#BREAKING Government Shutdown Update on Captive Wild Horses and Roundups

#BREAKING: All adoptions of BLM Mustangs are on hold during the government shutdown. Those BLM employees in offices aren’t working but wranglers are feeding and watering the captive wild horses!

We have confirmed there is a stop work order on all roundups! So no roundups will occur during the government shutdown.

Take Action! Sign and SHARE the Petition to Defund the Roundups and Stop the Slaughter: https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups

Please Sign and Share the Petition to STOP the cruel collar experiments: https://www.thepetitionsite.com/180/446/599/take-collars-off-wild-horses-now/

Write your elected officials a handwritten letter and ask them to stop the roundups, Pesticide PZP for population control (because there is “no evidence” of overpopulation) and get an independent head count done before dishing out federal funds for a broken program based on inflated population numbers. Here is the petition to get out to them and use for talking points: https://www.change.org/p/u-s-senate-investigate-the-wild-horse-burro-count-in-captivity-and-freedom

We urge public watchdogs to lawfully photograph the captives to ensure their safety during the government shutdown. Will Bureau of Land Management staff be scooping up the dead horses in the morning as usual with the shutdown? Is this the time to expose how many wild horses are dying in the captive pens?

Please help us continue our work to Protect and Preserve native and wild horses with a donation because every dollar counts. Click www.PayPal.me/ProtectMustangs Thank you and Bless you.

Together we can turn this around!

Anne Novak
Volunteer Executive Director
Protect Mustangs

P.O. Box 5661
Berkeley, Ca 94705


Protect Mustangs is a 501(c)3 nonprofit organization dedicated to protect and preserve native and wild horses


Nellie Diamond (#0484) has 3-Strikes and BoLM is offering her for Sale

It’s not her fault she wasn’t picked! Help Nellie Diamond (#0484) find a safe home.

PM 3-Strike Nellie Diamond 10620484 for Sale

Nellie Diamond (#0484) is on the Internet Adoption and offered for sale $25. She seems to have been deeply hurt by losing her home and her herd after the Bureau of Land Management (BoLM) roundup 3 years ago. No one is taking the time to see beyond her loneliness. Nellie Diamond might do well with a sister mustang from her herd–the Diamonds out of Nevada. Once she is treated with love, patience and respect Nellie will shine like a Diamond too.

Here is the online application: https://www.blm.gov/adoptahorse/howtoadopt.php

Nellie can be shipped out to any of the locations listed below for free and then you need to transport her home from there.

BoLM says:

Sex: Mare Age: 6 Years   Height (in hands): 13.3

Necktag #: 0484   Date Captured: 02/03/13

Freezemark: 10620484   Signalment Key: HF1AAAAAG

Color: Gray   Captured: Diamond (NV)


Tag-#0484. 6 year old gray mare rounded up from the Diamond Herd Management Area in Nevada in February of 2013.

This wild horse is currently located in Palomino Valley, NV.  For more information, please contact Jeb Beck at (775) 475-2222 or e-mail: j1beck@blm.gov

This wild horse is available for sale or adoption with bids staring at $25.00. At the conclusion of the bidding, the successful bidder will inform the BoLM if they are purchasing or adopting the animal. If the animal is purchased, not adopted, the successful bidder receives bill of sale to the animal upon completion of payment and final paperwork. If the animal is adopted, the minimum bid must be $125, and the animal is not eligible for title until the one year anniversary.

Pick up options (by appt): Palomino Valley, NV; Delta, UT; Elm Creek, NE; Pauls Valley, OK.

Other pick up options: Ewing, IL (September 3) ; Mequon, WI (September 16); Clemson, SC (September 23); Loxahatchee, FL (September 30); and Murray, KY (October 7).

Adoption confirmation for this wild horse must be finalized, by e-mail to BLM_ES_INET_Adoption@blm.gov, no later than Noon Mountain August 4. After this date, all unclaimed wild horses will be available for in-person walk up adoption/purchase ONLY.

Diamond Complex Herd Management Areas

The Complex involves three HMAs, and areas outside of HMAs: the Diamond HMA is managed by the Battle Mountain District, the Diamond Hills North HMA by the Elko District and the Diamond Hills South (and areas outside of HMA boundaries) by the Ely District. Because the wild horses move around the HMAs across the Diamond Mountain Range, the three Districts work together to manage the Complex, according to BoLM.

PM Diamond Helicopter Roundup

Protect Mustangs is an organization who protects and preserves native and wild horses.

Does the Bureau of Land Management want to shoot wild horses with pesticides or sterilize them from helicopters now?

Pm PZP Darts


Speak out against motorized vehicles (helicopters, etc.) to roundup, dart underpopulated wild horses and burros as well as transporting them away from their homes forever!


Who says BLM won’t sterilize wild horses from helicopters?

BLM Spin Doctors put this out:

Battle Mountain, NV.—The Bureau of Land Management (BLM) will conduct a public hearing on the use of motorized vehicles including aircraft in the monitoring and management of wild horses and burros on public lands in Nevada.  The hearing will be held on Thursday, July 28, at 6 p.m. at the Bureau of Land Management Battle Mountain Office, 50 Bastian Road, Battle Mountain, NV 89820.

An annual public hearing is required to comply with Section 404 of the Federal Land Policy and Management Act.  The BLM proposes to use a helicopter, fixed wing aircraft and other motorized vehicles to conduct population surveys on herd management areas (HMAs) and obtain seasonal distribution information for wild horse and burro herds throughout Nevada.  Also proposed is using a helicopter to assist in gathering excess wild horses and burros on HMAs and complexes throughout the state during the coming year.  The actual number of areas where gathers or population surveys will be conducted will depend on a number of factors including funding. The hearing will also consider the use of motorized vehicles to transport gathered wild horses or burros as well as to conduct field monitoring activities.

We hope some real advocates will show up at the hearing to tell them wild horses are underpopulated and should be left free from harassment, period.

If you cannot attend the hearing, written comments must be mailed to the BLM Battle Mountain District Office, Attention: Shawna Richardson, 50 Bastian Road, Battle Mountain, Nevada 89820 and Email to: bmfoweb@blm.gov and be received by August 8, 2016 to be considered. Be sure to copy your senators and representative on your comments.

Keep in mind Shawna Richardson is an active member of the pro-livestock Facebook “Solutions” group pushing sterilization of America’s wild horses. Beware: Her buddies in wild horse advocacy will say she’s just trying to help the wild horses with the “tools in the toolbox”. That’s how the traitors hide the “Final Solution” for wild horses and burros.


Protect Mustangs is an organization who protects and preserves native and wild horses.

Emergency roundup that’s been planned since 2014 starts Monday

Stop the Roundups!

More wild horses will be removed forever

ELY, Nevada – The Bureau of Land Management (BLM) Ely District is scheduled on Monday to begin a helicopter roundup to wipe out approximately 100 wild horses from public and private lands adjacent to U.S. Highway 93 and State Route 322 in and outside the Caliente Herd Areas Complex and Eagle Herd Management Area in eastern Nevada. This issue could be resolved with fencing but they would rather spend the taxpayers money for the next 20 years to warehouse wild horses or send them to slaughter after the American taxpayer has fattened them up with hay.

The District will remove up to 50 wild horses from between Pioche and Eagle Valley that have moved outside the Eagle HMA in search of forage during last years drought. Now that the area is getting enough precipitation the BLM could simply push them back onto the HMA to save the taxpayers money. The Arbitrary Management Level (AML) for the Eagle HMA is 100-210 wild horses. The current population is 1,370 wild horses.

The District will remove up to 50 wild horses from Oak Spring Summit west of Caliente that have moved outside the Caliente Complex in search of forage. Why is the Caliente Complex managed for zero wild horses? The current population is 796 wild horses.

The roundup is expected to take four to six days to complete. A veterinarian will be on site during roundup operations, which will be conducted by a contractor.

The native wild horses will be removed forever, transported to the Axtell Contract Off-Range Corrals in Axtell, Utah, where they will be offered for adoption to qualified individuals if the BLM’s customer service improves. Un-adopted wild horses will be at risk of being sold to slaughter middlemen after 3 strikes in BLM’s failed adoption system or placed in long-term pastures where they will be humanely cared for and treated, and retain their “wild” status and protection under the 1971 Wild Free-Roaming Horses and Burros Act until they are over ten years old and then they legally can be sold by the truckload to a slaughterhouse in Canada or Mexico according to the Burn Amendment to dispose of wild horses and burros.
The BLM claims they do not sell or send any wild horses to slaughter. They sell them to the middlemen who then sell wild horses to slaughter. This way the BLM’s hands don’t get dirty.

The Eagle-Caliente Complex Emergency Gather is no emergency as it’s been planned to appease ranchers and county commissioners with greased palms since 2014. The impacts are described and analyzed in the Ely District Public Safety and Nuisance Gather Environmental Assessment available at http://1.usa.gov/23ws5je but almost no maps or data appears there. This is the bulk of the information

Have you wondered why no well funded group is challenging the roundup in court or mediating for alternative holistic management solutions? Is the BLM using fertility control or just removing all the wild horses?

Follow the money . . . Know what resources (renewable energy, tracking mining, etc.) are about to erupt in that area. Keep in mind this is the same BLM office and cast of shady characters who are involved in the Water Canyon GONACON™ EXPERIMENT.

The roundup Hotline has been established at 775-861-6700. A recorded message will provide updated roundup activities. Roundup reports will be posted on the BLM Ely District website at http://on.doi.gov/1lGnDYC.

Please go to the roundup if you can at your own risk, document and now that it’s 2016 be sure to report animal cruelty to the FBI if you see it. But be careful because this part of the country is run by wild horse hating scoundrels pretending to be otherwise.

For more information from a BLM employee, contact:

Ben Noyes, wild horse and burro specialist
BLM Ely District office
702 North Industrial Way
Ely, NV 89301
(775) 289-1800

Pm BLM Spin


Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.

Donate to save wild horses with the law on their side!

PM Helicopter Mustang Roundup

We are grateful our sucessful legal actions have stopped roundups and saved thousands of lives in the Pine Nut and Fort McDemitt areas. Protect Mustangs is creating a legal team to continue the fight for wild horse freedom in the courts. We almost didn’t find lawyers in time to help save the Pine Nut herd. We need to hire a staff lawyer

The team at Protect Mustangs feels legal action is a very important area of focus with a huge impact to save many lives.

Please make your donation to the Wild Horse Legal Fund today because the Pine Nut, Nevada, California, Wyoming, and other wild horses need legal protection again. The palm greasers going to BLM want them gone and we will take action. Click here to donate: https://www.gofundme.com/MustangLaw2016

Did you know that Academy Award-winner Michael Blake (Dances with Wolves), RIP, joined our Fort McDermitt lawsuit in 2013 to help stop two years of horrible roundups that were sending wild horses to slaughter?

