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 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.
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
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