We the undersigned ask the board to make the following recommendations:
The board should recommend that BLM and USFS immediately create a designated task force to address the increase in shooting deaths of federally-protected wild horses and burros. BLM and USFS should prioritize increasing Law Enforcement presence in herds where shootings have occurred. The lack of prosecution of these egregious offenses is giving an impression that the law is meaningless, federal agencies do not care and increase the risks to the safety of members of the public that go out on the range to enjoy wild horse and burro herds.
The board should recommend that BLM complete the process of formalizing welfare rules so they are enforceable. BLM created a draft, began a review phase and then simply said the draft was "final" and "policy." The draft and review never went for public comment and then formalization as policy. The board itself will refer to the Comprehensive Animal Welfare Program (CAWP) as "policy." However, in practice, even agency employees will stumble when discussing CAWP and not know what to call it: standard, program, policy? In our litigation it is still not clear what BLM considers CAWP. Please recommend BLM complete formalization of concise and enforceable welfare rules by putting out the standards for public comment and finalization.
The board should recommend that BLM and USFS include facility reports as part of online gather updates. The backlog in unanswered Freedom of Information Act (FOIA) requests has been unacceptable for years. The majority of FOIA requests agencies receive have to do with disposition of horses and burros post-capture. Listing which facilities receive animals on a daily basis, how many, vet reports and death reports during active operations out to three months would cut down the FOIA backlog and save considerable taxpayer funding on the FOIA program and in litigation involving the FOIA program.
The board should recommend the Adoption Incentive Program (AIP) be suspended. The board has recommended additional safeguards that BLM has said it would implement. The safeguards have done nothing to slow down the numbers of wild horses and burros being sent to sale barns immediately after title, indicating that the AIP still functions as a subsidy to the trade to slaughter of federally-protected wild horses and burros. Furthermore, the board should consider recommending that BLM suspend titling of wild horses and burros altogether so the animals maintain protection as "wild" for their lifetimes closing the loophole in this one simple act. Instead, recommend that BLM bring back the label of fostering an animal and provide a certificate that would allow the BLM to reclaim any horse or burro found in any kill-lot.
The board should recommend that BLM prioritize creating and updating Herd Management Area Plans (HMAPs). Although no litigation update is part of the agenda, BLM has lost two lawsuits in 2024 and is facing more in 2025 on this very serious subject. The courts have clearly stated that removal/fertility control (population growth suppression) planning is not management planning nor are gathers. The board should soundly reprimand BLM for decades of ignoring this foundational management document. Prior to creating new gather assessments, the board should recommend that BLM craft HMAPs to tier those gather assessments in order to create sound management decisions (a mandate of the law). Simply perpetuating removals that do not tier to actual management planning is irresponsible.
Thank you