Michael Blake wins Oscar for writing Dances with Wolves
This is what Michael Blake wrote on August 21, 2013:

I, Michael Lennox Blake, declare and state as follows:

1. I am an author as well as a screenwriter. I have written several books and screenplays including Dances with Wolves, which was released to international acclaim in 1990. In 1991, I won every major award for my screenplay for Dances with Wolves, including an Academy Award, Golden Globe, Writer’s Guild Award, and the Silver Spur. I have also received public service awards including the Eleanor Roosevelt Award and the Americanism Award, in addition to many other awards during my life.

2. I reside in Sonoita, Arizona. I am a member of Protect Mustangs, and also am on the Advisory Board for Protect Mustangs. In a professional capacity I am an author and screenwriter. I support the work that Protect Mustangs does to protect wild horses and advocate for effective wild horse conservation on public lands.

3. I have visited Nevada for decades to see the wild horses, study them, and be inspired by them for my work. I have explored the lands of Nevada where the wild horses roam in freedom for inspiration and research for my work. I intend to return to these areas so I may continue to be inspired and do research for my work.

4. In 1992, I helped commission the first comprehensive aerial census of wild horses in Nevada. In almost every herd area, the horses were far less numerous than the BLM estimated. The final count in our survey was 8,324.

5. Protect Mustangs’ members are interested in wild horses, and I support their work to protect wild horses’ freedom and safety from cruel and harmful practices including but not limited to illegal roundups. Their mission is to educate the public about indigenous wild horses, protect and research American wild horses on the range, and help those who have lost their freedom. Protect Mustangs works to educate the public about the decisions and activities of the government that impact wild horses, and find solutions for wild horse conservation that does not include roundups and auctioning off wild horses for slaughter. Members of the public and horse advocates across the United States are interested in and support Protect Mustangs’ work to protect wild horses due to their recreational, scientific, spiritual, ecological, cultural, artistic, historical, iconic, and aesthetic values.

6. I wrote in my book Twelve the King:

“But he and hundreds of thousand like him are gone now from this beautiful land, and for that reason alone I could not stop as I traveled over four hundred miles of Nevada roads. Something evil is still afoot in this land, and it has left its imprint everywhere. In all those miles of open, free country, the mark of evil is present in what is absent. The wild horses are missing from the land.”

7. I have written extensively about the American West and find inspiration seeing and studying wild horses. If these unbranded, wild horses are rounded up and removed by the USDA Forest Service and/or the BLM on tribal land, or elsewhere by the Forest Service and/or the BLM, I will be harmed because I will no longer have the ability to study them or be inspired for my books, stories and other works.

8. Wild horses and their connection with the land in the American West inspire me to write. I have plans to spend time in the future using and enjoying these lands and studying free-roaming wild horses on public lands in the Owyhee HMAs and where the wild horses roam in the Humboldt-Toiyabe National Forest, as well as on tribal lands. The proposed gather on USDA Forest Service and tribal lands will forever remove wild and free-roaming horses that I rely upon in my professional and personal capabilities.

9. I derive significant satisfaction and happiness from the existence of native wild, free- roaming horses. Ensuring the continued existence and distribution of wildlife including wild horses in the West is of the utmost importance to me and has directly influenced my life a great deal. The West is far different than the East because the West still has wildlife—including wild horses that inspire me to write fiction and non-fiction.

10. If the Fort McDermitt Horse Gather proceeds as planned, it will prevent me and other members of Protect Mustangs from recreating, enjoying, studying, being inspired from, and writing about the wild horses in the area in the future. I am very unlikely to continue deriving benefit and inspiration concerning the wild horses in an area where they have been removed and herd numbers drastically reduced as is proposed by the Fort McDermitt Horse Gather and the 2013 Agreement between the Forest Service and Fort McDermitt Tribal Council. Our members share these views as well.

11. I have been studying and gaining inspiration from seeing wild horses in Nevada throughout my life. I have certain plans to continue visiting these wild areas of Nevada authorized for roundup, including the Humboldt-Toiyabe National Forest, throughout my lifetime. For the aforementioned reasons I would be directly harmed should the unbranded, wild horses at issue in the Fort McDermitt Horse Gather be removed and the horses rounded up and be allowed to go to holding, auction, sale, or slaughter.

[End of Michael Lennox Blake’s declaration]

HELP build the legal fund today so Protect Mustangs can continue to fight for wild horses in court. We are a unique group dedicated purely to the protection and preservation of America’s wild horses. We need to act quickly and independently to HELP SAVE wild horses with legal action. Please make a donation today and share this fundraiser: https://www.gofundme.com/MustangLaw2016 or donate via PayPal to Contact@ProtectMustangs.org

Thank you for taking action today to help save the wild horses!

Many blessings,

Anne Novak
Volunteer Executive Director
Non-profit mission: Protect and preserve native and wild horses

PO Box 5661
Berkeley, CA. 94705

PM Pine Nut 332 90K meme

Lennox August 2014

Marybeth Devlin comments on the Sulphur Wild Horse roundup plan

Email: blm_ut_sulphur@blm.gov

Copies: jwhitloc@blm.gov, tchristense@blm.gov, eburghar@blm.gov
January 19, 2016
Cedar City Field Office
176 E DL Sargent Drive
Cedar City, UT 84721
Project Name: Sulphur Wild Horse Gather Plan

Document: Environmental Assessment — Preliminary

NEPA ID: DOI-UT-C010-2015-0011-EA
This letter responds to your request for substantive comments and new information that BLM-Cedar City should consider regarding the subject Plan. I submit mine as an interested party in behalf of the wild horses of the Sulphur Herd Management Area (HMA).

I support the use of radio collars to track the horses and the construction of a fence along Highway 21 for the safety of both horses and humans. However, I urge you to cancel the roundup-and-removals, discontinue PZP treatments, correct the fraudulent population-estimates, and take other specified corrective actions.

I suggest the addition of another alternative: Increase the AML, collar the horses, fence the Highway but remove interior fences, conserve apex predators, and install guzzlers throughout the HMA.

As for the proposed alternative, if BLM has confidence in the WinEquus population-growth modeling, then please note that the “removals only” alternative yields a median-trial average herd-size that is nearly 24% lower than the proposed alternative — 318 versus 417. As for PZP injections, they should be abandoned because they are dangerous to the mares, to the foals (born and unborn), and to the staff and volunteers that handle the pesticide.

For ease of reference, here are the links to the documents at issue:

News Release — 2015 EA


News Release — 2015 Public-Safety Removals


Sulphur Gather Environmental Assessment — Preliminary

Overpopulation, Forage Limitations

BLM lists overpopulation and forage / water limitations as the need for the proposed action. The “overpopulation” in this case merely means “over AML”. And because the AML is arbitrary and unscientific, it is meaningless. Range-conditions function as natural feedback to wild horses, allowing them to self-regulate their numbers. That is how Nature works. BLM is meddling unnecessarily. The intervention that is needed would be to offset the impact of livestock-grazing — eliminating interior fences that block wild-horse movement and installation of trick-tanks (guzzlers) to capture and store precipitation.
The Proposed Action

BLM-Cedar City plans to conduct two-to-four helicopter-style roundups-and-removal operations over the next 10 years to bring the herd’s alleged overpopulation down to the low-bound of the arbitrary management level (AML) — 165 horses on 265,675 acres — and maintain it there. BLM claims there are “excess” horses but the EA does not reveal the number. Instead, the EA goes on and on about the historical numbers and removals. Not even a “ballpark” figure is listed for how many horses BLM would remove initially, some sources have mentioned “over 500.”

BLM further plans to forcibly inject all of those few mares it plans to allow back into the HMA with PZP-22, the long-acting version of the pesticide. PZP is known to sterilize after as few as three injections in mares, or after just one shot in fillies that have not yet reached puberty. And the EA states that BLM plans to administer PZP treatments to yearling fillies.

Baseless and Biased Assumptions

A review of BLM’s data — its assumptions, claims, population-estimates, gather-data, and PZP-inoculations — for the Sulphur herd disclosed

Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes,
Ignorance of the new study that found the effective birth-rate averages 10 percent,
Ignorance of the new data showing “hands-off” management results in 5-to-8 percent growth,
Failure to include studies — both old and new — that reveal PZP’s damaging impacts, and
Birth Rate versus Herd-Growth Rate

Before we examine BLM’s reported herd-growth rates of this HMA, it is important to understand the difference between the birth rate and the herd-growth rate. The birth-rate is not the same as — and should not be equated to — the population growth-rate. BLM claims an average birth rate in wild-horse herds of about 20% a year. But herd-growth is unlikely to reach 20 percent a year. Here’s why: Horses die.

An independent study reviewed BLM roundup-records for a representative sample of four herd management areas and a robust sample-size of 5,859 wild horses (Gregg, LeBlanc, and Johnston, 2014). While the researchers found an overall birth rate of just under 20 percent, they also found that half of foals perish in their first year of life. Thus, the effective foal-to-yearling survival rate is just 10 percent. Cedar City’s claim that 95% of the Sulphur foals survive is not credible. It is just self-serving for administrative convenience in equating the birth rate to the growth rate. That wrong assumption has been disproved. Moreover, I note that the 2013 inventory counted 25 foals born out of season. That anomaly was likely due to the PZP treatments, which research by Ransom et al. (2013) disclosed.


However, CCFO failed to include that study as a reference; and although it did cite another Ransom et al. study (2010), it was not included in the EA’s “References” section either.

Births outside the normal parturition-pulse put the survival of both the mares and foals at risk.
Adult Wild-Horse Mortality Rate Must Be Factored

But it is not only foals that die. Adult wild horses also perish. They succumb to illness, injury, and predation. Indeed, the EA claims that 8 horses were found dead in 2015. The adult death rate must be taken into consideration. Adult mortality is at least as high as the 5% a year for horses that die in short-term holding, where they are fed, watered, and provided care.

Given the 50% foal mortality-rate, and the 5%-or-higher average annual death rate of adult wild horses on the range, herd growth could not increase 20% a year, and a herd-population could not double in 4 years — refuting yet another BLM myth. But BLM ignores mortality — foal and adult — in its population-estimates, which exaggerates the numbers it posts.
The Herd-Growth Rate Must Necessarily Be Lower Than the Birth Rate

In light of the high foal-mortality rate and the expected adult wild-horse mortality rate, the herd-growth rate must always be lower than the average 20% birth rate. However, herd-growth rates many times higher than 20% — which would necessarily mean birth rates substantially higher still — are routinely found in BLM’s population data, including the year-to-year figures for Sulphur HMA and other HMAs under Cedar City Field Office’s jurisdiction. Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates — that is one of the ways BLM creates the false impression of a population-explosion.
Stochastic Events Also Reduce Herd Growth

BLM also fails to consider another factor limiting herd growth — stochastic events — which are random catastrophes such as wildfires or contagious diseases or pesticide treatments that suddenly wipe out mass-numbers of herd-members. Stochastic events can result in no-growth or even negative growth.

