Alan Shephard responded to my questions for the Stone Mountain Roundup. I asked BLM the questions on February 2, 2012 before the roundup but they never followed through until June 8, 2012 with their response.
Here are his answers to my questions.
1.) To better understand the percentage of wild horses adopted at the previous “integrated” adoption what was the total amount of wild horses rounded up in January 2008 at the Roberts Mountain Wild Horse Gather? We understand from your response below 5 wild horses were adopted at that integrated adoption.
One must understand that the goal of an integrated on-site adoption is not to adopt all horses gathered during the capture operation. The goal of an on-site adoption is to select a reasonable number of wild horses (based on expected demand) with various traits to offer to the public for adoption. This helps to reduce the number of horses shipped to BLM facilities, helps to raise awareness of the adoption program and allows a wild horse to go directly home with an adopter instead of going through the facilities, and experiencing additional handling due to preparation and transportation.
During the Roberts Mountain gather in 2008, we gathered a total of 373 wild horses. 331 of those were shipped to BLM facilities, and 25 were held for the on-site adoption. Approximate 109-123 wild horses remained on the range after the gather.
The animals selected for adoption were painted with identifying numbers on their hips during the routine sorting activities that take place after capture, and left in the central holding corrals. On the day of the event, the public viewed the wild horses in the pens, and selected the horses they wanted to adopt. Everyone interested wanted a different horse, so no bidding or lottery was needed. Five horses were chosen for adoption. The adopted animals were then freezemarked and vaccinated in the central holding corrals working chute by BLM and contractor employees. The vet also drew blood for Coggins testing. The unadopted horses were then transported with the rest of the horses to BLM facilities, never having had any additional handling. To facilitate viewing by the public, for the Stone Cabin and Bullfrog on-site adoptions, we built a separate set of adoption corrals a few hundred feet away from the main holding corrals. In this way, the public was able to view the adoption animals throughout the days leading up to the event itself without interfering with the activities at the holding corrals. Our future adoption events will be structured this way as well.
The Roberts Mountain gather was an emergency situation. Thick snow on the valley floor in combination with low forage production and overpopulation led to horses in very poor body condition. In addition, a winter snow storm and freezing conditions precluded a large turnout for the adoption event. We were very pleased to adopt 5 animals at this event.
2.) Will the unadopted mustangs up for adoption who are not adopted receive one strike towards the three strikes to become a sale authority horse?
The on-site adoptions are outside of any adoption events that would count against the horses.
3.) What can be done to improve the adoption rate at “integrated” adoptions such as this?
Because of the nature of the on-site adoptions, we don’t believe that it would be possible to adopt large numbers of wild horses (in excess of 20 or so). These are generally remote areas, often during winter months, and with less than optimal ability to construct efficient corrals, alleyways and working areas. We can improve our integrated adoptions through increasing advertising in advance of the events and working with partners to help spread the word. With heavy workloads in other priority projects at BLM it is not easy to dedicate large volumes of time to these projects. The goal is to “integrate” them in such a way that they don’t require large amounts of time or money but can result in the adoption of a number of animals from the gather operation. We are interested in any suggestions you may have to help improve these adoptions. We will be planning our next event in conjunction with the Diamond Complex gather we are proposing for January 2013. The scoping letter is going out soon with a tentative Preliminary EA due for release in June or July. With this amount of time to plan, the historic adoption base in Eureka and the past interest in these horses, we are hoping for a successful event and potential adoption of 15-20 wild horses.
4.) Who is the roundup contractor?
The Contractor for the Stone Cabin Complex gather was Sun J.
4.) How many acres of land does this HMA contain?
Information about the gather area is available in the Stone Cabin Complex gather EA available at
The Stone Cabin and Saulsbury HMAs total 484,888 acres.
5.) What is the AML for this HMA?
For your information the following table provides the final results of the gather operation completed in February 2012.
6.) What other forms of ‘multiple use” will occupy these HMAs in the future and what is there now?
Please access the Stone Cabin Complex EA at the site identified above for this information.
7.) What is the cost of the roundup? How much is the contractor being paid per head?
National contracting policy requires that this type of contracting and financial information can only be released through a request under the Freedom of Information Act (FOIA).
9.) Will potential adopters be able to spot a horse at the roundup and inform you they want to adopt that horse so you will pull it from the pool to be sent to short-term holding?
In any on-site adoption we conduct with a gather, we would try to include wild horses in the event that an observer may be interested in. However, the logistics of the operation won’t allow us to accommodate those kinds of requests except in only the rarest occasions. In order to facilitate the blood draw for Coggins testing, the horses that are included in the adoption event must be selected from the gathered animals at least 5-7 days prior to the event. Depending on the complexity or length of the gather operation itself, that could mean that they would have to be selected during the first few days or the middle of the gather. For the well-being of the animals, we prefer to select all animals within a day or two, rather than continue to add animals to the adoption pens over the course of many days, which could result in additional stress to the animals as they are disturbed and must become associated with new pen-mates.
