". Others asked whey they weren't protected like the bald eagle. Well, let's look at that. The bald eagle is no longer as protected as it once was. We pushed them to the brink of extinction and they were our nations' symbol from the beginning. We did a great job there. Some other comments said the horses have no predators. That is a lie, they do. But our government has erradicated most of these predators because these poor animals can't tell the difference between worthless horses and priceless cattle. (Ok after I get upset I tend to get REALLY ticked off, but I am trying to keep some of the really bad words from spilling out.)

The grazing program on federal lands is one that costs the tax payer ALOT. It is really hard to know the exact cost because so much of it is hidden by the BLM. We do know that in the past it lost over $41 million dollars a year (darn that is where the money went to maintain the horses in holding facilities!!) and that was years ago. Grazing fees haven't increased, as a matter of fact they are as low as the law allows. Under Reagan the program was losing so much money that he passed laws to set a minimum fee and allowed the BLM to increase the fees up to 25% a year. Instead of raising the fees, the BLM REDUCED them. So, we can expect that we, the tax payer, is paying more. I am not going to go into too much more of the policies that are absolutely riddiculous things we pay for, but let's just say we should all move west and get grazing permits so we don't have to pay our own bills. If we did that then maybe we would have the money to fight/match those working to destroy our horses.

I am also sick to death of being told that because I care about horses and being humane to animals I don't care about children. I am not sure how anyone can make that leap, but that is the most stupid thing I have ever heard. I have worked for years as a kid to raise money for March of Dimes and Muscular Distrophy. I have volunteered hundreds of hours at schools, sat on PTA committees, donated to Habitat for Humanity and thousands of other things. I care about people too. There are literally thousands of organizations that work on those issue, there are only a handful of humane organizations and fewer still that work for the horses. Things that hurt children break my heart too. I cry over them as well, probably more.

In the end when mustangs are extinct and no longer are available to be viewed by our children and grandchildren who should we cry for? Those that will never see those stunningly beautiful animals or the animals that are gone? How can we explain to them that money was more important? Or is it already too late, that we have become a souless society that cares more about the bottom line? We are facing their extinction. What about horse slaughter? Is the almighty dollar more important than doing the right thing, the humane thing?

Ok, I am done with my rant. I am going to say here that these are MY personal opinions. They may not reflect those of AHDF, its board or members. Names of political figures are not to be meant as an endorsement or oppostion of them as candidates of whatever they may or may not be running for.

Thursday, August 28, 2008

BLM answers why "dangerous" horse was killed

According to the BLM Draft Euthanasia Plan a horse may be subject to euthanasia if it "Exhibits dangerous characteristics beyond those inherently associated with the wild characteristics of wild horses and burros". The BLM stated that they have had this policy for years and has replied with a policy signed in 1999. The policy is pasted below. The link to the page on the justification doesn't link to anything because this is so old.

During the Nellis removal in July was the first time we have ever had a gather summary where a horse was euthanized under the the dangerous horse criteria. Since the Draft plan called for justification of such a euthanasia, we requested this justification for the destruction of a healthy horse. We received the justification today. It is posted below. However, one has to wonder if such reasons were justified. My comments will be in black and those of the BLM in blue.

According to the USDA vet who recommended the euthanasia at the request of the BLM the horse "stayed at the edge of the pen" near an adjoining pen which originally held mares. At this boy's age it is probable that he was a band stallion. These mares could have been his, or one or more may have been in season. Later that pen held stallions. He "did not stay close to or mix with the group of stud horses in his pen". Stallions who are band stallions or breeding domestic stallions don't mix well with other studs as they see them as competition. He was "very aggressive to other horses in the pen, not allowing them to stand at that end of the pen". Obviously he had determined his territory and defended it, especially since it was nearest to the mares. He "showed little or no fear of humans and would readily leave the group of horses in his pen" (huh, I thought he didn't group with the other horses) "and run past or though the people in the pen during sorting". Ok, he was avoiding the people and refusing to be caught again. He could have been fearful, nothing new here. I have seen domestic horses do that to avoid capture, especially when more than one person approached. Plus, he probably saw the gate being opened and was making for it to escape. Remember at this time he was in pens still in his own environment. He did this over several days until moved to his own pen, when the BLM employees moved him in fear for their safety. Probably when the decision was made to "euthanize" him.

The USDA vet, Dr Albert Kane, recommended his euthanasia based on an opinion that the horse's "unusual" behavior. He states that this made the horse "dangerous to handle beyond the danger inherently associated with the wild characteristics of wild horses and burros". No notes were made about the horse attempting to strike out, bite or otherwise intentionally injure anyone. I would also like to point out that the wording of this is exactly that of the Draft Plan, not the "established" policy. The established policy states that its actions must be a documented threat to the health and safety to the public and its "threatening" behavior. I don't believe that this was true in this case at all. It is simply that he was a 10 year old stallion that would have gone directly to the overburdened long-term holding facilities. It was much easier to euthanize him on the range where it was less likely that the public would hear of it until too late and it could be done unobserved.

While this old 1999 policy was dragged back out it is interesting that in the ensuing years the BLM had changed its general euthanasia policy several times, but not this one. In the old plan for the euthanasia of 'dangerous" horses it states...
Before the BLM may euthanize an animal solely on the grounds that it is unusually dangerous to human health and safety, the authorized officer, in consultation with a veterinarian, extension agent, local humane official, or other individual acceptable to the authorized officer, must determine that the animal poses a significant danger which is unlikely to be corrected through accepted gentling practices. The BLM's authorized officer and a veterinarian, extension agent, local humane official, or other individual acceptable to the authorized officer, shall prepare and sign a written document that provides a physical and behavioral description of the animal specifying the reason this animal is considered unusually dangerous. However, this euthanasia inspection was done by an USDA vet as the 2005 general euthanasia plan called for. It is all a bit confusing, are we following the 1999 policy or the 2005 which doesn't mention dangerous animals or the Draft Plan? This euthanasia seems to have taken a bit from this one a bit from that one and heaped them all together.

UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
July 20, 1999
In Reply Refer To:
4730.1 (260) P
Ref. IM No. 98-141

EMS TRANSMISSION 07/26/99
Instruction Memorandum No. 99-154
Expires: 09/30/00

To: All Field Officials

From: Assistant Director, Renewable Resources and Planning

Subject: Humane Destruction of Dangerous Wild Horses and Burros

Field Offices have raised concerns about handling and/or adoption of dangerous animals currently in the adoption system. This policy identifies the rationale and requirements for decisions to euthanize unusually dangerous wild horses and burros. The Bureau of Land Management (BLM) has issued and implemented policy to euthanize animals, because they are old, sick or lame (WO-IM No. 98-141, Humane Destruction of Wild Horses and Burros). The euthanasia of an unusually dangerous animal is permissible where it is declared excess through herd management policy and guidelines, and it is a documented danger to the public. The rationale and citations for this conclusion are attached. When the authorized officer has ascertained an animal to be dangerous, the BLM should euthanize the animal in a manner consistent with the BLM policy in Manual 4730 Destruction of Wild Horses and Burros and Disposal of Remains.

Prior to being offered for adoption, horses and burros are observed during capture, preparation, shipping and handling during adoption events and training. During this time, an animal may exhibit dangerous characteristics beyond those associated merely with the inherent wild characteristics of mustangs and burros. The BLM may identify these threatening animals as unusually dangerous and find that they pose an unacceptable risk to the health and safety of the public.

While unusually aggressive behavior might be an acceptable risk on the range, such an animal can pose an unacceptable risk of injury to persons, when they are maintained in enclosed spaces where some level of handling is required. When the Bureau knows that a horse is untameable and violent, it is reasonable to conclude that an average adopter could not "humanely care" for the horse as stated in the regulations (e.g., provide proper transportation, feeding, medical care, and handling 43 CFR 4750.1).

The BLM cannot solve the problem by removing unusually dangerous animals from the adoption system and placing them in a sanctuary because this resolution also poses significant risk of injury, both to the animals in transport, and to the sanctuary operators. Most facilities are operated by private businesses under contract with the BLM and a few small sanctuaries are or have been operated by volunteers. Both contractors and volunteers may have the right to file suit in the event of injury or loss, depending on language that the BLM has in its agreements with such groups.

The course of action the BLM will pursue in circumstances where an animal is a documented risk to health and safety of the public and determined to be an unusually dangerous animal, is humane destruction.

In all cases, the final decisions regarding humane destruction of a wild horse or burro for the safety of the public, rests solely with the authorized officer (43 CFR 4730). Humane destruction of unusually dangerous animals will be conducted according to the following procedures:

* Before the BLM may euthanize an animal solely on the grounds that it is unusually dangerous to human health and safety, the authorized officer, in consultation with a veterinarian, extension agent, local humane official, or other individual acceptable to the authorized officer, must determine that the animal poses a significant danger which is unlikely to be corrected through accepted gentling practices. The BLM's authorized officer and a veterinarian, extension agent, local humane official, or other individual acceptable to the authorized officer, shall prepare and sign a written document that provides a physical and behavioral description of the animal specifying the reason this animal is considered unusually dangerous.
* The Wild Horse and Burro National Program Office (WO-260) must be notified through electronic mail of the decision to euthanize an unusually dangerous wild horse or burro.
* The BLM should never euthanize a wild horse or burro solely for reasons of population control.

Since the passage of the Act, the BLM has handled over 160,000 wild horses and burros in the adoption system and surmises that the need to humanely destroy animals classified as unusually dangerous should be a rare occurrence.

If you have any questions regarding this policy, please contact Lee Delaney, Group Manager, WO-260, at (202) 452-7744.
Signed by: Authenticated by:
Tom Walker Robert M. Williams
Deputy Assistant Director Directives, Records
Renewable Resources and Planning & Internet Group,WO540

1 Attachment
1 - Rational for Euthanasia of Dangerous Animals Based on Law and Regulations (1 p)

Saturday, August 23, 2008

BLM Draft Euthanasia Policy

This post is going to be pretty long so bear with me.

On 30 June 2008 the BLM wrote a new "memo" dealing with the issue of euthanizing the wild horses. This is important because memos are basically instructions on how policy is interpreted and instructions to the field on how they are to proceed. The new memo makes changes to when and under what conditions wild horses are to be euthanized. In the draft they included a new format for gather/removal summary reports. (This will be important later so please keep it in mind.) There are 2 earlier memos dealing with euthanizing wild horses but there are differences between these older memos and the new proposed one. This post is going to focus on the differences. I would like to thank American Herds which provided some of the best information I have, the draft plan and the Nellis Gather Summary.

All pertient memos will be pasted at the end of my post so that you can see for yourself the issues. I believe that the plan is not to euthanize the 30,000 in holding facilities all at once, but to euthanize them in smaller numbers until the number in holding are at what the BLM would consider managable numbers. The public would rise up in opposition over a mass slaughter, but may not recognize the smaller more scattered euthanasia plan. However, that is my opinion, you judge for yourself.

The parts in blue are copied exactly from the BLM documents. Text in black are my comments.

The 2 older memos list 6 reasons for euthanizing a wild horse in the field and in short or long term holding facilities. These are the same in both memos. These reasons are

(1) Displays a hopeless prognosis for life;

(2) suffers from a chronic or incurable disease, injury or serious physical defect;
(includes severe tooth loss or wear, severe club feet, and other severe acquired or
congenital abnormalities)

(3) would require continuous treatment for the relief of pain and suffering in a
domestic setting;

(4) is incapable of maintaining a Henneke body condition score greater than two, in
its present environment;

(5) has an acute or chronic injury, physical defect or lameness that would not allow
the animal to live and interact with other horses, keep up with its peers or exhibit
behaviors which may be considered essential for an acceptable quality of life
constantly or for the foreseeable future;

(6) suffers from an acute or chronic infectious disease where State or Federal animal
health officials order the humane destruction of the animal as a disease control
measure.


The draft plan states 7 reasons for euthanasia in the field and in short or long term holding. The additional criteria is... "Exhibits dangerous characteristics beyond those inherently associated with the wild characteristics of wild horses and burros." The other change is on number 4 where it raises the body score to 3. "Is incapable of maintaining a Henneke body condition score (see Attachment 1) greater than or equal to 3, in its present environment;".

The next change comes under euthanizing in the field. The older memos state that "
Older wild horses and burros encountered during gather operations should be released if, in the opinion of the authorized officer, the criteria described in 1-6 above for euthanasia do not apply, but the animals would not tolerate the stress of transportation, adoption preparation, or holding and may survive if returned to the range. This may include older animals with significant tooth wear or tooth loss that have a Henneke body condition score greater than two. However, if the authorized officer has inspected the animal's teeth and feels the animal's quality of life will suffer and include health problems due to dental abnormalities, significant tooth wear or tooth loss; the animal should be euthanized as an act of mercy."