There was such an event recently in Kazakhstan, where 120,000 endangered Saiga antelope — half the world’s population — died off suddenly and inexplicably.


Imagine if such a catastrophe were to befall the Sulphur herd. Note that the Saiga deaths involved antelope-mothers and their calves. What if Sulphur’s few fertile mares and their foals perished all of a sudden, leaving mainly stallions and sterile old mares? BLM must proactively manage the herd per IUCN International Union for the Conservation of Nature guidelines, if only in case of stochastic events.
Maximum AML Set Below Minimum Viable Population

But “cooking the books” is not the only way BLM falsifies the population-picture. Another ruse BLM employs is restricting maximum herd-size below minimum-viable population (MVP) size. Then, whenever a herd is made to appear — via fictitious figures — to exceed the arbitrary management level, BLM screams “excess!” and declares an immediate need for mass-removals and sterilizations. It should be noted that more than 70 percent of the herds are “managed” below MVP, including Sulphur. What is the MVP? According to the International Union for the Conservation of Nature: 2500, a number which could easily be accommodated by the 265,675 acres of the Sulphur HMA.
Phony Population-Estimates

According to BLM’s 2013 population-estimate, the Sulphur herd was reported to have had 384 members. The corresponding estimate for 2014 showed 718 horses.


Let’s do the math.

718 in 2014
– 384 in 2013
334 — an 87-percent increase (334 ÷ 384 = 87%).

This is improbable. Even if 87% were only the birth rate, it would be 335% higher than the 20% birth rate that BLM claims as average and which the independent study by Gregg et al. confirmed. Surely, herd growth — births minus deaths — could not be that high.

BLM attributes the impossibly-high estimate to “improved inventory methods.” But as has been pointed out to BLM previously, the “mark-resight” method, conducted by helicopter, appears to overcount the population. Indeed, as the report by the specialty-contractor who conducted the Red Desert Complex (Wyoming) census emphasized, there are assumptions and caveats that must be considered when evaluating the numbers, including the potential for having double-counted due to “horse activity (moving).” The method itself exaggerates the numbers.

Population and Gather Reports — The Data

Discrepancies were evident per a review of the …

HMA and HA Statistics reports for the Sulphur herd from 2008-2015,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in CCFO’s News-Release for 2015’s public-safety gather,
Sulphur HMA — Utah — Herd Population Changes — 2008 to 2016

The following chart merges the yearly population-estimates with the gather and contraceptive data to reveal how the numbers were calculated and where errors were made initially, which caused them to compound. The beginning-of-the-year figure for 2015 — the pre-gather estimate — was per the BLM’s pre-safety-gather News Release.

Max Beginning
Year AML Estimate R-up Done Foal-Crop and Other Figures, Estimates
2008 250 435 + 87 BLM estimated foal-crop @ 20%.
Falsely equated it to the herd-growth rate.
November 522 Pre-gather estimate = 435+87
362 Rounded up
333 Removed
29 Released
160 Assumed to have evaded capture
1 Tacked on
190 Post-gather estimate = 29+160+1
2009 190 + 40 BLM estimated foal-crop @ 21%
Falsely equated it to the herd-growth rate.
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
Falsely equated it to the herd-growth rate.
December 297 Pre-gather estimate = 230+67
250 Planned to gather
90 Rounded up — 36% of plan
30 Removed
38 Mares vaccinated with PZP
22 Other horses also released
207 Assumed: evaded capture
267 Post-gather estimate = 38+22+207

2011 267 + 53 BLM estimated foal-crop @ 20%
Falsely equated it to the herd-growth rate.
PZP would not have affected mares
—– already pregnant when inoculated.
320 End-of-year estimate = 267+53
2012 320 + 64 BLM estimated foal-crop @ 20%
Falsely equated it to the herd-growth rate.
But that birth-rate estimate was wrong.
PZP was at maximum effect and
—– would have reduced the foal-crop.
384 End-of-year estimate = 320+64

2013 384 +334 BLM estimated foal-crop @ 87%
Falsely equated it to the herd-growth rate.
Not only implausible generally, but
PZP was still exerting contraceptive
—– effect, would have reduced foal-crop.
718 End-of-year estimate = 384+334
2014 718 +144 BLM estimated foal-crop @ 20%
thus compounding earlier errors.
Falsely equated it to the herd-growth rate.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
830 End-of-year estimate = 718+144-30-2
2015 830 Public health and safety excuse used
to justify removing 100 wild horses
without an EA.
February – 101 Number removed — plus 2 horses
said to be “domestic.”
The subject EA states: “Currently there are
approximately 200 head of wild horses that
are within 6 miles of Highway 21. These
horses are continually on the highway in search
of space, forage and water.” EA pdf-page 28
My comments: So, 200 took the place of the
100? Implausible. Wild horses roam. It’s their
nature. That’s why a safety-fence is needed.
729 Adjusted population estimate
2015a 729 146 If BLM estimates foal-crop @ 20%
and falsely equates it to the herd-growth rate.
– 8 Deaths
867 End-of-year estimate = 729+146-8
2016 867 173 If BLM estimates foal-crop @ 20%
and falsely equates it to the herd-growth rate.
1040 Possible pre-gather estimate = 867+173
The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.
Not the First Time Population-Estimates Were Found to Be Flawed

In May 2014, I submitted comments regarding the environmental assessment for Bible Spring Complex, which is also under BLM-Cedar City’s jurisdiction. For the three HMAs and the one HA that compose the Complex, major discrepancies were disclosed — one-year growth-rate-estimates of …

125 %
131 %
153 %
157 %
249 %

Thus, the errors uncovered with regard to BLM’s population-estimates for the Sulphur HMA are not isolated instances. Together with those revealed for the Bible Spring Complex, these disparities point to a systemic problem.

Recommendations: BLM needs to correct its mathematical errors and acknowledge those mistakes to the public. Elected officials, local permittees, and ordinary taxpayers need to know that the population-estimates previously announced for the Sulphur HMA were wrong. BLM must take responsibility and inform the public that it portrayed an incorrect picture — an exaggerated picture — of the herd’s population.

Recommendations: Stop the inflammatory rhetoric. For example, the EA warns, ominously: “If horse populations were allowed to continue to double or triple throughout the HMA, wild horses would utilize all of the available AUM’s allocated for other resources.” EA pdf-page 27 Scare tactics have no place in a legitimate EA. Stop the nonsense.
Societal Impact of Inflated Population-Data

The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public — particularly local elected officials and permittees — in an uproar over a false “overpopulation” that BLM’s faulty figures portray.

BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.
County Commissions Pass Resolutions, but Commissioner Goes to Jail

The EA cited the resolutions that local county commissions have reportedly passed, demanding that BLM reduce the herd to AML. However, one of the ringleader-commissioners, Phil Lyman, was recently sentenced to jail after having been convicted of conspiring to operate off-road vehicles on public lands closed to off-road vehicles, and operation of off-road vehicles on public lands closed to off-road vehicles. He and a co-conspirator must pay their share of $96,000 in damage caused and serve 3 years probation.

Federal prosecutor Jared Bennett asked the judge to sentence Lyman to a “limited but reasonable” prison term to promote respect for the law and to deter others from committing the crime. Lyman knew the ride was illegal and he used his political office to recruit others to participate, he said.

Bogus Data Inflames Local Ranchers and Costs Wild Horses Their Freedom

The EA states that there have been requests over the past two years from land owners adjacent to the Sulphur HMA for removal of wild horses. These requests most surely came from renegade ranchers, such as LaVoy Finicum of Arizona who, inspired by Cliven Bundy, has gone public with his refusal to recognize BLM’s authority, to pay his grazing fees, and to comply with season-of-use. In Nevada, in addition to Cliven Bundy, Kevin Borba and Dan Filippini blatantly defied BLM’s authority; yet they too were pacified with concessions. BLM enables and rewards such bad behavior by caving in to it. There are likely permittees in Utah emulating Bundy, Borba, Filippini, and Finicum.


The EA’s proposed removals of wild horses and pesticide-treatments on the few allowed to remain appear designed to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by fictitious figures on herd-growth.
Bundy Brothera and Finicum Lead Armed Takeover of the Malheur National Wildlife Refuge

Ammon and Ryan Bundy, along with LaVoy Finicum are the “spokesmen” who have commandeered the Malheur Wildlife Refuge. Armed for battle, they continue, as of this writing, to occupy. Using Federal vehicles and machinery, they tore down a fence built to keep trespass-livestock out. They come and go as they please, even soliciting snacks and coffee creamer (French Vanilla) from supporters. The situation is out of control. BLM and FBI appear to be kowtowing to the rebels.

Here are excerpts from a news report:

The militants occupying the Refuge asked Harney County ranchers to tear up their leases with the Bureau of Land Management and stop paying the federal government to graze cattle on public land.

“I’ve done it. Cliven Bundy’s done it,” said LaVoy Finicum, an Arizona rancher and the militants’ defacto spokesman. “Now is the day. Now is the time. Are you going to wait for tomorrow? For next week? Next month? Next year? When? When will you stand up if not now?”

Finicum invited the ranchers to cancel their leases with the BLM at a ceremony before the media at the refuge on Saturday. He said two ranchers, one from New Mexico and another from Harney County, are scheduled to void their contracts publicly.

Ryan Bundy went on to emphasize his view that breaking away from the federal government means ranchers wouldn’t have to follow federal laws, like the Endangered Species Act.

LaVoy and the Bundys also acknowledged their proposition is risky. They said any rancher who joined them would get protection from the armed militants ….

CAWP Condones Abuse

The Comprehensive Animal Welfare Program (CAWP) for rounding up wild horses has farcical features. For example, hitting, kicking, striking, and beating a wild horse “in an abusive manner” is prohibited. The guidelines do not define at what point such mistreatment would be deemed “abusive” and, at any rate, there are no consequences identified for violating the prohibition.

Another example: The roundup–helicopter–the CAWP okays the use of helicopters — is not allowed to hit a wild horse. (There is plenty of video-footage showing that such ramming occurs.) If the helicopter hits a wild horse, what to do? The CAWP says: Document it! Again, there are no penalties for such abuse.

Yet another example: The helicopter-pilot must not drive wild horses to the point of exhaustion. The attending veterinarian–if there is one (the CAWP requires one be present but the EA says there “may” be one)–must “check for signs of exhaustion.” And …? And, nothing. Just check. No penalties.

