Centennial, Panamint & Slate Range Herd Areas Wild Burro Gather Plan FY2021-FY2031 EA DOI-BLM-CA-LLCAD05000-2021-EA
April 14, 2021
Bureau of Land Management (BLM)
California Desert District Office
22835 Calle San Juan De Los Lagos
Moreno Valley, CA 92553
Submitted online: blm_ca_ri_burrogather@blm.gov
Re: Centennial, Panamint and Slate Range Wild Burro Roundup 10-Year Plan
These comments are submitted on behalf of The Cloud Foundation (TCF) for the “Centennial, Panamint and Slate Range Herd Areas Wild Burro Gather Plan FY2021-FY2031 Environmental Assessment” DOI-BLM-CA-LLCAD05000-2021-EA. TCF is a national organization that is committed to protecting and preserving America’s wild horses and burros on our public lands through education, engagement and public participation in government actions.
I. Overview
BLM manages 15 million acres of public lands in California. The BLM only allows 365 to 465 wild burros to live on less than 25% of BLM-managed public lands in California – fewer than 500 burros are allowed to live on more than 3,200square miles of public lands in California. The proposed action to zero-out all burros on more than 560,000 acres in the Centennial, Panamint and Slate Range Herd Areas will compound the bleak situation facing these supposedly “protected” animals. These wild burros are heritage species and are the last large remaining burro herds in California.
The EA states that the 1994 California Desert Protection Act designated the Department of the Navy to manage wild horses and burros on Navy Air Weapons Station China Lake lands. However, the EA fails to include an official and current declaration from the Department of the Navy stating that it is not possible to allow any burros to live on any of the BLM-managed lands in and near the Herd Areas.
Under the Wild Free-Roaming Horses and Burros Act, wild burros and horses are an “integral part” of the public lands on which they roamed in 1971. They are “living symbols” that “enrich the lives of the American people.” The Act was passed to keep them from “fast disappearing” as a protected national resource. The Proposed Action would violate the very intention of the WFRHBA.
These California burro herds are important from a genetic standpoint. The larger (by comparison) number of burros (Appropriate Management Levels for burros in these Herd Areas used to exceed 1,700) enables a genetically-healthy population. This is necessary to ensure the long-term genetic health of burros nationwide. Dr. Gus Cothran, the BLM’s equine geneticist, has presented the genetic data available on all burros managed by the BLM and it is clear from this data that the majority of burros face a genetic crisis.
The National Academy of Sciences (NAS) scientific review (Attachment 1) of the BLM Wild Horse and Burro Program states that the genetic viability of the U.S. burro population is in jeopardy due to the aggregated populations and overall low number of burros stating, “removing burros permanently from the range could jeopardize the genetic health of the total population.” Clearly, burros should not be removed especially given that this is likely one of the last genetically-healthy burro populations left in the U.S.
The EA fails to consider the cumulative effects that the Proposed Action would have on the national wild burro population. By removing genetically healthy burros from the wild population, given the history of removals that has literally crashed the burro population’s genetic health, this Proposed Action will have tremendous cumulative impact to the national burro population.
TCF strongly urges the BLM to work with the Department of Navy to identify areas where the burros can live in or near their original Herd Areas.
II. The EA Fails to Consider Adequate Alternatives to Mitigate the Claimed Need for the Proposed Action In EACH of the Herd Areas/Herd Management Areas
The EA fails to provide adequate data and consideration of mitigating actions to support the claim that all burros must be removed “due to the conflicts with the NAWSCL and the unfeasibility to maintain a population on BLM lands.” Additionally, the EA fails to provide adequate data to support the claim that “public safety concerns and protection of wildlife habitat resource” “necessitate removal of all burros from the HAs” because no agency actions could be taken to mitigate the need to remove all burros. Lastly, Areas of Critical Environmental Concern (ACEC) status does not require the removal of burros, rather it might require the agency to conduct range management to keep burros away from sensitive areas. Lastly, if “Burros were recently identified as contributing factors for not achieving and/or not allowing for progress towards achieving the proper function/condition of some springs and water sources,” then spring protective measures should be implemented, not the zeroing out of all burros.
The Proposed Action is tiered to the 31-year-old California Desert Conservation Area Resource Management Plan/Final (1980). The Proposed Action and current EA rely on 30-year-old planning documents. While we appreciate the precedence of the Department of the Navy and the applicable laws, the EA fails to outline steps or Alternatives that might meet the Department’s security and safety needs while also allowing the burro populations to remain. Alternatives that were not considered include: fencing to keep the animals out of sensitive areas, eliminating livestock grazing and moving burros to those areas (Lacey-Cactus-McCloud allotment and other nearby allotments), or protecting water sources to draw the animals away from areas of special security or safety concern. The EA fails to provide the most recent rangeland health assessment for the Lacey-Cactus-McCloud allotment and the actual AUMs utilization over each of the past five years.
The EA failed to provide any data on the Superior Valley Allotment (in the Slate Range HA) including but not limited to the length of the suspension for this permit, current rangeland health status, when the allotment was last grazed and the actual AUM utilization.
