|
SUSTAINABLE HERDS
GENERAL COMMENT: The Public Lands Foundation has long advocated that wild horses and burros should be managed on a limited number of federally designated Ranges in the West. All WH&Bs would eventually live on these Ranges, exclusive of livestock and all HMAs would be retired. Ranges would be managed for the benefit of WH&Bs and wildlife. There is a growing interest for considering this approach. We continue to request that this option for managing WH&Bs be fully explored to determine whether it could be a viable option to the current management strategy. Developing this option would not be in conflict with the proposed Strategy of February 28, 2011. Goal: Manage wild horse and burro (WH&B) populations on public lands so that healthy rangelands and animals are maintained in a thriving natural ecological balance with other multiple uses. Objective 1: Maintain the population of WH&B within the established AML for all of the HMAs. Action 1: Beginning in FY 2012 through FY 2014, remove an estimated 7,600 excess animals per year to temporarily hold population size at approximately 32,000 to 36,000 animals on the range. Prioritize gathers in areas where overpopulation most threatens land health, animal welfare, and public health and safety. DO NOT SUPPORT. The Act requires that WH&Bs be managed to AMLs. The population target exceeds AMLs. Action 2: Consider adjustments to AML through in-depth analysis of herd and habitat monitoring data, and following appropriate NEPA analysis with public involvement. DO NOT SUPPORT. With already strained ability to manage WH&Bs, BLM should not promote this contentious issue. Those who disagree with an established AML should bear the burden, using good science, of showing that the AML needs to be changed. If it is necessary to do this as a part of regularly scheduled plan updates and is seen as an essential element, then it may have to be done. However, it should only be addressed if every other resource allocation is addressed. Objective 2: Use a wide range of fertility control and other population control measures to slow herd growth rates and better align the number of excess WH&B which need to be removed with the number of animals that can be placed in private care. Action 1: Implement “catch, treat, and release” (CTR) gathers with the principal goal of applying PZP fertility control to 2,000 mares per year to reduce the number of on the range pregnancies. Decisions on where and when these gathers would take place following appropriate NEPA analysis. SUPPORT. Why is treatment limited to only 2000 mares per year? Action 2: Adjust herd sex ratios to favor males to reduce the number of on the range pregnancies following appropriate NEPA analysis. SUPPORT. Ratios should be further adjusted in favor of stallions instead of the 60:40 ratio currently being used in many HMAs. Action 3: In herds where biologically sterile mules are a component, return mules to the range reduce the number of pregnancies and assist in slowing herd growth rates. SUPPORT. It seems as though the word “to” is missing between “range” and “reduce.” Action 4: Consider incorporating a non-reproducing component in a number of Herd Management Areas (HMAs), while maintaining the remainder of the herd as a self-sustaining (reproductive) population. This is confusing as written. Does it mean that geldings and/or sterilized mares would be part of the AML while the remainder of the HMA will be maintained as a self-sustaining (reproductive) population? Objective 3: Implement actions to improve WH&B management within HMAs. Action 1: Enter into voluntary agreements with livestock operators to trade use areas (livestock to WH&B) where feasible. DO NOT SUPPORT. It is not clear how this action does anything but expand already out of control herd populations while at the same time compounding impacts on resources by trading managed livestock for yearlong grazing by WH&Bs. Action 2: Identify opportunities to mitigate impacts to WH&B, where appropriate, from authorized activities on the public lands. Inadequate information upon which to base a comment. Objective 4: Improve gather efficiency and expand the use of various gather techniques. Action 1: Implement bait or water trapping gather techniques where feasible. SUPPORT. If this not being done already, why not? Action 2: Increase national in-house gather capabilities. DO NOT SUPPORT. No case has been made for increasing the federal workforce to do this work. It competes with, if not contradicts, Action 3 below. Action 3: Improve the number and type of local and national gather contracts, including consideration of stewardship contracts, assistance agreements, volunteer agreements, or other types of partnership agreements. SUPPORT. However, it is unclear why this is being proposed at the same time a reduction in WH&Bs gathered is being proposed. Objective 5: Conduct rangeland health assessments, herd health evaluations, and habitat monitoring (utilization, trend, actual use, and climate data) in order to verify appropriate management level (AML) ranges and determine progress toward attainment of land health as well as long-term sustainable herd health. Action 1: Use best available rangeland health information to support decisions that affect the management of WH&B herds and their habitat. SUPPORT. Action 2: Coordinate WH&B habitat monitoring with other resource program’s monitoring activities and continue habitat and herd monitoring. SUPPORT. Action 3: Monitor body condition and forage and water availability to evaluate herd health. When conditions require, take appropriate action to protect the health of wild horses and burros and the land they depend on for habitat. SUPPORT. Action 4: Use current science to estimate WH&B population size. SUPPORT. Action 5: Continue sampling to evaluate the genetic diversity of WH&B herds, and take appropriate action to mitigate any concerns. SUPPORT ECOTOURISM Goal: Provide opportunities for ecotourism and value-added opportunities for local economies while maintaining the health of all WH&B and the public lands. Objective 1: Develop public recognition for WH&B herds Action 1: Promote WH&B herds through partnerships. Develop and maintain local support groups to focus their volunteering efforts on herd management areas. SUPPORT.