One more example: The CAWP allows electric prods to be used on the horses “no more than three times during a procedure … except in extreme cases with approval ….” Who’s counting? Who is able to supervise properly in the chaotic conditions of a wild-horse roundup? Hotshots are abusive and should never be used. Ever.
BLM Lies about Impact of Abusive Roundup

The EA’s standard wording disinforms the reader that virtually all negative impacts of roundups disappear within hours to several days of when wild horses are released back into the HMA. That is false. Please refer to the report linked below. I recommend BLM add it to the “References” section after studying it and reforming your methods accordingly.

BLM Fails to Address Results of Helicopter Hearing

The EA states:

As required by regulation [43 CFR 4740.1(b)], a public hearing was held in Price, Utah on December 8, 2015 and will be held in subsequent years to discuss the use of helicopters and motorized vehicles in the management of Utah BLM’s wild horses and burros. … Comments received from the Preliminary Environmental Assessment (EA) and at those public meetings will be considered and, if applicable, will be addressed in management actions, NEPA documents, and decision documents using the most current direction from the National Wild Horse and Burro Program. EA pdf-page 44

I submitted detailed, substantive comments for the hearing. By now, BLM should have acted upon them and made reforms.
BLM Lies about Foal Weaning

In more standard wording, the EA states: “Nearly all foals that would be gathered would be over four months of age and some would be ready for weaning from their mothers. In private industry, domestic horses are normally weaned between four and six months of age.” EA pdf-page 37

Please note that in “private industry,” foals receive special feed and supplements, and they would be sheltered from the elements. In the wild, foals nurse for many months longer than in domestic settings, where the profit-motive leads breeders to wean early — a traumatic event for both foals and their dams.
Increased Foaling Rates?

BLM claims to need to reduce the wild-horse population. Yet the EA states: “Achieving the AML and improving the overall health and fitness of wild horses could also increase foaling and foaling survival rates over the current conditions.” EA pdf-page 36 This is an example of BLM’s eagerness to justify the unjustifiable. But in so doing, BLM belies its own contentions.
BLM Lies about Population Growth

In looking for every reason not to adopt any alternative but the proposed one, BLM insists repeatedly that unless mass-removals and PZP treatments are conducted, “… wild horse populations may increase at a faster rate and exceed the high end of the AML ….” EA pdf-page 38 However, that contradicts the WinEquus population-projections, which show a higher median-trial population for the proposed action.
BLM Lies about PZP Safety

The EA claims PZP injections would not affect unborn foals. That is false.

Sacco et al. reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques. These findings were disclosed in 1981. Yet, PZP is regularly administered to pregnant and lactating mares, who transfer the destructive antibodies to their fetus, via the placenta, and to their foal, via mother’s milk.

If mares are injected with PZP while pregnant or nursing, these fillies will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when such fillies are injected as yearlings, it will be their second treatment, or potentially even their third. In fact, they could already have been sterilized in utero or while nursing.

BLM Lies about Gender Ratio

The EA warns that gender-ratios could become lopsided if the proposed action were not taken: “Near normal populations exhibit a 1:1 sex ratio. Population shifts favoring males could occur as males are better adapted to compete for resources during changing environmental conditions.” EA pdf-page 41

But BLM also advises that, for the WinEquus population-modeling trials, one of the assumptions employed was: “Sex ratio at birth: 58% males.” EA pdf-page 90 Further, I note that following the 2008 gather, 12 females and 17 males were returned to the range, giving males a 59:41 percent advantage to the males. Finally, bachelor-stallions are more successful in escaping from helicopter-roundups. They have no mares and foals to protect. So, the roundup-method itself creates a post-gather herd skewed to more males than females.
BLM Uses Obsolete Range Assessment Technique

The EA states that the “Key Forage” method was used to evaluate range-conditions. The full title of that approach is the “Key Forage Plant” (KFP) method. However, KFP is obsolete, having been replaced by the Landscape Appearance method as far back as 1996. Moreover, per Technical Reference 1734-7, Ecological Site Inventory, such qualitative assessments “may result in reduced accuracy, limiting use of the data.” If for only this reason, I cannot rely on the EA’s representations regarding conditions in the Sulphur HMA.
BLM Lies about Year-Round Wild-Horse Presence

The EA states that wild horses do more damage because they are present year-round as opposed to livestock, which supposedly are not. However, inspection of the Active-Use chart EA pdf-page 20 reveals that nearly 49% of the livestock allotments are used year-round, and 67% are used 8-to-12 months. Further, actual-use is whatever the permit-holders self-report. Going back to the rogue ranchers in open rebellion against BLM, it is likely that real use is much higher than “actual.”
BLM Hauls Water but Fails to Install Guzzlers

BLM states that water is the limiting factor for wild-horse populations, and claims to have hauled 160,000 galllons of water into the HMA last summer for the wild horses. EA pdf-page 20 What this points to is the need for guzzlers — trick-tanks — to capture and store whatever precipitation there is.
BLM Falsely Blames Wild Horses for Damage to Riparian Areas

In its zeal to condemn the wild horses, BLM lumps wild horses in with livestock as responsible for damage to riparian areas. Yet, the EA also notes that it “is not the nature of wild horses to rest exceedingly at water sources.” EA pdf-page 53 Stop the false accusations. Your bias is showing.
BLM Plans to Use Barbed Wire for Safety Fence

Horses and barbed wire do not mix. Yet, the EA states that barbed wire will be used for the fence along Highway 21. That is not good enough. You need to use appropriate materials that pose less risk of injuring the horses.

Here are some links to information on the various types of fences and their price-ranges. Note: I have no connection whatsoever with any of these groups.




BLM Notes Interior Fences Block Wild Horses

The EA admits, without further explanation: “Construction of fences within Sulphur HMA boundaries could inhibit the free-roaming nature of wild horses.” EA pdf-page 42 It is time to remove interior fences, not to install more. This matter needs to be resolved.
Finally, Some Truth-Telling

It was refreshing to encounter at least some truthfulness in the EA:

At the turn of the century, large herds of livestock grazed on unreserved public domain in uncontrolled open range. Eventually, the range was stocked beyond its capacity, causing changes in plant, soil and water relationships. Some speculate that the changes were permanent and irreversible, turning plant communities from grass and herbaceous species to brush and trees. EA pdf-page 43

BLM needs to stick to the facts and cease blaming wild horses for what livestock already did.

Please consider these substantive comments and new information — new to BLM — and make the necessary course-corrections and reforms.

Marybeth Devlin

URGENT: Petition to stop violent wild horses roundups and stop sending them to slaughter!

Wild horses are a native species who must be saved!

Sign and share the urgent petition

Loopholes allow the BLM to sell thousands of wild horses to slaughter middlemen known as kill buyers to dispose of alleged “excess and unadoptable” American wild horses and this must stop now! Slaughter is cruel and inhumane.

This is what cruel roundups look like:

Roundups are the first step towards slaughter.

Craig Downer published the peer reviewed paper titled The Horse and Burro as Positively Contributing Returned Natives in North America.

According to a press release from National Academy of Sciences (NAS) released June 5, 2013, “The U.S. Bureau of Land Management’s (BLM) current practice of removing free-ranging horses from public lands promotes a high population growth rate, and maintaining them in long-term holding facilities is both economically unsustainable and incongruent with public expectations, says a new report by the National Research Council.”

The NAS report states there is “no evidence” of overpopulation. Only tobacco science and spin backs up BLM’s population claim to justify roundups and fertility control/sterilizations. . .

PZP is an EPA approved RESTRICTED-USE PESTICIDE that sterilizes wild horses after multiple use so it’s risky for long-term herd survival. See information here: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

Giving PZP to wild mares also results in foals being born late in the fall or winter and dying because they are too little to make it through a harsh winter.

Fertility control research trials are big business. Left unchallenged, wild horses and burros will continue to be lab rats for human fertility control research. This exploitation must stop!

We request an immediate halt to roundups for scientific population studies and studies on holistic management before it’s too late.

Wild horses are a returned-native species in America. Rounding up federally protected wild horses and burros has been documented as cruel. Warehousing them for decades is fiscally irresponsible. Sending wild horses to slaughter by selling them to middlemen is cruel and inhumane. Clearing wild horses and burros off public land–for industrialization, fracking, grazing and the water grab–goes against the 1971 Free Roaming Wild Horse and Burro Act put in place to protect the living legends of the American West. They must never go to slaughter.

We request you defund and stop the roundups immediately as well as reverse the Burns Amendment to stop unlimited sales of wild horses to slaughter.

There is no accurate census and the BLM figures do not add up. We request population studies for each herd management area (HMA) and each herd area (HA) because we are gravely concerned there are less than 18,000 wild horses and burros in the 10 western states combined. More roundups, fertility control/sterilizations and sales to slaughter will wipe them out because the majority are no longer genetically viable herds.

Wild horses are underpopulated despite spin from the forces that want to perform heinous sterilizations in the field. Humane fertility control could be looked at as an option only after scientific population studies have been conducted for each herd management area. The EPA approved restricted-use pesticides known as PZP and Gonacon have risks as do other drugs . . . Right now fertility control is premature, will destroy natural selection and could cause harm because wild horses are underpopulated in the West.

Field observers have noticed a worrisome decline in wild horse and burro populations since the BLM’s rampant roundups from 2009 to this day.

Kindly allow returned-native wild horses and burros to reverse desertification, reduce the fuel for wildfires and create biodiversity on public land, live with their families and inspire us with their spirit.

Right now America’s wild horses and burros are being managed to extinction. They need your help to stop the roundups and slaughter today.

Go to the petition on Change.org here and email it to your friends and family: https://www.change.org/p/defund-and-stop-the-wild-horse-amp-burro-roundups

BLM Ely, Nevada, district to roundup native wild horses

Visit Nevada?

The Bureau of Land Management (BLM) Ely District is scheduled in early November to begin rounding up and removing approximately 120 alleged excess wild horses from in and around the Triple B and Silver King herd management areas (HMAs) in eastern Nevada.

Details will be posted on the district website as they become available. The roundups are allegedly necessary to prevent further damage to private property and provide for public and animal safety.

The district will remove about 70 alleged excess wild horses from the Triple B HMA, located about 30 miles northwest of Ely, that are allegedly damaging private property, and allegedly harassing and breeding domestic stock resulting in landowner complaints. Appropriate Management Level (AML) for the Triple B HMA is 215-250 wild horses. The current population is 1,311 wild horses.

The district will remove up to 50 excess wild horses from in and around the Silver King HMA. The horses to be gathered are located about 120 miles south of Ely. They are an alleged safety concern on U.S. Highway 93 and are damaging private property, resulting in property owner complaints. The AML for the Silver King HMA is 60-128 wild horses. The current population is 452 wild horses.

The BLM claims attempts to keep wild horses away from private property and the highway, including trapping and relocating animals to other portions of the HMAs, have been unsuccessful.