If potential adopters inform us of certain traits they are interested in (age, color, sex), we can try to include representative animals in the adoption pens. Anyone interested in adopting must still be approved and must participate in the lottery or bid unless it happens that everyone present is interested in a different animal. We would not select animals specifically to be adopted by a certain individual which would constitute favoritism and bias and not be fair to other adopters.
10.) How do you determine which horses are pulled for processing, possible adoption and long-term holding and which wild horses and burros will return to the range?
There are many factors considered and they are typically specific to HMA, geographic area, and other parameters. Some of these factors are discussed on page 16-17 of the Stone Cabin Complex Gather EA. When analyzing the expected herd age structure and sex ratio, in comparison to the numbers of animals needed to be removed to meet the post gather objectives, we can look at the numbers of animals expected per age group. In some cases, we can remove only younger animals such as those less than 4 years of age, and meet the AML target. This way, animals older than 5 are released and not transported for inclusion into the adoption program, Long Term Pastures or the sale program.
If the needs of the gather require the removal of more animals than just the younger age groups, then we consider how many more needed to remove and evaluate how many from the older age groups we would release or remove to reach the AML target. We release older animals that would not do well with the additional transportation and handling as long as they are healthy enough and have healthy enough teeth to thrive in the wild.
We consider historic traits as well. In the case of the Stone Cabin Complex, the “Stone Cabin Grey” has long been known in the area. Our goals included making sure the post gather population was well represented by the Stone Cabin Grey as well as other characteristics included in the herd.
Healthy animals are always preferred for release over animals that are thinner or weaker. Oftentimes, young three year old mares are thin or very thin due to the requirements of pregnancy, lactation and growth. We make every attempt to select animals for release that are already proving to thrive in their existing environment and exhibit good body size, muscling and the overall appearance of a healthy animal.
The BLM also follows an Instruction Memorandum which provides guidance for the “selective removal criteria” for gathers.
We will provide a copy of IM-2010-135 at your request. The IM covers many of the considerations for selection of animals to remove from the range as well as potential exceptions to the policy. The pertinent information related to age is as follows:
1. Age Criteria: Wild horses will be removed in the following order:
a) Age Class – Four Years and Younger
Wild horses 4 years of age and younger should be the first priority for removal and placement into the national adoption program.
b) Age Class – Eleven to Nineteen Years
Wild horses aged 11 to 19 years of age should be removed from the HMA only if management goals and objectives for the herd cannot be achieved by removing horses 4 years and younger or if specific exceptions prevent them from being turned back and left on the range.
c) Age Class – Five to Ten Years Old
Wild horses 5 to 10 years of age are the lowest priority for removal and should be removed only if management goals and objectives for the herd cannot be achieved through the removal of animals identified in a) and b) above.
d) Age Class – Twenty Years and Older
Wild horses aged 20 years and older should not be removed from the HMA unless specific exceptions prevent them from being turned back and left on the range. In general, this age group can survive on the HMA but can have greater difficulty adapting to captivity and the stress of handling and shipping if removed.
11.) When was the last time you rounded up these horses and when will you roundup horses in these HMAs again?
The information about several of the past gathers of the Stone Cabin HMA and Stone Cabin Complex are available in the Stone Cabin Complex Gather EA beginning on page 29. Despite the fact that fertility control was implemented in conjunction with the 2012 gather, population growth will eventually result in the population exceeding the AML and another gather would be scheduled as appropriate. Ongoing field monitoring will continue to document rangeland health, habitat limitations and any changes that could warrant adjusting the AML or which provide information regarding the need for a gather to remove excess wild horses. Population inventory through helicopter flights will also monitor the population size, distribution and animal health. It is expected that the AML could be exceeded within 4-5 foaling seasons, depending on the success of the fertility control vaccine administered during the gather.
12.) Will a burro behavior expert be on site the whole time burros are being rounded up so the cruel hot-shotting incident at Calico will not be repeated? We would like to see a burro expert on site to prevent animal cruelty paid to the roundup contractor using American tax dollars.
As described in the Stone Cabin Complex and Bullfrog Burro Gather EAs, APHIS veterinarians are on-site throughout the gathers to oversee the operations and monitor the health of the animals. The BLM has been conducting wild horse and burro gathers since the mid-1970’s and collectively has a great deal of experience in conducting gathers safely and humanely, as do the contractors. The use of “hot-shots” is monitored by BLM and used only when absolutely necessary.