Under the new memo that is changed to "
The authorized officer will report action(s) taken during gather operations in the comment section of the daily gather report (Attachment 2). Documentation will include a brief description of the animal's condition and reference the applicable criteria (including 1-7 above or other provisions of this policy). The authorized officer will release or euthanize wild horses and burros that will not tolerate the handling stress
associated with transportation, adoption preparation or holding. However, the authorized
officer should, as an act of mercy, euthanize any animal which exhibits significant tooth
loss or wear to the extent their quality of life would suffer."

The older memos state here that ...

If, for humane or other reasons, the need for euthanasia of an unusually large number of animals during a gather operation is anticipated, the euthanasia procedures should be identified in the pre-gather planning process. When pre-gather planning identifies an increased likelihood that animals may need to be euthanized, plans should be made for an APHIS veterinarian to visit the gather site and consult with the authorized officer on euthanasia decisions.

In all cases, the final responsibility and decision regarding euthanasia of a wild horse or burro rests solely with the authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures described in the 4730 manual.

The new memo is missing this section completely.


Here you will see that in the older memos it allows for the release of animals with a body score of 2 or higher. In the new plan it changes it to a body score of 3. It also allows for the euthanasia of "dangerous" animals. According to Dean Bolstead the BLM has had a dangerous animal policy for "many years". However, we have been unable to locate this policy from previous memos and he did not see fit to provide us with any supporting documentation. (A request has been sent requesting the documentation, but he has not replied yet. Although, it has only been a day or so since that request was made.) Also, the new memo is missing the need for an AHPIS vet onsite when there may be a need for many possible euthanasias.

The next change comes under euthanasia in short term holding. Both allow for the euthanasia of animals that meet conditions previously set forth. However, the older memos state...

(B) If in the opinion of the authorized officer and a veterinarian, older wild horses and
burros in short-term holding facilities cannot tolerate the stress of transportation, adoption
preparation, or long-term holding they should be euthanized. However, if the authorized
officer has inspected the animal and feels the animal's quality of life will not suffer, and
the animal could live a healthy life in long-term holding, the animal should be shipped to
a long-term holding facility.

(C) It is recommended that consultation with a veterinarian is obtained prior to euthanasia. If an animal suffers from any of the conditions listed in 1-6 above, but is not in acute pain, the authorized officer has the authority to euthanize the animal in a humane manner. Situations where acute suffering of the animal is not involved could include a physical defect or deformity that would adversely impact the quality of life of the animal if placed in the adoption program or on long-term holding. The authorized officer will ensure that there is a report from a veterinarian describing the condition of the animal that was euthanized. These records will be maintained by the holding facility.


The new memo states...

If in the opinion of the authorized officer and a veterinarian, wild horses and burros
in short-term holding facilities cannot tolerate the stress of transportation, adoption
preparation, or long-term holding they should be euthanized.

and
If an animal suffers from any of the conditions listed in 1-7 above, but is not in acute
pain, the authorized officer has the authority to euthanize the animal in a humane
manner, but it is recommended that consultation with a veterinarian is obtained prior
to euthanasia. Situations where acute suffering of the animal is not involved could
include a physical defect or deformity that would adversely impact the quality of life
of the animal if placed in the adoption program or on long-term holding. The
authorized officer will ensure that there is a report from a veterinarian describing the
condition of the animal that was euthanized. These records will be maintained by
the holding facility.


It takes away the option of the authorized officer to allow the animal to be transported if he deems the animal able to live a healthy life. The second section change is subtle but exist. One thing that is missing in the new memo is a section that deals with the euthanasia of large numbers of animals. In the older memos this states...

If, for humane reasons, the need for the euthanasia of a large number of animals is anticipated, the euthanasia procedures should be identified to the WH&B State Lead or the National Program Office (NPO) when appropriate. A report that summarizes the condition, circumstances and number of animals involved must be obtained from a veterinarian who has examined the animals and sent to the WH&B State Lead and the NPO.

The draft memo leaves the decision solely on the field level and leaves the requirment for the veterinarian as suggested, not required. This is a VERY big change.

The section on long term holding also has changes. The first change comes in the directives to examine the horses. The old memos state...

The WH&B Specialist who is the Project Inspector and the contractor will evaluate all horses and their body condition throughout the year. Once a year a formal evaluation as well as a formal count of all horses at long-term holding facilities will be conducted. The action plan for the formal evaluation is as follows:

While the new memo states...

The LTH facility's Project Inspector (BLM WH&B Specialist) and the LTH contractor will
evaluate all horses and their body condition throughout the year. During the year if any animal is
affected by any of the conditions listed in 1-7 above, the contractor or other person authorized by
the Project Inspector is authorized and obligated to euthanize that animal. Once a year a formal
body condition evaluation as well as a formal count of all horses at long-term holding facilities
will be conducted. The action plan for the formal evaluation is as follows:

This change states that it is the obligation of the agent or contractor to euthanize.

The next difference is in the evaluation proceedures. Most are the same but the big difference is The qualifications of the vet involved in the evaluations. The old memos state...

1. All animals will be inspected by field observation to evaluate body condition and
identify animals that may need to be euthanized to prevent a slow death due to
deterioration of condition as a result of aging. This evaluation will be based on the
Henneke body condition scoring system. The evaluation team will consist of a BLM
WH&B Specialist and a veterinarian not involved with regular clinical work or contract
work at the long-term holding facilities. The evaluations will be conducted in the fall
(September through November) to identify horses with body condition scores of 3 or less.
Each member of the team will complete an individual rating sheet for animals that rate a
category 3 or less. In the event that there is not agreement between the ratings, an
average of the 2 scores will be used and final decisions will be up to the BLM authorized
officer.


The new memo states...

1. All animals will be inspected by field observation to evaluate body condition and
identify animals that may need to be euthanized to prevent a slow death due to
deterioration of condition as a result of aging. This evaluation will be based on the
Henneke body condition scoring system. The evaluation team should consist of a BLM
WH&B Specialist and an APHIS or other veterinarian acceptable to BLM. The
evaluations should be conducted in the fall (September through November) to identify
horses with body condition scores of 3 or less.