The BLM will utilize the services of roundup contractor Cattoor Livestock Roundup, Inc., of Nephi, Utah, which uses a helicopter to locate and stampede wild horses toward a set of corrals to be trapped and who has already been paid millions of tax dollars, year after year. The pilot is assisted by a ground crew and a domesticated horse, known as a Judas horse who is trained to lead wild horses into the corral.

Wild horses removed from the range will be transported to the National Wild Horse and Burro Center at Palomino Valley, in Reno, Nevada, where they will be offered for adoption to qualified individuals. Wild horses for which BLM is unable to adopt out will be placed in long-term pastures where they will be allegedly humanely cared for and retain their “wild” status and protection under the 1971 Wild Free-Roaming Horses and Burros Act.

A Wild Horse Gather Information Line has been established at 775/861-6700. A recorded message will provide information on daily gather activities and schedules. The BLM will also post daily gather information on its website.

Public lands within the HMAs will be open to the public during gather operations, subject to necessary safety restrictions, and the BLM will make every effort to allow for public viewing opportunities. The BLM has established protocols for visitors to ensure the safety of the wild horses, the public, and BLM and contract staff. The protocols are available at http://on.doi.gov/1lGnDYC under “Observation Opportunities.”

Roundups in and outside the Triple B HMA were analyzed in the Triple B, Maverick-Medicine, and Antelope Valley HMA Gather Plan and Environmental Assessment (EA), signed in May 2011 and available at http://on.doi.gov/1tgdHc6. Gather activities in and around the Silver King HMA were analyzed in the Ely District Public Safety and Nuisance Gather EA signed in August 2014 and available at http://on.doi.gov/1lx856K.

For more information, contact Chris Hanefeld, BLM Ely District public affairs specialist, at 775/289-1842 or chanefel@blm.gov.

An American writes to the BLM against helicopter roundups in Wyoming


© Protect Mustangs

© Protect Mustangs

July 16, 2014

Bureau of Land Management
Wyoming — State, District, and Affected Field Offices
Wyoming — Annual Hearing — Use of Helicopters, Motorized Vehicles

Per the standard practice for BLM state offices that administer the Wild Horse and Burro Program to hold an annual hearing on the use of motorized vehicles and aircraft — chiefly helicopters — for counting, capturing, and carting off wild horses and burros, such a meeting has been scheduled for this date in Rock Springs, Wyoming. I regret that I cannot attend the hearing. However, I am submitting information, recommendations, and alternatives as an interested party in behalf of the wild horses of Wyoming. I request that my comments be read aloud at the hearing.
HELICOPTERS — Dangerous to Humans
Scheduled Airliners — Safe; Helicopters — Crash-Prone

The American public considers travel-by-air to be safe, even routine. Crashes are rare, and fatalities, few. Thus, it is easy to assume that all flight is safe, which is not the case.

Helicopters are notorious for crashing. Please compare and contrast Wyoming’s aviation crash-records of scheduled air carriers versus helicopters during the 42-plus years since the passage of the Wild and Free-Roaming Horses and Burros Act of 1971 — the period from January 1, 1972 to May 31, 2014 — per the National Transportation Safety Board (NTSB):

Scheduled Air Carriers (“Part 121”)

14 — Accidents and incidents (minor events excluded)
0 — Accidents that resulted in fatalities


113 — Accidents and incidents (minor events excluded)
5 — Accidents that resulted in fatalities
6 — Number of persons that died in those accidents

At the link below, you can replicate the searches to verify these data.


Similarity to Aerial Hunting

In the United States, more than a hundred helicopters and planes have crashed while conducting aerial hunting, whose procedures closely resemble those involved in rounding up wild horses. Just as with BLM gathers, aerial-hunting pilots fly only a few feet off the ground and perform risky maneuvers from which they may not be able to recover.


Moreover, the long hours involved, and the frustrations of working with frightened, unpredictable animals, can lead to pilot error. Video documentation is plentiful of helicopter pilots ramming horses and burros with their landing skids, seemingly intentionally.

Helicopter Accident and Incident Record during Wild Horse Roundups

Helicopters have crashed while rounding up wild horses. BLM admits to approximately 10 helicopter accidents and “hard landings” during wild-horse gathers over the past 30 years or so. That’s about one crash every three years. What airline would stay in business with such a safety record?

Using helicopters for gathering wild horses and burros is inherently risky, with no greater purposes than administrative convenience and “efficiency.” Such purposes do not justify the risks. There is no imminent threat to life or property that would require the use of helicopters to roundup some horses. BLM is wrong to continue this dangerous activity when a safe alternative is available — bait trapping.

Helicopter Census Method Puts BLM Personnel at Risk

BLM’s environmental assessments often allude to the use of “multiple experienced observers” (whom I suppose to be BLM staffers) to count and photograph wild horses — or what they think are wild horses — while being flown in grid patterns over the range.

Given the crash-proneness of helicopters, BLM could face a tragedy — with loss of several key personnel, friends, and colleagues in an accident. Counting wild horses does not justify this risky method. Instead, consider bait-and-or-water trapping every member of each herd — without removals. Fit them with telemetry collars, and track them.

Helicopters — Some Recent and Relevant Accidents

1. On February 18, 2013, a helicopter belonging to El Aero Services, Inc. took off from its home-base in Elko, Nevada to perform certain operations on behalf of BLM. The helicopter subsequently crashed near Eureka, Nevada. The pilot was killed. Here is the link to the National Transportation Safety Board’s (NTSB) report:


Please note that, on one of the helicopter-runs preceding the crash, BLM’s Helicopter Manager was aboard. Moreover, the NTSB report seems to suggest that the accident may have been caused, at least in part, by pilot-fatigue. Best practices (US Army flight regulations) would have called for reduced “time-on-task” — no more than 37 hours per week, with additional reductions by factors of 1.3 to 1.6 due to low-altitude flight, which is known to be more tiring than higher-altitude flight. The pilot that died flew in excess of those recommendations and, tellingly, the accident happened on the last run of the last day of that long work-week.

2. While the crash referenced above occurred during a seed-dispersal project, the NTSB report discloses that the pilot had experienced a previous accident, on October 18, 2007, … while herding horses in North Dakota. On that day, the pilot was conducting a helicopter-roundup on behalf of the National Park Service. Please see the photographs on pages 4 – 7 of the PowerPoint Presentation, found at the link below.


Per the NTSB report, the probable cause of the 2007 accident was: ‘”The pilot failed to maintain clearance from the fence while maneuvering at low altitude.”‘ The pilot and passenger both suffered minor injuries. The report does not say, but that passenger may well have been a Federal employee. Who was the contractor? Again, it was El Aero Services, Inc. Here is the link to that Probable Cause Report:


I note that, despite the 2013 tragedy and the 2007 accident, El Aero was recently awarded a $6,000,000 contract for helicopter services relating to the Wild Horse and Burro Program.

3. On April 14, 2014, a helicopter being used by Wildlife Services to locate a radio-tagged Bighorn sheep crashed near Bullfrog, Utah. The pilot and crewmember were seriously injured. Here is the link to the preliminary accident report.


Recommendation: Avoid helicopters for counting and gathering wild horses. As they say, the life you save may be your own.

4. On June 29, 2014, a helicopter being used to fly photographers around the Paul, ID area crashed. The pilot and two passengers were injured, and the helicopter was crushed. BLM staffers saw the downed aircraft and responded to the scene to render assistance (leading some onlookers to infer — mistakenly — that it was a BLM aircraft). I am including this event for your consideration because BLM personnel photograph wild-horse bands while taking inventory and when determining population-distribution.


Why Helicopters Crash

Below is the link to the slide presentation Human Factors in Helicopter Accidents that accompanied the keynote address given by NTSB Board Member Robert Sumwalt at the Fifth International Helicopter Safety Symposium.


Mr. Sumwalt’s talk focused on a crash that occurred in New Mexico during a search-and-rescue flight. Note the similarities between the factors that led to the crash in question and the conditions, standard operating procedures, and observed pilot behavior in BLM helicopter roundups. The factors deemed to have played a significant role in the New Mexico accident included:

Flight conditions

Remote, mountainous terrain
Windy conditions
Twilight, less than 2 hours of daylight


Culture that prioritized mission execution at all costs
Weak requirements for risk assessment during the mission
Actions and attitudes detrimental to safety
Lack of a “safety-focused culture”


Self-induced pressure to conduct the flight
Situational stress that “… distracted him from identifying and evaluating alternative courses of action”
Inadequate pilot staffing
Personal temperament — “very aggressive, high-speed type”
Long work hours and sleep disruptions due to work-related phone calls at night

BLM Helicopter Roundups Involve Additional Risks

The factors listed above could have been said of most BLM helicopter roundups. However, there are additional risks inherent in a BLM wild-horse gather:

BLM-FS Roundup — Flight Conditions

Low and slow
Desert-type environments — brownout potential
Winter roundups — whiteout potential
Dealing with unpredictable animals
High potential for loss of situational awareness

BLM-FS Roundup — Organizational

Need to stick to the scheduled time-frame for completing the roundup
Pressure to appear to reduce exaggerated estimated herd levels to low-AML
Culture of secrecy and deception regarding helicopter roundup flights
COTR/PI failure to stop the pilot’s pitiless harassment of exhausted horses

BLM-FS Roundup — Pilot

Financial incentive to round up as many horses as fast as possible
Motivation to earn the per-horse fee in addition to the flat-fee for service
Preoccupation, seeming fixation, to capture every last horse
Evident haste to bring the bands in, forcing them to gallop over rough ground
Divided attention — multi-tasking — while monitoring aircraft systems
Showing off, trying to impress onlookers that he has the “right stuff”
Aggressive, relentless prodding and ramming of horses with the landing skids to make them move faster, but often knocking them down instead
Impatience, anger, frustration, recklessness, and vindictiveness reflected in the roundup pilot’s patterns of behavior — egregious emotions that can lead to unwise decisions and result in an accident

How the Bad Behavior Looks

Below is the link to a report that aired on HLN about the recent Jackson Mountains roundup in Nevada. Most of the still-photos are of those operations. There is also video footage from previous roundups, documenting the pilot sadistically ramming animals with the half-ton helicopter’s landing skids, even flipping one little burro upside down. (Once it loads, there’s a 15-second ad, and then the news-clip starts.)
(Run-time: 2 minutes, 54 seconds.)


Pilot Error — The Cause of Most Helicopter Crashes

According to studies, human error remains the causal factor in 65 to 90 percent of helicopter mishaps. BLM has been gambling that the risky behavior involved in its wild-horse roundups can continue without further disasters. But the odds are against it. Such roundups are tragedies waiting to happen. BLM is negligent in continuing to use helicopters when a safe, superior gather-method is available.