Action
2:
Explore ecotourism and marketing strategies for our HMAs through
partnerships. Consider good examples of success in ecotourism and
value-added opportunities to local economies.
SUPPORT. PASTURES AND PARTNERSHIP SANCTUARIES Goal: Provide for sustainable long-term care of excess, unadopted WH&B in the most cost-effective manner in long-term pastures or partnership sanctuaries. Objective 1: Provide additional capacity for the humane care of excess, unadopted WH&B in long-term pastures and partnership sanctuaries in a manner that is equally or more cost-effective than at present. Action 1: Maintain existing, long-term pasture capacity to care for excess, unadopted WH&B. QUALIFIED SUPPORT. Explore opportunities to move some WH&Bs from existing long-term pastures to new contract sanctuaries on western ranges. Action 2: Solicit and evaluate proposals for partnership sanctuaries and acquire additional long-term pastures for unadopted excess WH&B (non-reproducing). SUPPORT so long as these partnerships occur on land similar to that currently supporting WH&Bs. Action 3: Explore opportunities to partner with the Farm Services Agency to provide humane care for excess, unadopted WH&B through their pasture programs. DO NOT SUPPORT. This action competes with Action 2 that would maintain excess horses on western rangelands. Additionally, Farm Service Agency legal acreage limitations are too small to be efficiently managed and they will not add efficiency to the excess WH&Bs holding effort. They could end up reducing BLM’s capability by having numerous, relatively small contracts that each have an overhead and inspection requirement. Action 4: Seek authority to extend the period for contracts or assistance agreements from a maximum of 5 years to 10 years to provide greater stability/assurance of pasture availability, and continue to solicit (contract) for long-term grassland pastures for a minimum of 200 and a maximum of 5,000 wild horses. SUPPORT extending contract authority. DO NOT SUPPORT soliciting. Soliciting grassland pastures is in competition with Action 2. If it is necessary to take this Action, it should be for a minimum of at least 500 WH&Bs. Each smaller agreement would require a unique contract, payments and periodic inspections, adding to the logistical complexity of the WH&Bs program. Objective 2: Manage pastures and partnership sanctuaries in a manner that maintains excess, unadopted, and non-reproducing WH&B in pastures large enough to allow free-roaming behavior while providing the food, water, and shelter necessary to sustain them in good condition. Action 1: Continue to follow existing animal care requirements in existing contracts. SUPPORT. Action 2: Seek partnerships with existing animal sanctuaries/preserves for the placement of wild horses. SUPPORT. Action 3: Open a dialogue with potential partners: land trust and open space organizations, conservation and sportsman groups, private forestry corporations, state or local open space areas, Native American tribes, and others. QUALIFIED SUPPORT. This should only be done if a minimum herd size of 500 head can be accommodated on western rangelands. Action 4: Explore transfer of animal title to the partner. SUPPORT. Objective 3: Provide opportunities for ecotourism and public viewing. Action: Explore opportunities that include training, grants, tax incentives, emphasizing opportunities for tourism, and developing some privately owned, and economically self-sustaining partnership sanctuaries. QUALIFIED SUPPORT. This should only be done if a minimum herd size of 500 head can be accommodated on western rangelands.