The first difference is that they are justifying the fact that they will be euthanizing to prevent sufferring. The next difference is that in the older memos it says that the vet should be one with no relationship with the BLM. The new memo suggests that it should be a vet with whom the BLM has a working relationship. It also no longer provides for independent evaluation forms, just agreement between the parties.

This is basically all that the old memos contain. However, the draft plan includes much more. This includes the justification of euthanizing "dangerous" animals. The new memo states in part...

In making the determination to euthanize an animal solely on the grounds that it is unusually
dangerous, the authorized officer, in consultation with a veterinarian, extension agent, local
humane official, or other individual acceptable to the authorized officer, must determine that the
animal poses a significant and unusual danger beyond that normally associated with wild horses
and burros. The authorized officer must document the aspects of behavior that make the animal
unusually dangerous.

This is where the Nellis Gather Summary comes in. This gather summary uses the summary submitted in the draft Euthanasia Plan. Less than a month before the gather they were using the older gather summary. However, this one uses the summary attached to the draft plan, which has supposedly not been approved. It is also the first time that we can document a single horse being euthanized as "dangerous". However, there was no included documentation of "the aspects of behavior that make the animal dangerous". It also didn't note the reason in the section for that. In all other animals it stated things like 2 Act of Mercy. It was the ONLY one without a reason. The euthanized animal was euthanized on 3 July 2008. He was a 10 year old stallion with no other noted injuries or medical issues (#12 on a list of 33). Because of his age he would have been sent to long term holding. A request for clarification from the BLM has not yet been supplied. (I need to clarify this by stating that while a request for clarification has been requested, it has, at the time of this writing, only been a day or so. So, this shouldn't be read as they won't respond, just that they haven't yet. If they do respond we will be happy to post their side.) At this point it would seem that while the Draft plan has not yet been "officially" put into action, it has at least in this instance

At the end of the memo they finally address the euthanasia of large numbers of horses. I won't post again what the old memos said. I will just paste here the new draft memo...

If the need for euthanasia of an unusually large number of animals is anticipated, these actions
should be identified and outlined in advance whenever possible.When field monitoring and pregather planning identify an increased likelihood that animals may need to be euthanized during a gather, this should be addressed in the gather plan. In an on-the-range or facility situation where
a gather is not involved, advanced planning should also be done whenever possible.
Arrangements should be made for an APHIS or other veterinarian to visit the site and consult
with the authorized officer on the euthanasia decisions. This consultation should be based on an
examination of the animals. It should include a detailed, written evaluation of the conditions,
circumstances or history of the situation and the number of animals involved.Where appropriate,
this information should be specific for each animal affected. It is critical that the Authorized
Officer include contractors that may be involved; the State Office Wild Horse and Burro
Program Lead; appropriate Field Office, District and Resource Managers and the NPO in their
planning.
Any plan of action will include practical considerations including: (1) who will destroy the
affected animals, (2) what method of euthanasia will be used and (3) how carcasses will be
disposed of in accordance with the 4730 manual; this euthanasia policy; and local, State or
Federal regulations that may apply. A communications plan for internal and external contacts
(including early alerts to State, National Program and Washington Offices) should be developed
in advance or concurrently while addressing the situation at hand. The communications plan
should address the need for the action, as well as the appropriate messages to the public and the
media. This will include why animals are being euthanized and how this fits BLM policy.
In all cases, the final decisions regarding euthanasia of a wild horse or burro rests solely with the
authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures
described in the 4730 Manual.

Now let's look at how this varies from previous memos. First, it mandates that special internal communications should be established and the "spin" for the public established if any are to be made. In short and long term holding, the prior memos require the informing and reports to be sent to the state lead and NPO (National Policy Office). In the draft plan it just states that they should be "included" and have alerts sent to them. On the plus side, it doesn't allow that the reports be maintained by the holding facility but who then does hold them on the individual animals? The draft plan only asks for individual reports, where appropriate.

The draft plan doesn't just allow for the euthanasia of horses, it mandates it as an obligation. It allows for a greater number of animals to be euthanized and adds "dangerous" animal euthanasia. Most if not all of the terms are vague and can be interpreted very liberally allowing for large numbers of animals to be euthanized. It also lowers the Heneke body score on the range from 3 to a 2. As I stated earlier, I belive that this plan is to allow the BLM to euthanize more animals so that mass euthanasia is not required. But you decide.

First is the oldest euthanasia memo, then the draft plan. Finally will be the Nellis Gather Summary in the format of the draft plan.

APPENDIX III Euthansia Policy

UNITED STATES DEPARTMENT OF THE INTERIOR

BUREAU OF LAND MANAGEMENT

WASHINGTON, D.C. 20240

October 20, 2005

In Reply Refer To: 4730/4700 (WO-260) P

EMS TRANSMISSION 11/03/2005 Instruction Memorandum No. 2006-023 Expires: 09/30/2007

To: All Field Officials (except Alaska)

From: Assistant Director, Renewable Resources and Planning

Subject: Euthanasia of Wild Horses and Burros

Program Area: Wild Horses and Burros

Purpose: This policy identifies requirements for euthanasia of wild horses and burros.

Policy/Action: A Bureau of Land Management (BLM) authorized officer may authorize the euthanasia of a wild horse or burro in field situations (includes free-roaming horses and burros encountered during gather operations) as well as short- and long-term wild horse and burro holding facilities with any of the following conditions:

(1) Displays a hopeless prognosis for life;

(2) suffers from a chronic or incurable disease, injury or serious physical defect;
(includes severe tooth loss or wear, severe club feet, and other severe acquired or
congenital abnormalities)

(3) would require continuous treatment for the relief of pain and suffering in a
domestic setting;

(4) is incapable of maintaining a Henneke body condition score greater than two, in
its present environment;

(5) has an acute or chronic injury, physical defect or lameness that would not allow
the animal to live and interact with other horses, keep up with its peers or exhibit
behaviors which may be considered essential for an acceptable quality of life
constantly or for the foreseeable future;

(6) suffers from an acute or chronic infectious disease where State or Federal animal
health officials order the humane destruction of the animal as a disease control
measure.