Helicopter Pilots — Would Seem More Qualified, But …

Ironically, helicopter pilots are typically more mature, more experienced, and have higher ratings than the average pilot. They tend to maintain their currency in time and type. Yet despite their seeming advantages, they have more accidents — 46-percent more. If a crash occurred during a helicopter-roundup, the pilot, BLM staff, observers, and the wild horses could be hurt or killed.

Commercial Considerations — Economic Viability Factors

An insightful helicopter-crash study, Root Causes of Helicopter Pilot Error Accidents, which had been posted on the Federal Aviation Administration’s Website, noted that economic pressures also affect the safety of helicopter operations. Helicopter pilots work under financial stress. They strive to maintain high utilization rates, make flights when requested, complete flights as planned, meet schedules, please people, and … make money. I am transmitting a file with the Root Causes report for your reference in addition to my comments.

BLM contract helicopter pilots appear in a big hurry to gather as many horses as quickly as possible, presumably to maximize profits — they are paid a per-horse fee in addition to their flat-fee for service. They push the horses to gallop, even as the band approaches the wings of the corrals. The horses, lathered in sweat and heaving, come to an abrupt halt in the crowded pens, contrary to humane-care standards. However, it must be noted that the entity in charge — BLM — has allowed the pilots to behave in this manner.

Complacency — A Root Cause in 55 Percent of Helicopter Crashes

When a pilot has repetitively — and so far without incident — engaged in an activity that is dangerous, he may become complacent. Such a pilot would lose a sense of the risks that are inherent in what he is doing, becoming casual instead of careful. Boredom may also be a factor. With less vigilance, the pilot relaxes his standards, becomes careless, and puts himself and others at risk. Complacency leads to pilot error. The Root Causes study found complacency (as well as its fellow-traveler, overconfidence) to be a root cause of 55 percent of helicopter accidents. From the observed behavior of the BLM-roundup pilots, it can be inferred that they have become complacent. They appear to have lost awareness of the riskiness of their endeavors.

Here is an anonymous quotation that was included in the Root Causes report:

A Superior Pilot is One Who Stays Out of Trouble By Using Superior Judgment to Avoid Situations That Might Require The Use of Superior Skill.

BLM contract helicopter pilots cannot be said to meet this superior standard.

Helicopters — Subject to Brownouts in the Desert, Whiteouts in the Winter

When helicopters maneuver at low altitude, the rotors’ down-wash may create brownout — conditions of reduced visibility for the pilot due to blowing and recirculating dust and sand. Whiteout is the corresponding phenomenon with snow. Visual cues become obscured, and the horizon can disappear. Brownout can result in spatial disorientation — the pilot loses awareness of the orientation of the helicopter with respect to the earth. Engulfed in a swirl of dust or snow, the pilot might not be able to tell whether the helicopter is flying level or drifting into an object. In the visually-degraded environment of a brownout or whiteout, a helicopter-pilot can become spatially disoriented and crash. BLM personnel may be on board.

Here is the link to a news report on how the Military is studying the problem of brownout.
(Run-time: 1 minute, 41 seconds.)

Here is the link to a video of a police-helicopter landing (safely) in a whiteout.
(Run-time: 1 minute, 15 seconds)

BLM helicopter-roundups have taken place under both brownout and whiteout conditions.

In the Event of an Accident, Rescue Efforts Would Be a Challenge

In a helicopter roundup, the pilot flies off alone looking for bands of horses to bring back from across a herd management area that can encompass many square miles. Should a crash occur in rugged terrain at a remote location, medical help might not get there in time. While the pilot may be willing to accept this risk, surely BLM should not be putting a contractor in situations that could endanger his safety — and his life — merely to round up horses. And surely BLM’s own personnel should not be asked to risk their life to perform a non-emergency job.
HELICOPTERS — Dangerous to Horses
Inhumane Roundup Method

BLM’s use of helicopters to round up the wild horses is inhumane. The horses are terrified by the thunderous, high-intensity noise as they are pursued by the low-flying helicopter. They are blasted with sand, dirt, and gravel from the rotor wash. Panicked by the chaos, they stampede, injure themselves, and become separated from their babies and bandmates. Mares miscarry. Foals become orphans. Many horses die from stress, even more have to be euthanized. Helicopter-style roundups are abusive, especially to foals, older horses, and pregnant mares. This is unacceptable.

As has been documented on video, helicopter pilots conducting these roundups appear in a hurry to gather as many horses as quickly as possible, presumably to maximize profits — they are paid a flat fee plus a per-horse amount. Frustrated by the wild horses’ lack of cooperation and impatient to get them moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the animals into a somersault. There is video documentation of such abuses, and a court found that they had indeed occurred. There has also been documentation of contractors whipping wild horses in the face, kicking them in the head, dragging them by the neck with ropes, using electric prods on them.

Recommendations: Helicopter-style roundups must be abolished. Roundups in extreme temperatures — either the summer heat or the winter cold — must end. Stampeding horses for countless miles — causing them to lather with sweat and then bringing them to an abrupt halt — must be prohibited. Forcing the horses to run long distances over rough terrain, thereby wrecking the delicate hooves of the newborns and resulting in lameness and even death — must never happen again.

BLM should institute the kind approach to gathering wild horses. Roundups should be done slowly, quietly, and gently using the bait-and-water trapping approach. This method also tends to preserve family unity, which is essential to wild-horse social structure.
HELICOPTERS — Dangerous to the Environment
Possibility of a Post-Crash Fire’s Leading to a Wildfire

The crash of a roundup-helicopter could result in a fuel-spill. Especially in these times of drought, when there is an abundance of dry brush, a wildfire could be sparked. Thus, even the environment is at risk from the use of helicopters to round up wild horses. It bears repeating that, because herd management areas are typically in remote locations, it would be difficult to put out a post-crash fire and keep it from getting out of control.

Potential for Increase in Transmission of West Nile Virus

This year has seen West Nile Virus (WNV) infections among wildlife in Wyoming. According to data submitted to the Centers for Disease Control and Prevention (CDC), WNV infections have been found in mosquitoes, birds, sentinel animals, or veterinary animals.


Last year, there were at least 13 cases of humans that become infected by WNV, for which there is no vaccine or treatment. One resident of Powell died of WNV.


Helicopter-stampedes can result in wild horses trampling riparian areas and in so doing, creating stagnant water puddles — conditions ideal for mosquito breeding. The prospect of a helicopter gather increasing the likelihood of WNV outbreaks among wildlife was raised by BLM in a 2012 environmental assessment. BLM was concerned because WNV has been a significant cause of mortality among sage grouse and other bird species. The precautionary principle would call for protecting Wyoming’s residents — both human and avian — from exposure to harm.

Helicopters Emit Exhaust Gases that Contribute to Ozone and PM-10

Aircraft engines “emit water vapor, carbon dioxide (CO2), small amounts of nitrogen oxides (NOx), hydrocarbons, carbon monoxide, sulfur gases, and soot and metal particles formed by the high-temperature combustion of jet fuel during flight.” (Please see the last paragraph on page 2 at link below.)


The EPA notes that ground-level ozone has many detrimental health effects, which is why it monitors that form of pollution and regulates it. Fuel combustion, transportation, and fugitive dust — all of which are operative in a helicopter roundup — contribute to ozone.


Except for one aircraft-services contractor who still flies a B47G-3B-2 helicopter whose reciprocating engine uses 100-octane low lead fuel (100LL), all the other contractors fly turbine-engine helicopters, which use jet fuel. Although basically kerosene, jet fuel contains many additives, except lead. According to one source (link below), in addition to 70 or so proprietary compounds whose identity is withheld as being confidential business information (CBI) and which might even include mercury, here are some of the compounds emitted in the exhaust of combusted jet fuel:

Freon 11, Freon 12, Methyl Bromide, Dichloromethane, cis-l,2-Dichloroethylene, 1,1,1-Trichloro-ethane, Carbon Tetrachloride, Benzene, Trichloroethylene, Toluene, Tetrachloroethene, Ethylbenzene, m,p-Xylene, o-Xylene, Styrene, 1,3,5-Trimethyl-benzene, 1,2,4-Trimethylbenzene, o-Dichlorobenzene, Formaldehyde, Acetaldehyde, Acrolein, Acetone, Propinaldehyde, Crotonaldehyde, Isobutylaldehyde, Methyl Ethyl Ketone, Benzaldehyde, Veraldehyde, Hexanaldehyde, Ethyl Alcohol, Acetone, Isopropyl Alcohol, Methyl Ethyl Ketone, Butane, Isopentane, Pentane, Hexane, Butyl Alcohol, Methyl Isobutyl Ketone, n,n-Dimethyl Acetamide, Dimethyl Disulfide, m-Cresol, 4-Ethyl Toulene, n-Heptaldehyde, Octanal, 1,4-Dioxane, Methyl Phenyl Ketone, Vinyl Acetate, Heptane, Phenol, Octane [referring to the saturated hydrocarbon not the short form of the term “octane rating”], Anthracene, Dimethylnapthalene (isomers), Flouranthene, 1-methylnaphthalene, 2-methylnaphthalene, Naph-thalene, Phenanthrene, Pyrene , Benzo(a)pyrene, 1-nitropyrene, 1,8-dinitropyrene, 1,3-Butadiene, sulfites, nitrites, nitrogen oxide, nitrogen monoxide, nitrogen dioxide, nitrogen trioxide, nitric acid, sulfur oxides, sulfur dioxide, sulfuric acid, urea, ammonia, carbon monoxide, ozone, particulate matter (PM10, PM2.5).


If the piston-engine aircraft is used, pollution also occurs. The 100LL “avgas” fuel, when combusted, emits lead, a dangerous neurotoxin. The EPA advises:

Lead emissions to air undergo dispersion and eventually deposit to surfaces. Lead deposited to soil and water can remain available for uptake by plants, animals and humans for long periods of time.

The EPA further states: “Lead is a persistent, bioaccumulative and toxic (PBT) pollutant listed among EPA’s 12 priority PBT pollutants.” Please see page 11 at link below.


Why would BLM even consider polluting the environment just to round up some horses?

Helicopters and Green-House Gas (GHG) Emissions

At the link below is a compare-and-contrast analysis of the GHG emissions produced by a passenger van versus by a helicopter transporting those same passengers. Interestingly, the aircraft in question, a B206 L4, is a model that one of the contractors uses. From other documents, we know that the roundup helicopter may refuel as many as four times a day. Such a frequency brings its own dangers of pollution from spills.

Bottom line: helicopters use much more fuel and, consequently, release many times the GHGs that a motor vehicle does. Which begs the question: Why would BLM employ such a polluting vehicle to round up equids when safe, humane alternatives are available? In fact, since there is no need for roundups at all, the cost, waste, and pollution are all the more indefensible.


