Secretary of the Interior,
The 1971 Act requires the Bureau of Land Management (BLM) to manage wild horses and burros humanely. To that end, the agency determined that running heavily pregnant females and newborn foals was not humane. Using the available information back in 1980, the agency designated a west-wide "March 1- June 30" as "foaling season." In the case of burros, the agency simply states no such foaling season exists.
Since the 1980's the ability to make a science based determination has increased. BLM has failed to change the dates according to the best available science.
Foaling season has variations from herd-to-herd and appears to be shifting slightly with climate change. Both wild horse and wild burro herds have a peak foaling season.
We ask that you immediately create a Memorandum that requires field office to begin Herd Management Area Plans (HMAP) that include site-specific data on foaling season. Running heavily pregnant mares and new foals is not acceptable. Using outdated and colloquial information to base parameters on is also not acceptable.
Please, send an Internal Memorandum (IM) today that rectifies this egregious and unacceptable error.