13.) We are very concerned about the lack of transparency at roundups and keeping visitors miles away from the trap site is unacceptable. In 2009 and 2010 members of the public and media were allowed closer access to document the roundups. Why has this policy changed?
Public observation protocols in relation to visitor distance from the trap site were established following the filing of several complaints to the Federal Aviation Administration (FAA) by visitors which stated that the contractor helicopter was flying too close to the wild horses and the public visitors. BLM and its gather contractors addressed the concerns with the FAA in order to establish a management direction to follow in regards to visitor viewing distance based on safety concerns. The BLM’s Office of Aviation Safety issued a letter to the National Wild Horse and Burro Program stating that to minimize risks to the public from helicopter operations, the gather Contractor is required to conduct all helicopter operations in a safe manner, and to comply with FAA regulations (FAR) 91.119 (14 CFR § 91.119). The FAA regulation establishes the safety distance of 500 feet (minimum) from the operating helicopter for non-essential personnel and visitors.
Public observation sites are established in locations that reduce safety risks to the public (e.g., from helicopter-related debris or from the rare helicopter crash landing, or from the potential path of gathered horses), to the wild horses (e.g., by ensuring observers would not be in the line of vision of horses being moved to the gather site), and to contractors and BLM employees who must remain focused on the gather operations and the health and well-being of the wild horses. National guidance is that these locations be located a minimum of 500 feet from the working and safety zones of the helicopter per FAA regulations.
14.) We want to go on the record to ask that the canvass on the metal corral panels–blocking the ability to see inside the trap site even from a distance–be taken down. It appears the BLM shrouds the mustangs in secrecy and does not want the media or public to see what is going on when wild horses are captured. This protocol is very upsetting to members of the public. Will you take down the canvas tarps blocking media and public visibility to document the roundup?
The canvas tarps, snow fence and other material used on the corrals and alleyways is a tool to improve animal welfare and handling. The BLM and contractor does not use these materials to block the view of the public or media. The health and welfare of the animals is a priority above the ability to gain un-obscured view of the animals.
15.) The American public wants to know all roundup-related deaths are accounted for correctly. If a wild horse–enjoying life out on the range–is removed from the range alive and you kill it because it is “old” or for whatever other reason this needs to go on the record as “roundup related”. The horse would have continued to live for some time if the BLM had not rounded it up. Will you count all deaths from wild horses rounded up from 30 days of their capture as “roundup related” deaths?
From the time that wild horses and burros are captured until they are transferred into private ownership BLM records wild horse and burro mortality by date and location. The various locations that deaths are associated with include trap/gather sites, while in transit, short-term holding facilities, long term holding facilities and while animals are with adopters up until the time they are titled. BLM does not plan to categorically attribute all deaths 30 days after capture to a gather event. Some deaths within this time frame may directly be associated to a gather related incident while others are not.
To give the program an accurate accounting of the death of wild horses and burros the BLM separates the recording of deaths in different categories; 1) euthanized due to preexisting condition in the field, 2) due directly to the gather operation, 3) when they are at the preparation facility, 4) adoptions, and 5) long-term pasture facilities. There are subsets to these categories in our information system.
16.) We also want to go on the record to ask that you hold all aspects of capture, temporary holding, processing and adoption on public land, giving reasonable access to the media and the public, as an act of good faith showing the global community that the Wild Horse and Burros program has taken the new direction the courts are expecting you have taken. Will you hold all aspects of the roundup, holding, processing and adoption on public land to build trust with the public?
The first priority in selection of holding corrals and gather trap locations is the welfare of the animals. These gather corral locations are placed where the animals are located, where there is access and in the case of the holding corrals, and in the case of the central holding corrals, where there is water or other amenities to ensure proper care of the animals during their stay.
Substrate is also an important consideration. Oftentimes gravel pits are chosen because they would be less likely to become dusty or muddy during use. Access can be an issue in the remote HMAs of the west. Particularly in Nevada, there are not many roads in many of these areas, and often the roads that do exist are not fit to transport wild horses or burros due to poor conditions.
The landscape is also an important consideration for good gather trap corral placement. These areas must be selected where the animals can be safely and efficiently gathered. Good trap corral placement is very important, and these considerations must come before the requests of the public or media. During gathers we make every effort to allow the public to view the gather operations from safe and reasonable distances which do not jeopardize animal or human safety. Additional information about public viewing protocol is available in the Stone Cabin Complex and Bullfrog Burro Gather EAs. The BLM is open to any recommendations you may have regarding public viewing or other topics of interest.
December 22, 2011 Q & A to BLM regarding the Tri-State Calico Complex Roundup