Helicopters and Noise Pollution

An HMA is a designated space for wild horses and burros. It should be a place of peace and quiet. Using helicopters is a violation of that environment, disturbing the peace with the deafening roar of the chopper flying at very low altitude. It is unacceptable to use such a vehicle in a wild-horse area, polluting the environment with high-decibel noise and vibrations.

In its Report to Congress on Nonmilitary Helicopter Urban Noise Study, the Federal Aviation Administration noted that “a helicopter may be much more noticeable than a fixedwing aircraft because of the impulsive blade-slap sound.” Members of the public have a heightened reaction to helicopter-generated, low-frequency noise. This distinct “impulsive” (spontaneous changing) pattern is referred to as the “unique noise character” of helicopters. The FAA’s report explained:

When throbbing occurs at low-frequencies, the actual loudness is greater than that predicted by the equivalent level. Stated another way, even though the equivalent level of a sound may be below the threshold of audibility, the sound is audible.

The report further noted:

Rate of response is defined as the ratio or relative order of magnitude of percent average noticeability comparing two unique sources of noise. In this case, helicopter noise was compared to fixed-wing airplane and train noise. The rate of response function for helicopter sounds grew at three times the rate of response functions found for airplanes and trains. This paper showed that sound noticeability may be a significant variable for predicting human response to noise. The character of the sound was a key ingredient to noticeability. Helicopters, with their distinctive sound character, appeared to be more noticeable than other sounds for the same A-weighted sound exposure level.


Surely, wild horses will be similarly disturbed as well as traumatized by the roar, thunder, and rattle of the helicopter. In addition, they will suffer the brutality of being rammed by the landing skids to prod them into moving faster, as ample video documentation has revealed. Such cruelty took place in plain view of observers with video cameras. Imagine what went on out of their sight and scopes.

Helicopters and Decibel Readings

The following link contains a chart of decibel readings taken by a person that lived near a site in East Hampton, NY where helicopters operated out of the nearby airport. Note that for helicopters flying at “dangerously low, tree-top level,” readings of 85 to 90 decibels were common. Depending on the species, trees can be 30 to 60 feet tall or taller, and the helicopter would have been higher still to be above the tree tops.


At the link below, we learn that a Bell J-2A helicopter at 100 feet above ground level (AGL) reaches 100 dB. This reading is similar to those recorded by the private citizen referenced above.


According to another source, the decibel reading for helicopters reaches 105 dB, or louder than a jackhammer. Altitude: 100 feet AGL.


The following chart indicates that, at just 85 dB, hearing loss can occur. At 100 dB, the maximum safe exposure time is just 15 minutes. A roundup of a single band of wild horses can take much longer than 15 minutes.


At this link, there are more examples of sound levels in various environments.


BLM documents note — and we have seen for ourselves that — when herding equids, the roundup helicopter “would drop as low as 5 or 6 feet when turning the animals.” At this extremely low altitude, the noise level is likely well over 100 decibels, producing pain and suffering that is surely injurious to the acutely sensitive hearing of the equids. Combined with tremendous vibrations and the blasting rotor wash, the process is cruel and pitiless.

It is unacceptable to subject sentient creatures to such torment. America’s wild horses must be handled with care and concern. The agencies’ administrative convenience is the least important consideration.

Helicopters — Adverse Effects on the Wilderness, on the Wildlife

The impacts of using helicopters for roundups include the blowing of soils, injury to plants, and stress and possible injury to wildlife. The noise, pollution, stampeding of wild horses for miles-on-end would negatively impact the environment.
HELICOPTERS — Inappropriate Method for Counting Wild Horses
Aerial Inventories Produce Gross Over-Counts

BLM has also been employing aircraft to conduct inventories of wild horses and burros. However, the aerial method results in significant over-counts, as evidenced by BLM’s reporting of census figures that indicate reproductively-impossible birth-rates.

It is difficult to accurately count mustangs by means of a flyover, hard to tell horses apart and to know for sure that they haven’t been counted already. Due to wild horses’ roving nature — they are known to roam up to 50 miles a day — many instances of counting the same animals is probable. Indeed, wild horses may become particularly mobile, frightened into fleeing the deafening roar of the helicopter used for the flyover. Therefore, it is likely that horses are double-counted, and not per the “direct count” or “mark-resight” or the “simultaneous double-count” methods that BLM touts, but literally by counting many horses twice, perhaps even more than twice. Cows may be mistaken for horses. Deer may inadvertently get counted too.

An aerial inventory also tends to include “rock horses,” which fool the eye particularly when one is high above the landscape in an aircraft traveling at relatively high speeds. Related to this phenomenon is observer fatigue, which sets in after hours in a cramped, stuffy aircraft cabin, confined by seatbelt and crash-helmet, craning one’s neck to peer out the grimy windows, counting and photographing what look like they might be horses. The process repeats. And repeats. It gets tiresome. Airsickness may become an issue. The aircraft contractor and the census-takers know what they are supposed to find: Excess horses. Funds have been budgeted for a roundup, and with government allocations, it’s either “use ’em or lose ’em.” Why, even the worst-case modeling projections say there should be excess horses — just like the estimates predicted and the extrapolations seemed to show. So, excess horses are “found.” Confirmation-bias at work.

BLM needs an accurate method of taking inventory. The current approach has proven unreliable. Impossibly-high estimates of wild horse and burro populations have led to unnecessary removals, costly holding, and impaired relations with grazing permit-holders (who become alarmed by reports of a mustang population explosion) and wild-horse-and-burro advocates (who know there cannot be even half the number of mustangs on the range that BLM claims).

Recommendations: BLM-Wyoming should contract the census-taking function to independent experts, ideally ones associated with a university that has a strong animal-sciences program. BLM should research new technologies for remotely tracking wild horses and burros and then procure the system that best serves the purpose. There might even be a way to link the tracking devices to a data-base that would store comprehensive information on each animal. By employing technological approaches to tracking, BLM will secure accurate, reliable data for management purposes, including a complete demographic breakdown of the wild horses and burros in every HMA along with each equid’s genetic profile.

Why Would an Over-Count Be So Bad?

BLM justifies the need for a roundup when it estimates that horses in excess of the “appropriate management level” (AML) populate an HMA and/or have taken up residence outside an HMA. From this estimated population figure, BLM typically subtracts the lower bound of the AML to determine how many horses to remove.

For example, let’s say an HMA’s AML-range is 150 to 200 horses but that now the herd has grown to 300. BLM conducts an aerial inventory but “sees” 500 due to its over-count. It then plans a roundup thusly:

500 — estimated population — 67 percent higher than actual
− 150 — low AML
350 — targeted for removal

BLM assumes the helicopter roundup will achieve a gather “efficiency” of 80 percent. Accordingly, BLM expects that, of the 500 horses it estimates are in residence …

400 — will be captured, of which …
350 — will be removed and
50 — will be released back.

The 100 that supposedly don’t get caught, plus the 50 that are to be released = 150.

The helicopter roundup ensues. Just 300 horses are captured — but they constitute the entire herd. All are removed (“gate-cut”) because the gather seemed to fail to achieve its “efficiency” goal when, in reality, the roundup got 100 percent, thus exceeding the goal and wiping out the herd. BLM assumes that 200 horses cleverly hid and evaded capture, and that they are still on the range, breeding away. In fact, the herd has been rounded up into extinction.

Aircraft Census and Gather Contractors — Apparent Conflict of Interest

The aircraft service providers used by BLM for conducting inventories and roundups know the score — if “excess” horses are found, a roundup will be scheduled and they can make some serious money. Thus, there is motivation to find — or create the appearance of — an over-population.

Doing so would be easy. The same area could be crisscrossed multiple times. BLM staff could easily become disoriented and not be able to tell that they had been over an area already. The horses could be spooked into fleeing outside their HMA, which would accomplish four things inuring to the financial benefit of a helicopter contractor. Scaring the horses and driving them out of the HMA could …

Cause them to be counted twice — once inside, and once outside the HMA,
Gin up the number of horses that appear to populate the HMA,
Automatically target such horses for removal, and
Result in the false appearance of a need for a roundup.

Thus, the helicopter inventory method suggests the appearance of a conflict of interest. The potential conflict pertains to the incentive to increase revenues through generating more billable services and more billable horses.

Recommendations: First, reform the census methods as earlier advised. Then, reform the roundup procedures by abolishing the helicopter-stampede method and instead, employing bait-and-water trapping. These corrective actions will eliminate the conflict of interest.
MOTORIZED VEHICLES — Dangerous to Wild Horses’ Health
Motorized Transport — Long Travel is Cruel, and Results in Illness, Deaths

Helicopters are not the only vehicles of concern. Trucks and trailers transport the gathered horses and burros, first to short-term holding, and eventually to long-term holding in most cases. Which brings up transit time. Prolonged confinement in trailer-travel is bad for horses’ health. BLM’s procedures call for mustangs that are in transit to be offloaded, rested, watered, and fed during journeys lasting more than 24 hours. However, the rest-stop provision may be waived (and probably usually is) if the “stress” of receiving a rest stop is deemed likely greater than the stress of uninterrupted travel. The procedures I’ve reviewed do not reveal who makes this determination or who monitors compliance. It is difficult to envision any scenario that would provide for an easy offloading of wild horses. Are there contract facilities along the way for this purpose? BLM does not say, but probably not. Thus, the supposed provision for humane transport is merely theoretical. The mustangs suffer terribly, since these trips to long-term holding surely take more than 24 hours.

On the “Tips for Traveling with Horses” episode of the “Best of America by Horseback” show that aired on RFD-TV on February 16, 2011, the guest veterinarian advised that horses should not be transported longer than 12 hours. Studies have disclosed a higher incidence of fevers and respiratory infections when travel-time exceeds 12 hours. Thus, there is no doubt that the wild horses, already stressed and crowded together in a cattle-car for more than twice that amount of time, will suffer illnesses as a direct result of the prolonged transport. The extended period in transit may be one reason why mustang fatalities in long-term holding (eight percent) exceed both those that occur in roundups (one percent) and those that take place in short-term holding (five percent).

So, here we have costly roundups, extravagant expenditures of taxpayer funds to ship wild horses around the country when there is room for them right where they are, and an inhumane method of said transport leading to more expenditures for veterinary care due to illnesses brought on by excessive time in transit.

Recommendations: BLM should create a mustang-transport task force to come up with ways of routing horses so that time in transit is always less than 12 hours. The team needs to develop not just procedures but definitive ways of verifying driver compliance. Possibly, electronic tracking mechanisms could be placed on the trailers to monitor location, speed, and other data. Intermediate check-points could be established. Also, BLM needs to devise a way to monitor to ensure contract drivers are operating their truck safely, and in a way that minimizes stress on the horses. Merely having rules and securing assurances are not enough. Trust, but verify.