Euthanasia in field situations (includes on-the-range and during gathers):

There are three circumstances where the authority for euthanasia would be applied in a field situation:

(A) If an animal suffers from a condition as described in 1-6 above that causes acute pain
or suffering and immediate euthanasia would be an act of mercy, the authorized officer
has the authority and the obligation to promptly euthanize the animal. If the animal is
euthanized during a gather operation, the authorized officer will describe the animal's
condition and report the action using the gather report in the comment section that
summarizes gather operations (See attachment 1). If the euthanasia is performed during
routine monitoring, the Field Manager will be notified of the incident as soon as practical
after returning from the field.

(B) Older wild horses and burros encountered during gather operations should be
released if, in the opinion of the authorized officer, the criteria described in 1-6 above for
euthanasia do not apply, but the animals would not tolerate the stress of transportation,
adoption preparation, or holding and may survive if returned to the range. This may
include older animals with significant tooth wear or tooth loss that have a Henneke body
condition score greater than two. However, if the authorized officer has inspected the
animal's teeth and feels the animal's quality of life will suffer and include health
problems due to dental abnormalities, significant tooth wear or tooth loss; the animal
should be euthanized as an act of mercy.

(C) If an animal suffers from any of the conditions listed in 1-6 above, but is not in acute pain, the authorized officer has the authority to euthanize the animal in a humane manner. The authorized officer will prepare a written statement documenting the action taken and notify the Field Manager and State Office Wild Horse and Burro (WH&B) Program Lead. If available, consultation and advice from a veterinarian is recommended, especially where significant numbers of wild horses or burros are involved.

If, for humane or other reasons, the need for euthanasia of an unusually large number of animals during a gather operation is anticipated, the euthanasia procedures should be identified in the pre-gather planning process. When pre-gather planning identifies an increased likelihood that animals may need to be euthanized, plans should be made for an APHIS veterinarian to visit the gather site and consult with the authorized officer on euthanasia decisions.

In all cases, the final responsibility and decision regarding euthanasia of a wild horse or burro rests solely with the authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures described in the 4730 manual.


Euthanasia at short-term holding facilities:

Under ideal circumstances horses would not arrive at preparation or other facilities that hold horses for any length of time with conditions that require euthanasia. However, problems can develop during or be exacerbated by handling, transportation or captivity. In these situations the authority for euthanasia would be applied:

(A) If an animal suffers from a traumatic injury or other condition as described in 1-6
above that causes acute pain or suffering and immediate euthanasia would be an act of
mercy, the authorized officer has the authority and the obligation to promptly euthanize
the animal. A veterinarian should be consulted if possible.

(B) If in the opinion of the authorized officer and a veterinarian, older wild horses and
burros in short-term holding facilities cannot tolerate the stress of transportation, adoption
preparation, or long-term holding they should be euthanized. However, if the authorized
officer has inspected the animal and feels the animal's quality of life will not suffer, and
the animal could live a healthy life in long-term holding, the animal should be shipped to
a long-term holding facility.

(C) It is recommended that consultation with a veterinarian is obtained prior to euthanasia. If an animal suffers from any of the conditions listed in 1-6 above, but is not in acute pain, the authorized officer has the authority to euthanize the animal in a humane manner. Situations where acute suffering of the animal is not involved could include a physical defect or deformity that would adversely impact the quality of life of the animal if placed in the adoption program or on long-term holding. The authorized officer will ensure that there is a report from a veterinarian describing the condition of the animal that was euthanized. These records will be maintained by the holding facility.

If, for humane reasons, the need for the euthanasia of a large number of animals is anticipated, the euthanasia procedures should be identified to the WH&B State Lead or the National Program Office (NPO) when appropriate. A report that summarizes the condition, circumstances and number of animals involved must be obtained from a veterinarian who has examined the animals and sent to the WH&B State Lead and the NPO.

In all cases, final decisions regarding euthanasia of a wild horse or burro rest solely with the authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures described in the 4750-1 Handbook.

Euthanasia at long-term holding facilities:

This portion of the policy covers additional euthanasia conditions that are related to long-term holding facilities and includes existing facilities and any that may be added in the future.


At long-term holding facilities the authority for euthanasia would be applied:

(A) If an animal suffers from a traumatic injury or other condition as described in 1-6 above that causes acute pain or suffering and immediate euthanasia would be an act of mercy, the authorized officer has the authority and the obligation to promptly euthanize the animal.

(B) If an animal suffers from any of the conditions listed in 1-6 above, but is not in acute pain, the authorized officer has the authority and obligation to euthanize the animal in a humane and timely manner. In situations where acute suffering of the animal is not involved, it is recommended that a consultation with a veterinarian is obtained prior to euthanasia. The authorized officer will ensure that there is a report from a veterinarian describing the condition of the animal that was euthanized. These records will be maintained by the authorized officer.

The following action plan will be followed for animals at long-term holding facilities:

The WH&B Specialist who is the Project Inspector and the contractor will evaluate all horses and their body condition throughout the year. Once a year a formal evaluation as well as a formal count of all horses at long-term holding facilities will be conducted. The action plan for the formal evaluation is as follows:

1. All animals will be inspected by field observation to evaluate body condition and
identify animals that may need to be euthanized to prevent a slow death due to
deterioration of condition as a result of aging. This evaluation will be based on the
Henneke body condition scoring system. The evaluation team will consist of a BLM
WH&B Specialist and a veterinarian not involved with regular clinical work or contract
work at the long-term holding facilities. The evaluations will be conducted in the fall
(September through November) to identify horses with body condition scores of 3 or less.
Each member of the team will complete an individual rating sheet for animals that rate a
category 3 or less. In the event that there is not agreement between the ratings, an
average of the 2 scores will be used and final decisions will be up to the BLM authorized
officer.

2. Animals that are rated less than a body condition score of 3 will be euthanized in the
field soon after the evaluation by the authorized officer or their designated representative.
The horses that rate a score 3 will remain in the field and should be re-evaluated by the
contractor and WH&B Specialist that is the Project Inspector, for that contract, in 60 days
to see if their condition is improving, staying the same or declining. Those that are
declining in condition should be euthanized soon after the second evaluation.

3. The euthanasia process that will be used is a firearm. The authorized officer or their
designated representative will carry out the process. Field euthanasia does not require the
gathering of the animals which would result in increased stress and may cause
unnecessary injury to other horses on the facility.


4. Documentation for each animal euthanized will include sex, color, and freeze/hip
brand (if readable). Copies of all documentation will be given to the contractor and
retained by BLM.

5. Arrangements for carcass disposal for euthanized animal(s) will be in accordance with
applicable state and county regulations.