PLACE EXCESS ANIMALS IN PRIVATE CARE Goal 1: Place more animals into private care. Objective 1: Expand the adoption/sale demand. Action 1: Incorporate recognition of the 40th Anniversary of the 1971 Wild and Free-Roaming Horses and Burros (1971 Act) into adoption promotion and marketing in FY 2011. SUPPORT. Action 2: Increase the use of Internet-based placement. SUPPORT. Action 3: Increase the use of incentives to help defray the cost of horse ownership. SUPPORT. Action 4: Send letters to Federal, state, or local agencies encouraging them to consider using wild horses in their field work. SUPPORT. Action 5: Improve national/state/field level coordination of adoptions. Ensure a uniform, consistent, and cohesive national/regional adoption effort (i.e., coordinate the scheduling of BLM-sponsored adoption events). SUPPORT. Action 6: Expand the marketing to specific equine disciplines and offer trained animals and sponsorships to their members. SUPPORT. Action 7: Explore new authorities for new incentives. SUPPORT. Action 8: Expand the use of wild horses in public service by working with Congress to permanently pass a law requiring government agencies to use trained wild horses before purchasing domestic horses. DO NOT SUPPORT. Agency personnel who must use horses in their work should have some leeway, based upon agency policy, to have a say in the particular horse(s) they use. The enmity caused by such legislation would have an overall negative effect on the WH&Bs program. Forced use of trained wild horses could cost more than a local purchase of a domestic horse especially at this time when there are 100,000 excess domestic horses ostensibly competing with the adoption program. Action 9: Explore a virtual adoption program to allow individuals unable to physically adopt or care for an animal to make a financial contribution (virtually adopt) an unadopted animal in a sanctuary or long-term holding pasture. SUPPORT. Objective 2: Offer more trained animals. Action 1: Expand private partnerships to train animals without a Federal investment in infrastructure. SUPPORT. Action 2: Explore the Mustang Heritage Foundation’s proposal to adopt 4,000 animals each year, and other similar proposals. SUPPORT. Action 3: Expand University and/or prison partnership programs without a Federal investment in infrastructure. SUPPORT. Action 4: Establish more store fronts (privatized adoption facilities that can offer untrained and/or trained wild horses for adoption for the BLM (such as fostering volunteers, Trainer Incentive Program trainers, and others). SUPPORT. Must be more cost effective than other efforts to place animals. Goal 2: Develop a separate environmental education component for the WH&B Program. COMMENT. This second goal and its first objective and actions under the heading of “Place Excess Animals in Private Care” seems misplaced and should be under “Public Outreach.” Objective 1: Implement an environmental education program to tell the story of America’s WH&B. Action 1: Increase interaction with youth groups (e.g., 4-H, FFA, Boys and Girls Clubs). SUPPORT. Action 2: Work to create programs for youth (e.g., explore option to integrate Sally Ride’s youth science program and the First Lady’s plan for urban children.) SUPPORT. Action 3: Develop curriculum to species biology, history, and ecological interactions and impacts within larger biological communities and landscapes. SUPPORT. Action 4: Increase education opportunities at BLM-managed facilities through interpretation. SUPPORT. Action 5: Work with volunteers, partners, stakeholders, and others to host “Kids and Mustangs Days” throughout the U.S. in partnership with National Wild Horse and Burro Adoption Awareness. SUPPORT. Objective 2: Ensure WH&B are titled only to those individuals who provide the animals with a good home. Action 1: Continue to conduct random, post-adoption compliance inspections and to address/resolve any instances of noncompliance or inhumane treatment consistent with existing BLM policy. SUPPORT. Action 2: Continue to rigorously screen applications to ensure the prospective purchasers of WH&B are committed to providing the animals with a good home. SUPPORT. Action 3: Continue to implement sales of WH&B with limitations (purchasers must sign a bill of sale acknowledging their intent to provide the animals with a good home). SUPPORT. Sale without limitation also needs to be developed. ANIMAL WELFARE