Too Long Standing Still

There is also a concern about the length of time horses may be kept in trailers that are not moving. BLM’s policy says that wild horses may not be left standing “… for a combined period of greater than three (3) hours.” Crammed into a trailer in the hot sun, three hours is a long time. This provision needs to be reconsidered and reformed.

Recommendations: Total time for the horses to be confined in a trailer without the vehicle being in motion should be limited to 1½ hours. During rest and refueling stops, the trailer should be parked so that it is protected from the elements. Another issue that must be resolved is how to verify and enforce driver-compliance.
Crunch the Numbers

Expenditures of government funds need to be estimated, evaluated, and justified. BLM-Wyoming must complete an analysis of all costs, both immediate and long-term, of using helicopters and motorized vehicles to round up and cart off horses rather than cart in materials for range-improvements — such as to construct guzzlers. The cost-benefit analysis needs to crunch the numbers to ensure that public funds would be spent prudently. A thorough analysis will bring clarity to the decision-process. Rounding up wild horses generates immediate and on-going, long-term costs. It is an unsustainable approach involving …

Population inventories and monitoring flights via contract helicopter service
A helicopter roundup of a certain number of wild horses
Fertility-control treatments administered to mares
Removal of those horses
Transport of said horses
Short-term holding to prepare horses for adoption, and
Long-term holding for the many horses that are not adopted.

Through crunching the numbers, BLM will likely determine that a better use of its funds — and its helicopters and motorized vehicles — would be for rain-catchment projects. Guzzlers would improve conditions on the range for all water-consumers — livestock, wild horses, and wildlife — for decades to come. Thus, expenditures for such beneficial range improvements would not merely be costs but long-term investments.
End Helicopter Roundups

I urge BLM-Wyoming to repudiate helicopter roundups and, instead, implement bait-and-water trapping as the method for gathering wild horses. I ask you to take this approach right away.

Helicopter roundups should have ceased long ago. The spectacle of this brutal roundup method being used against the wild horses has horrified the nation. It is in the Agency’s own self-interest to stop incurring negative publicity and casting itself in a bad light. I urge you to reform your methods. End helicopter roundups.

Cruelty-Free Methods — No Helicopters, No Whips, No Electric Prods

I urge the BLM-Wyoming to ban the use of helicopters, whips, and electric prods in gathering and maneuvering wild horses. It is time to implement cruelty-free, whip-free, prod-free operations.

Bait Trapping Only

I urge the BLM-Wyoming to require the use of the kind method of gathering wild horses — bait trapping. This method is a true best management practice. Because bait-trapping has been proven effective, it makes sense to adopt it — after Wyoming’s wild-horse herds substantially exceed the minimum-viable population (MVP) level prescribed by the International Union for Conservation of Nature (IUCN) with regard to wild equids.

Recommendations: Use bait trapping exclusively. The goal is for bait-trapping to replace helicopter roundups. Bait-trapping should not be just another method of gathering horses but the method. I urge the BLM-Wyoming to embrace the superior bait-trapping approach.

Bait Trapping and Public Observation — Transparency, Accountability Essential

The public is interested in observing wild-horse roundups. Even though bait trapping is safe and kind to the horses, we wish to see the process in action. But because this method is slower, and requires waiting for the horses to enter a trap, observing in person will be challenging to arrange.

Recommendations: Install real-time video cameras — “caval-cams” — at the trap sites and corrals Live-stream the video on your website. That way, any member of the public can monitor a gather online. Think of the public-relations advantages of video-cams over the current practice of keeping observers unhappily far away from the site. Of course, there may still be some observers that prefer to visit the traps and corrals. That option should still be available. However, it will no longer be a contentious matter. Bait trapping is a gentle process, so most of the safety precautions currently necessary due to the dangers of low-flying helicopters chasing stampeding horses will be eliminated.

Learning the New Method

If Wyoming’s BLM staffers do not feel qualified to conduct bait trapping, there are trained units that could be brought in to do it or to show staff how it is done. Learning something new is an opportunity for personal as well as professional growth. BLM’s Billings Field Office (Montana) eschews helicopters in favor of bait trapping. Externally, the American Wild Horse Preservation Campaign and The Cloud Foundation can refer you to an an expert in water trapping that works with the US Forest Service and, thus, is an approved contractor.

When to Gather

When herds significantly exceed the IUCN population guidelines for sustainable genetic viability, a bait-trapping gather may be necessary. The appropriate time to gather wild horses is in autumn — before the snowfall season. By then, foals are older, and temperatures are cooler. Small-scale, annual fall events will mean fewer horses coming up for adoption, and they will be available just in time for the holidays. The horse adoption market won’t be overwhelmed — as it is now — and fewer mustangs will need to be placed in sanctuaries, preserves, or long-term holding. Such an approach will prove cost-effective, enabling BLM to redirect the budget to rangeland improvements and other purposes.

Trapping, or Entrapment?

BLM has been exploiting alleged complaints from private-property owners of wild-horse trespass to set up capture-corrals on those very properties. The corrals are baited to induce the wild horses to trespass, and when they inevitably do, they are punished with permanent denial of their freedom. This approach is wrong.

Siting bait-traps on private property invites trespass and rewards it, likely provoking even more wild horses to leave their herd management area (HMA) than the few that may have wandered. Further, BLM then uses the private-property location of the traps as an excuse to bar humane observers, thus shrouding agency-operations in secrecy, which raises suspicion as to what you are hiding from the public.

I would also point out the appearance of a conflict of interest — permit-holding ranchers that use the HMAs to graze livestock are often the very ones complaining. By getting rid of the wild horses, they free up more room for their cattle. Some unethical permit-holders may even lure wild horses onto their property for this very reason, thereby giving themselves an unfair competitive advantage.


1. BLM should install guzzlers and mineral licks well-inside each HMA to encourage the wild horses to remain within the boundaries of their dedicated habitat. If supplemental forage is provided, it must be dropped toward the middle of the HMA. These proactive steps should be taken first. The goal is to draw the mustangs back into the HMA and to give them motives to stay there.

2. Complaints of wild-horse trespass received from permit-holders should be investigated and verified, with the “bring-’em-back-home” measures described above taken as the first response.

3. The perimeters of the HMAs should be fenced, and those fences, maintained.

4. Bait-traps must be sited on BLM land, where public-observation can occur.

Semi-Trucks and Trailers (Big Rigs), and Pickup Trucks

Use such vehicles to cart in materials … such as to haul water during drought, to bring supplemental forage to the wild horses, and to transport construction-materials for the installation of water catchments — guzzlers.

Partnership with Wild-Horse-and-Burro Stakeholders

The Wild Horse and Burro Program is a high-profile / hot-button topic. The Program is national in scope, and is monitored by dedicated advocates. Comments received from the public are beneficial, but consultation-efforts should not end there. BLM-Wyoming needs to cultivate real partnerships and establish good working-relationships with mustang-advocates, particularly with the leaders of the prominent national, state, and local organizations working to protect the interests of wild horses and burros. Representatives of our sector must be formally included in the planning process right from the start and all along the way.

Recommendations: BLM-Wyoming needs to establish an advisory committee of mustang-advocates and work with us to formulate policy — such as how to gather wild horses and burros. I call upon BLM to …

cooperate, and

… with us. Wild-horse advocates across the nation look forward to consensus-based decisions and to the development of best management practices concerning wild horses. As the recent National Academies of Sciences report said: “… management should engage interested and affected parties and also be responsive to public attitudes and preferences. BLM should engage with the public in ways that allow public input to influence agency decisions.”

Value All Comments — Publish All Results — Strive for Consensus

I urge BLM-Wyoming to publish the minutes of the hearing — as you did in 2013 — including the number of persons that participate in the hearing, both those that attend in person and those that submit comments. Show that you value every response on its own merits rather than labeling some as “form letters.” The Constitution provides for the right of citizens to petition the Government for a redress of grievances. The Constitution does not require each complainant to formulate a unique letter. Indeed, the very word “petition” connotes a document that multiple parties sign in agreement and solidarity regarding a particular issue. At court, there are even class-action suits, wherein many plaintiffs join together to seek justice regarding a matter of mutual concern. One action, many parties.

Please report …

How many persons attended the hearing and how many submitted comments,
How many and what percentage favored or opposed helicopters and why,
What different alternatives were proposed, and
What modifications, corrections, improvements will BLM make per the public input.

The process is supposed to build consensus. The public-involvement component is designed to get feedback from those persons interested enough to participate in the planning process. Disregarding feedback leads to decisions that are not supported by the majority of stakeholders.

Recommendations: Each and every comment must be honored fully, individually, and collectively, with the numerical results published.

Show Respect — Provide Ample Time for Comments — Encourage Dialogue

BLM-Wyoming’s 2013 hearing in this regard lasted just 13 minutes! The meeting commenced at 5:30 p.m. and concluded at 5:43 p.m. The six attendees were each allowed a maximum of two (2) minutes to speak. Questions were disallowed. A number of the attendees had traveled from out-of-state to take part in the hearing. By severely limiting the time allowed and by prohibiting questions, BLM showed contempt for these dedicated citizen-taxpayer-advocates and for the public-input process itself.

BLM staff also appeared disrespectful and distrustful of the attendees, seeming to suggest that the participants might become unruly. The hearing manager — who went on at length about all the “procedural guidelines” — issued the following warning to participants:

Profanity and vulgar language will not be allowed. Please keep your statements clean, or you will be escorted off the premises.

The hearing manager concluded the event … by suggesting that attendees might try to hide in the restrooms!

I would ask that everyone gather themselves and proceed to the exit. The building will be cleared. The restrooms will be checked and the building secured. This hearing is now adjourned. Thank you.


A required annual hearing needs to be a meaningful event. I suggest that a minimum of four hours be set aside for the hearing. A full day would be better. If the public were to see that BLM took these hearings seriously, more persons would surely attend.

Ample time must be reserved for each participant to comment, with the amount of time extended if there is a low number in attendance. I suggest 30 minutes per person. Question-and-answer periods are essential, and dialogue should be encouraged.

BLM staffers should be provided training in customer-service skills, and they need to be reminded that courtesy and respect must be shown to members of the public. BLM employees must be reminded that they are duty-bound to honor the public-input component, which the subject hearing is meant to fulfill.


Renounce the use of helicopters under any circumstances.
Use motorized vehicles only to carry in water, forage, or materials.
Empower wild-horse advocates to have a real influence on BLM processes
Respect hearing-participants, and respect the public-input component.

Thank you for this opportunity to participate in this hearing by submitting substantive comments. Would you please keep me informed and on your mailing list to be notified regarding matters that affect the wild horses of Wyoming.


Marybeth Devlin