In all cases, the final decisions regarding euthanasia of a wild horse or burro for humane reasons rests solely with the authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures described in the 4750-1 Handbook.

Timeframe: This action is effective from the date of approval through September 30, 2007.

Budget Impact: Implementation of these actions would not result in additional expenditures over present policies.

Manual/Handbook Sections Affected: No manual or handbook sections are affected.

Background: The authority for euthanasia of wild horses or burros is provided by the Wild Free-Roaming Horse and Burro Act of 1971, Section3(b)(2)(A) 43 CFR4730.1 and BLM Manual 4730-Destruction of Wild Horses and Burros and Disposal of their Remains.

Decisions to euthanize require an evaluation of individual horses that suffer due to injury, physical defect, chronic or incurable disease, severe tooth loss or old age. The animal's ability to survive the stress of removal and/or their probability of surviving on the range if released, transportation to a BLM facility and to adoption or long-term holding should be determined. The long term care of these animals requires periodic evaluation of their condition to prevent long term suffering. These evaluations will, at times, result in decisions that will require the euthanasia of horses or burros if this is the most humane course of action.

Coordination: This document was coordinated with the Wild Horse and Burro Specialists in each affected state, the National Program Office and Wild Horse and Burro Advisory Board.

Contact: Questions regarding this memorandum should be directed to Lili Thomas, Wild Horse and Burro Specialist, Wild Horse and Burro National Program Office, at (775) 861-6457.

Signed by: Authenticated by:

Thomas H. Dyer Robert M. Williams

Deputy Assistant Director Policy and Records Group,WO-560

1 Attachment 1 - Name of HMA Gather and Removal Report (2 pp)


UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
In Reply Refer To:
4730/4700 (WO-260) P
EMS TRANSMISSION
InstructionMemorandum No.
Expires: 09/30/2008
To: All Field Officials (except Alaska)
From: Assistant Director, Renewable Resources and Planning
Subject: Euthanasia ofWild Horses and Burros
Program Area: Wild Horses and Burros
Purpose: This policy identifies requirements for euthanasia of wild horses and burros.
Policy/Action: A Bureau of Land Management (BLM) authorized officer will euthanize or authorize the euthanasia of a wild horse or burro when any of the following conditions exist:
(1) Displays a hopeless prognosis for life;
(2) Is affected by a chronic or incurable disease, injury or serious physical defect (includes severe tooth loss or wear, club foot, and other severe acquired or congenital abnormalities);
(3) Would require continuous treatment for the relief of pain and suffering in a domestic setting;
(4) Is incapable of maintaining a Henneke body condition score (see Attachment 1) greater than or equal to 3, in its present environment;
(5) Has an acute or chronic illness, injury, physical condition or lameness that would not allow the animal to live and interact with other horses, keep up with its peers or exhibit behaviors which may be considered essential for an acceptable quality of life constantly or for the foreseeable future;
(6) Where a State or Federal animal health official orders the humane destruction of the animal(s) as a disease control measure;
(7) Exhibits dangerous characteristics beyond those inherently associated with the wild characteristics of wild horses and burros.
Euthanasia in field situations (includes on-the-range and during gathers):
(A) As an act of mercy, the authorized officer has the authority and the obligation to promptly euthanize an animal if it is affected by any acute or chronic condition described in criteria 1-7 above.
(B) The authorized officer will report action(s) taken during gather operations in the comment section of the daily gather report (Attachment 2). Documentation will include a brief description of the animal's condition and reference the applicable criteria (including 1-7 above or other provisions of this policy). The authorized officer will release or euthanize wild horses and burros that will not tolerate the handling stress associated with transportation, adoption preparation or holding. However, the authorized officer should, as an act of mercy, euthanize any animal which exhibits significant tooth loss or wear to the extent their quality of life would suffer.
(C) If the euthanasia is performed during routine monitoring, the Field Manager will be notified of the incident as soon as practical after returning from the field.
Euthanasia at short-term holding facilities:
Under ideal circumstances horses and/or burros would not arrive at preparation or other facilities that hold animals for any length of time with conditions that require euthanasia. However, problems can develop during or be exacerbated by handling, transportation or captivity. In these situations the authority for euthanasia would be applied:
(A) If an animal is affected by a condition as described in 1-7 above that causes acute pain or suffering and immediate euthanasia would be an act of mercy, the authorized officer has the authority and the obligation to promptly euthanize the animal. A veterinarian should be consulted if possible.
(B) If in the opinion of the authorized officer and a veterinarian, wild horses and burros in short-term holding facilities cannot tolerate the stress of transportation, adoption preparation, or long-term holding they should be euthanized.
(C) If an animal suffers from any of the conditions listed in 1-7 above, but is not in acute pain, the authorized officer has the authority to euthanize the animal in a humane manner, but it is recommended that consultation with a veterinarian is obtained prior to euthanasia. Situations where acute suffering of the animal is not involved could include a physical defect or deformity that would adversely impact the quality of life of the animal if placed in the adoption program or on long-term holding. The authorized officer will ensure that there is a report from a veterinarian describing the condition of the animal that was euthanized. These records will be maintained by
the holding facility.
Euthanasia at long-term holding facilities:
This portion of the policy covers additional euthanasia conditions that are related to long-term holding (LTH) facilities and includes existing facilities and any that may be added in the future.
The following action plan will be followed for animals at long-term holding facilities:
The LTH facility's Project Inspector (BLM WH&B Specialist) and the LTH contractor will evaluate all horses and their body condition throughout the year. During the year if any animal is affected by any of the conditions listed in 1-7 above, the contractor or other person authorized by the Project Inspector is authorized and obligated to euthanize that animal. Once a year a formal body condition evaluation as well as a formal count of all horses at long-term holding facilities will be conducted. The action plan for the formal evaluation is as follows:
1. All animals will be inspected by field observation to evaluate body condition and identify animals that may need to be euthanized to prevent a slow death due to deterioration of condition as a result of aging. This evaluation will be based on the Henneke body condition scoring system. The evaluation team should consist of a BLM WH&B Specialist and an APHIS or other veterinarian acceptable to BLM. The evaluations should be conducted in the fall (September through November) to identify horses with body condition scores of 3 or less.
2. Animals that are rated less than a body condition score of 3 will be euthanized in the field soon after the evaluation by the authorized officer or their designated representative, this can be the contractor. The horses that rate a score of 3 will remain in the field and will be re-evaluated by the contractor and the Project Inspector for that contract in 60 days to see if their condition is improving, staying the same or declining. Those that are declining in condition will be euthanized soon after the second evaluation.
3. Euthanasia will be carried out with a firearm by the authorized officer or their designated representative. Field euthanasia does not require the gathering of the animals which would result in increased stress and may cause unnecessary injury to other horses on the facility.
4. Documentation for each animal euthanized will include sex, color, and freeze/hip brand (if readable). Copies of all documentation will be given to the contractor and retained by BLM.
5. Arrangements for carcass disposal for euthanized animal(s) will be in accordance with applicable state and county regulations.
Euthanasia of Dangerous Animals:
Unusually aggressive behavior can pose an unacceptable risk of injury to persons when wild horses or burros are maintained in enclosed spaces where some level of handling is required.
When a horse or burro is violently dangerous, it is reasonable to conclude that an average adopter could not "humanely care" for the animal as stated in the regulations (e.g., provide proper transportation, feeding, medical care, and handling 43 CFR 4750.1). The BLM cannot solve the problem by removing unusually dangerous animals from the adoption system and placing them in a LTH facility because this resolution also poses significant risk of injury, both to the animals in transport, and to BLM personnel and LTH operators.
In making the determination to euthanize an animal solely on the grounds that it is unusually dangerous, the authorized officer, in consultation with a veterinarian, extension agent, local humane official, or other individual acceptable to the authorized officer, must determine that the animal poses a significant and unusual danger beyond that normally associated with wild horses and burros. The authorized officer must document the aspects of behavior that make the animal
unusually dangerous.
Euthanasia of a Large Number of Animals
If the need for euthanasia of an unusually large number of animals is anticipated, these actions should be identified and outlined in advance whenever possible.When field monitoring and pregather planning identify an increased likelihood that animals may need to be euthanized during a gather, this should be addressed in the gather plan. In an on-the-range or facility situation where a gather is not involved, advanced planning should also be done whenever possible.
Arrangements should be made for an APHIS or other veterinarian to visit the site and consult with the authorized officer on the euthanasia decisions. This consultation should be based on an examination of the animals. It should include a detailed, written evaluation of the conditions, circumstances or history of the situation and the number of animals involved.Where appropriate, this information should be specific for each animal affected. It is critical that the Authorized Officer include contractors that may be involved; the State Office Wild Horse and Burro Program Lead; appropriate Field Office, District and Resource Managers and the NPO in their planning.
Any plan of action will include practical considerations including: (1) who will destroy the affected animals, (2) what method of euthanasia will be used and (3) how carcasses will be disposed of in accordance with the 4730 manual; this euthanasia policy; and local, State or Federal regulations that may apply. A communications plan for internal and external contacts (including early alerts to State, National Program andWashington Offices) should be developed in advance or concurrently while addressing the situation at hand. The communications plan should address the need for the action, as well as the appropriate messages to the public and the media. This will include why animals are being euthanized and how this fits BLM policy.
In all cases, the final decisions regarding euthanasia of a wild horse or burro rests solely with the authorized officer (43 CFR 4730). Euthanasia will be carried out following the procedures
described in the 4730 Manual.
Timeframe: This policy is effective upon issuance.
Budget Impact: Implementation of these actions would not result in additional expenditures over
present policies.
Manual/Handbook Sections Affected: No manual or handbook sections are affected.
Background: The authority for euthanasia of wild horses or burros is provided by theWild
Free-Roaming Horses and Burros Act of 1971, Section3(b)(2)(A) 43 CFR4730.1 and BLM
Manual 4730-Destruction of Wild Horses and Burros and Disposal of their Remains.
Decisions to euthanize require an evaluation of individual horses or burros affected by injury,
physical defect, chronic or incurable disease, severe tooth loss, poor condition or old age. The
animal's ability to survive the stress of removal and/or their probability of surviving on the range
if released, transportation to a BLM facility and to adoption or long-term holding should be
considered. Humane, long-term care of these animals requires periodic evaluation of their
condition to provide for their well being. These evaluations will, at times, result in decisions that
will require the euthanasia of horses or burros.
Coordination: This document was coordinated with theWild Horse and Burro Specialists in each
affected state, the National Program Office andWild Horse and Burro Advisory Board.
Contact: Questions regarding this memorandum should be directed to Lili Thomas,Wild Horse
and Burro Specialist, Wild Horse and Burro National Program Office, at (775) 861-6457.
Signed by: Authenticated by:
Policy and Records Group,WO-560 Deputy Assistant Director
2 Attachments
1—Henneke body condition
2 - Gather Summary Report (2 pp)