Additionally, the EA fails to disclose or consider the following Alternatives to mitigate the extreme proposal to zero-out all burros from their Congressionally-designated habitat (special consideration should be given due the BLM-mismanagement of burros which is crashing the genetic health of the nationwide population):
· Accommodate wild burro number by utilizing 43 CFR 4710.5 which authorizes the BLM to reduce or eliminate livestock grazing to provide habitat for wild burros.
· Disclosure all rangeland health assessments for livestock allotments which overlap with the HMA (including pastures, allotments, etc.) – including all rangeland assessments used for the renewal of livestock permits, etc.
· Disclose information (including maps) regarding fencing within the HMA, when fencing is open or closed which might hinder burros from leaving the northern section of the livestock allotment and might be contributing the concentration of burro use of specific areas; whether any livestock water sources are fenced off from the burros.
· Erect fencing to prevent burros to return to NAWCLA lands – as per the EA statement that “There is a potential of 152 burros located in the northwestern portion of the Slate Range HA within NAWSCL moving onto BLM administered lands in their seasonal movements.”
The EA failed to address these alternative actions for the removal of burros from each of the Herd Areas/Herd Management Areas.
III. NEPA Requires Review and Analysis of CURRENT Conditions
The Proposed Action would continue through 2031 and the effects of those actions will continue beyond 2030. This highlights the uncertainty of implementing the proposed new, unproven and controversial actions over a 10-year period. Given the highly questionable short- and long-term safety, efficacy and impacts that will likely result from the actions outlined in the EA, a 10-year Decision Record is against the best interests of the public and puts the wild burros the agency is required to protect at risk. By issuing a 10-year Decision Record, the public’s ability to take legal action may be constrained. It is our right to oppose actions covered by the DR within the 10-year period as more information becomes available. Given that the Proposed Action includes vague and expansive terminology to include and implement currently untested fertility control methods, citizens would have no legal recourse to object to actions which may be taken in the future that would not be disclosed to the public.
National Environmental Policy Act (NEPA) requires that agencies review current data and seek public input and information regarding governmental actions. Indicating that this EA would satisfy the NEPA requirement for future actions over the next 10 years is blatantly incorrect, unethical and sidetracks Congress’ intent to include the public and ensure that agencies have the best current information when making decisions.
Due to changing environmental conditions, a blanket, 10-year EA cannot be considered sufficient under NEPA. The final EA must fully disclose, describe and analyze specific and current range data, water availability, range usage (differentiating usage by livestock and horses), and the agency’s intended actions, and allow the public ample opportunity to review the data and comment on the proposed action, as required by NEPA. To reiterate, NEPA requires that the BLM conduct further environmental analysis and public comment for future wild burro roundups and management actions and cannot rely on an outdated,10-year-old EA.
We strongly object to the Proposed Action that attempts to rely on the current EA to fulfill NEPA requirements for future roundups or management actions of the burros over the next 10 years. NEPA requires that agencies review current data and seek public (and other agency) input and information regarding current governmental actions. Indicating that this EA would satisfy the NEPA requirement for future actions over a 10-year period sidetracks Congress’ intent to include the public and ensure that agencies have the best current information when making decisions. Due to changing environmental conditions, a 10-year EA cannot be considered sufficient under NEPA for future actions. NEPA requires that the BLM conduct further environmental analysis and public comment for additional roundups and management actions in the future.
IV. The EA Fails to Adequately Address the Genetic Importance of the Targeted Herds
The EA fails to provide any genetic variability data on the target burros; this results in the EA failing to consider the genetic importance of these herds. The EA fails to provide data from the cited genetic analysis of the Panamint burros – “Cothran, G.E. 2001. Genetic analysis of the Butte Valley, Panamint and Saline Valley CA feral burro herds. Department of Veterinary Science, University of Kentucky, Lexington, Kentucky. 7 pp.” The EA fails to provide any other references to the genetic health of the burro herds therefore it appears the agency has not conducted any genetic variability samplings for nearly 20 years.
The EA states:
Wild burros do not form breeding bands. There are no strong individual bonds other than jenny-foal relationships. Wild burros present themselves as single animals, all-male groups, all-female groups, jenny-foal groups, or mixed groups. All of the groups are variable and their composition may change at any time. This loose social structure, where all animals are potential breeding partners, maximizes genetic diversity in small or dispersed burro populations.
Despite the above-stated social structure which “maximizes genetic diversity in small or dispersed burro populations,” the EA fails to consider that the BLM’s genetic expert, Dr. Cothran, has repeatedly pointed out that the BLM’s removal of burros from public lands has already led to a genetic crisis for the U.S. burro population as a whole. The NAS report notes:
· “removing burros permanently from the range could jeopardize the genetic health of the total population.” (NAS page 268)
· BLM "may need to assess whether the AMLs set for burros can sustain a genetically healthy total population." (NAS page 268)
· BLM must utilize “A participatory adaptive-management process for the setting and adjustment of AMLs…” (NAS page 250)
· “Environmental variability and change, changes in social values, and the discovery of new information require that AMLs be adaptable.” (NAS pages 12 and 253)
· “…management should engage interested and affected parties and also be responsive to public attitudes and preferences.” (NAS page 292)
Dr. Cothran stated, “The burros, I think, have in many cases had more severe population contractions [roundups] probably more inbreeding because of the smaller numbers on the land…. And one of things we are seeing is that most of the burro herds show very low [genetic] variability ... I think the burros, in terms of genetic diversity, are a much bigger problem than the horses are. And again, we have tested a fair number of burros...” Source: www.youtube.com/watch?v=f5HTuKtVMVg
Dr. Cothran said that many burro populations have only a 20 percent (20%) genetic variability factor compared to a healthy genetic variability of 70%. At 50% variability, a population is considered “challenged.”