GENERAL COMMENT: The Animal Welfare component should not only focus on welfare in gather and post-gather operations but should be expanded to include the welfare of the animals on the range along with a healthy ecosystem. Goal: Use a progressive approach to implement a Comprehensive Animal Welfare Program (CAWP). Develop and implement a CAWP to ensure the well-being of WH&B at gathers and in facilities. The CAWP will bring together a progression of new components such as education for employees, volunteers, and contractors; an ongoing, internal animal welfare assessment program; and periodic external reviews of our animal care and handling. Conduct the CAWP with complete transparency. Objective 1: Develop and implement a Comprehensive Animal Welfare Program (CAWP). Action 1: Use the structured approach successfully implemented by other industries to create a program to assess, monitor, document, and address noncompliance to ensure the BLM’s humane treatment of animals. SUPPORT. Action 2: Develop a WH&B Care and Welfare assessment tool. SUPPORT. Action 3: Consider recommendations from the American Horse Protection Association on findings from the independent observers. SUPPORT. Action 4: Continue the partnership with Animal and Plant Health Inspection Service to have veterinarians at gathers and conduct yearly visits to long-term pastures. Periodically review this partnership. SUPPORT. Action 5: Explore partnerships with other veterinary and professional organizations, such as the American Association of Equine Practitioners, to conduct external reviews of the BLM’s animal care and handling practices. SUPPORT. Action 6: Develop a rotating schedule and conduct periodic internal and external assessments in all BLM States. SUPPORT. Action 7: Consider hiring a full-time Animal Welfare Coordinator. COMMENT: The full cost including benefits, overhead, travel, etc. of this position will exceed $100,000. Before filling this position BLM should consider alternative use of the money. It should also consider having this coordination be added to the responsibility of current staff; and, make those in existing supervisory/managerial positions responsible for animal welfare program performance. Objective 2: Demonstrate to the public and Congress how the CAWP will benefit the animals under our care. Action 1: Develop an animal welfare mission statement. SUPPORT. Action 2: Prepare and implement a plan that includes outreach tools and performance standards to describe and explain the CAWP. SUPPORT. Action 3: Incorporate reporting of the BLM’s internal welfare assessment on the Website and in Reports to Congress. SUPPORT. Objective 3: Provide a continuing education program on animal care and handling for employees, volunteers, and contractors. Action 1: Develop an internal learning and training module. SUPPORT.
Action
2:
Implement training for employees, volunteers, and contractors.
SUPPORT.
SCIENCE AND RESEARCH Goal: Use current best science to manage WH&B and pursue increased knowledge of WH&B-related science. Objective 1: Pursue research that will improve methods and techniques to reduce WH&B population growth rates. Action 1: Continue existing research on fertility control. SUPPORT. Action 2: Conduct new research for ovariectomy in mares and explore new research for sterilization of both male and female WH&B. SUPPORT WITH COMMENT. Ovariectomy research in mares is ongoing (e.g. laparoscopy) elsewhere and should be a low priority for limited research dollars. Veterinarians with wild horse experience could later make informed recommendations whether and what kind of ovariectomy might take place. Action 3: Given a reasonable expectation of safety, implement promising management techniques as soon as they are practically, economically, and legally feasible. SUPPORT. Objective 2: Review and evaluate current science applicable to WH&B management. Action 1: Commission the NAS to review earlier reports and make recommendations on how the BLM should proceed in light of the latest scientific research. SUPPORT. Action 2: Review historic research recommendations of the National Wild Horse and Burro Advisory Board regarding and determine if these were implemented, are no longer relevant, or need to be pursued. SUPPORT. Action 3: Review and update the cooperative research strategy between the BLM and U.S. Geological Survey regarding WH&B research priorities. SUPPORT.
PUBLIC OUTREACH Goal: Utilize effective communications to build the public’s confidence and trust for the BLM’s management of the WH&B Program. Objective 1: Improve the WH&B Program’s Website. Action 1: Organize the Website in a manner that makes information easily accessible. SUPPORT. Action 2: Keep the Website current and up to date. SUPPORT. Objective 2: Increase the availability of WH&B Program information. Action 1: Keep the Wild Horse and Burro Program System (WHBPS) data current, and initiate programming changes to facilitate timely and accurate generation of standardized reports for gathers, adoptions, sales, and facilities. SUPPORT. Action 2: Post standardized reports on the Website. SUPPORT. Action 3: Update Website information on a regular basis, including updated videos and photographs of wild horses in long-term pastures. SUPPORT. Objective 3: Continue to make opportunities available for the public to view WH&B on the range, during gathers, and at short-term or long-term holding facilities. Action 1: Continue to provide information on the website about public viewing opportunities and post up-to- date information about ongoing gathers. SUPPORT. Action 2: Host an annual or periodic media and public tour of wild horses in long-term pastures. SUPPORT.
|