evada Wild Horse Range Emergency Gather 2008
Gather Summary Report
August 1, 2008
HMA Name/# Nevada Wild Horse
Range HMA / NV524
HMA Complex NONE
State/Field Office NV / Las Vegas Dates of Gather June 27, 08 – July 10, 2008
Person Submitting
Report
Name: Jerrie Bertola
Phone: (702) 515-5024
GATHER ACTIVITIES PLAED & COMPLETED
Name of the HMA NWHR HMA
# Planned for Gather 1,150
Actual # Gathered 949
# Planned for Removal 1,150
Actual # Removed 946
# Planned for Release 0
Actual # Released 3
# Treated with Fertility Control 0
Died/Destroyed – Natural/Unknown 27
Died/Destroyed – Gather Related 6
Post-gather Population Estimate 250-300
Date completed 7/10/2008
DAILY TOTALS
Date # Captured # Released # Shipped # Died/Euthanized # Fertility Treated Mares
June 27 0 0 0 0 0
June 28 0 0 0 0 0
June 29 138 0 0 0 0
June 30 105 0 86 0/7 0
July 1 207 0 81 0/1 0
July 2 71 0 120 0/3 0
July 3 102 0 120 0/1 0
July 4 85 0 135 0 0
July 5 21 0 79 0 0
July 6 93 0 39/11 0/15 0
July 7 15 0 118 0/3 0
July 8 7 0 0 0 0
July 9 105 0 0 0/3 0
July 10 0 3 124 0 0
Totals to date
949 3 913 0/33 0
Summary of Gather Results by HMA
HMA Name: Mares Stallions Foals Total
(1) Pre-Gather Population Estimate 672 448 280 1400
(2) Gathered1 436 367 146 949
(3) Treated and Released2 0 0
(4) Untreated and Released 2 1 0 3
(5) Shipped to BLM Prep Facility 416 354 132 902
(6) Other losses (explain below)3 17 12 4 33
(7) Ungathered4 250-300
(8) Estimated post-gather population5 250-300
(9) Shipped to Las Vegas (NWHA) 1 10 11
1 Line (2) should equal the sum of lines (3) through (6).
2 Must match the number shown on the PZP Application Report.
3 Line (6). Please explain the fate of any animals that were gathered but not included in lines (3), (4), or
(5).
4 Should equal the estimated total number of horses on the range from the pre-gather census (line (1))
minus line (2). Please explain any discrepancies.
5 Line (8) should be the sum of lines (3), (4), and (7).
This gather was completed using mainly water/bait trapping of the wild horses. Five trap locations were set- up simultaneously at Cactus Springs, the O&M gravel pond, Main Lake pond, Rose troughs, Silverbow troughs.
Due to the location and condition of the wild horses located in north portion of Kawich Valley near Sumner Spring, and in the south portion of the Cactus Range near Cactus Springs the helicopter was used for one day to gather the wild horses in these locations. The wild horses within Kawich Valley were located near the end of the gather and were utilizing a small amount of water located at Sumner Spring and a small amount of water that was available along the waterline (this water source is piped outside the boundaries of the NWHR by the
rancher who holds the water rights). The wild horses gathered at Cactus Springs had been coming to the water/bait trap seeking water; however, they would not enter the trap. South of this trap location is a small seep that the wild horses would then go to for water. The wild horses gathered during the last day from Cactus Springs as a collective group of wild horses had the poorest body condition scores (BCS), with many of the wild horses in BCS 3 (Henneke body condition scale from 1-9).
Gather operations were smooth with both water/bait and helicopter trapping. All wild horses were gathered humanely and shipped to BLM holding facilities in either Ridgecrest, CA or PVC outside Reno, NV.
Additionally, eleven wild horses were shipped to Las Vegas and placed with the National Wild Horse Association (NWHA). This included nine foals without mothers and one mare/foal. All the foals had been nursing or drinking supplemental milk replacer prior to shipping. The youngest foal was shipped with the mother but after several days in Las Vegas was humanely euthanized by a veterinarian as the foal was suffering from extreme dehydration and diarrhea and had a very poor prognosis for survival. The mare and remaining 9
foals remain with the NWHA and are doing well at this time. All of these horses will be available for adoption in Las Vegas. Any of the horses not adopted prior to October 1, 2008 will be available for adoption at the National Wild Horse Association’s Show and Adoption Event October 18-19, 2008 at Horseman’s Park in Las
Vegas, NV.
During the gather of the Nevada Wild Horse Range a total of 33 wild horses were humanely euthanized. All euthanasia was done under the direction of the BLM authorized officer and based on professional advice of the on-site veterinarian. All of the wild horses euthanized met the criteria under the BLM’ s euthanasia policy. The following reasons correlate to the reasons listed in the euthanasia table below. Reason Codes: (1) Displays a hopeless prognosis for life; (2) suffers from a chronic or incurable disease, injury or serious physical defect; (3)
would require continuous treatment for the relief of pain and suffering in a domestic setting; (4) is incapable of maintaining a Henneke body condition score greater than two, in its present environment; (5) has an acute or chronic injury, physical defect or lameness that would not allow the animal to live and interact with other horses, keep up with peers or exhibit behaviors which may be considered essential for an acceptable quality of life constantly or for the foreseeable future.


Horse Date Color Sex Age Description Reason
1 6/30/08 Buckskin S Foal Complete compound cannon bone left hind 2, Act of mercy
2 6/30/08 Sorrel M 6 Ruptured right eye 2, Act of mercy
3 6/30/08 Sorrel S 4 Severe club foot, left front 2
4 6/30/08 Buckskin M 4 Severe laceration old wire cut of extensor tendon right hind 5, Act of mercy
5 6/30/08 Black S 3 Severe club foot, left front 2
6 6/30/08 Sorrel S 3 Fractured elbow, left front 2, Act of mercy
7 6/30/08 Brown M 4 Bilateral club foot 2
8 7/1/08 Black M 2 Fractured neck, hit the panel 2, Act of mercy
9 7/2/08 Sorrel S 7 Double blind 2, Act of mercy
10 7/2/08 Roan S 3 Bilateral club foot 2
11 7/2/08 Bay M 20 Sever incisor deformity, Lame right front 2
12 7/3/08 Bay S 10 Dangerous
13 7/6/08 Brown S 4 Severe club foot, right front 2
14 7/6/08 Bay S 20+ Blind left eye, old fracture right hind 2
15 7/6/08 Brown S 3 Severe club foot, right front 2
16 7/6/08 Sorrel S 4 Abnormal mentation, probable head injury 2, Act of mercy
17 7/6/08 Brown M 20 Severely worn teeth, went down in ally twice to weak to transport 2, Act of mercy
18 7/6/08 Sorrel M 15 Body Condition Score 2, unable to maintain 4
19 7/6/08 Bay M 4 Severe club foot, left front 2
20 7/6/08 Buckskin M 4 Severe club foot, right front 2
21 7/6/08 Sorrel M 20 Chronic abscess left side, probable body wall defect 2
22 7/6/08 Sorrel M 20+ Body Condition Score 2, severely worn and missing teeth 4
23 7/6/08 Sorrel S Foal Severely lame poor prognosis 5, Act of mercy
24 7/6/08 Bay M 20 Body Condition Score 2 unable to maintain, severely worn and missing teeth 4
25 7/6/08 Sorrel M 20+ Body Condition Score 2 unable to maintain 4
26 7/6/08 Chestnut S 1 Bilateral chronic enlarged ankles, severely crooked legs 2
27 7/6/08 Sorrel M 3 Severe club foot, right front 2
28 7/7/08 Bay M 3 Chronic colic no response to treatment 1, Act of mercy
29 7/7/08 Bay M 20+ Severely broken teeth 2
30 7/7/08 Sorrel M 20+ Blind in right eye 2
31 7/9/08 Buckskin S Foal Fractured right hind cannon bone 2, Act of mercy
32 7/9/08 Roan S 25+ Severely impaired vision, broken teeth 2
33 7/9/08 Grey S 20+ Wrynose possible old injury, severe tooth wear 2