The EA fails to disclose any genetic health reports from Dr. Cothran. The final EA must include copies of those reports. If genetic reports show these burros to have healthy genetic variability, it is imperative that the BLM work with the Department of the Navy to create an MOU to sustain these healthy burro populations. Additionally, all livestock grazing in the Centennial HMA must be eliminated in order to provide habitat for these burros. The BLM is compelled to full disclosure, so the public has all available information in order to provide public comments.
V. Applicable Laws and Regulations
The EA and Proposed Action must address and be in conformance with applicable laws, regulations and statues including but not limited to those listed herein. Specifically, the livestock grazing in the Centennial HMA should be eliminated to provide habitat for some or all of the burros targeted for removal.
A. JOHN D. DINGELL, JR. CONSERVATION, MANAGEMENT, AND RECREATION ACT
The Dingell Act does not require the removal of wild burros.
SEC. 1214. SAVINGS CLAUSE. Nothing in this part diminishes the authority of the Secretary under Public Law 92–195 (commonly known as the ‘‘Wild Free-Roaming Horses and Burros Act’’) (16 U.S.C. 1331 et seq.).
B. California Desert Protection Act of 1994
The California Desert Protection Act does not require the removal of wild burros, but rather rests that responsibility with the Secretary of the Navy. The EA fails to include any current documentation from the Navy that indicates no burros could be managed on any of the lands.
The Secretary of the Navy shall be responsible for the management of wild horses and burros located on the lands withdrawn under section 802(a) of this title and may utilize helicopters and motorized vehicles for such purposes. Such management shall be in accordance with laws applicable to such management on public lands and with an appropriate memorandum of understanding between the Secretary and the Secretary of the Navy.
C. 43 C.F.R. 4710
The EA failed to consider the alternative action to temporarily or permanently reduce or eliminate livestock grazing from Herd Areas or Herd Management Areas pursuant to 43 C.F.R. 4710.5(a). This regulation allows the BLM to temporarily or permanently close a public land area to livestock grazing "If necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury.” The BLM has the discretion to implement this either temporarily or permanently and this action is available whether or not there is an emergency.
The EA claims the burros are in a northern section of the allotment which is closed to livestock grazing; but it does not indicate whether the fencing used to keep the livestock out of that area is also keeping the burros in that undesirable area.
The EA must consider this alternative in order to reduce removals and accommodate at least 108 of the current wild burros by using the agency's Adaptive Management mandate and its discretion under 43 C.F.R. 4710.3-2 and 43 C.F.R. 4710.5(a), which allows for the reduction or elimination of grazing for privately-held animals in order to improve conditions and forage availability for wild horses or burros. The Proposed Action could be postponed until the RMP amendment can be finalized.
D. Federal Land Policy and Management Act of 1976 (FLPMA)
FLPMA requires that BLM “balance wild horse and burro use with other resources” which equates at minimum to a 50-50 allocation of available forage between horses and livestock on WHTs. But given the other applicable laws and regulations, it is clear that livestock should be removed completely from the HAs/HMAs.
FLPMA addresses the importance of the non-market value within its definition of the term “multiple-use.” FLPMA requires that:
“(c) . . . consideration being given to the relative values of the resources and not necessarily to the combination of uses that will give the greatest economic return or the greatest unit output.”
The intrinsic value of wild horses and burros falls under the non-market definition specified by both laws.
Sec. 302 of FLPMA states:
“(a) The Secretary shall manage the public lands under principles of multiple use and sustained yield, in accordance with the land use plans developed by him under section 202 of this Act when they are available, except that where a tract of such public land has been dedicated to specific uses according to any other provisions of law it shall be managed in accordance with such law,” [43 U.S.C. 1732] and Sec. 102 “(b) The policies of this Act shall become effective only as specific statutory authority for their implementation is enacted by this Act or by subsequent legislation and shall then be construed as supplemental to and not in derogation of the purposes for which public lands are administered under other provisions of law” [43 U.S.C. 1701]
In addition, FLPMA requires the public lands to be administered for “multiple-use,” which Congress defined as:
“the management of the public lands and their various resource values so that they are utilized in the combination that will best meet the present and future needs of the American people . . . with consideration being given to the relative values of the resources and not necessarily to the combination of uses that will give the greatest economic return or the greatest unit output.” [43 U.S.C. § 1702(c)].
While commercial livestock grazing is permitted on public lands it is not a requirement under the agency’s multiple use mandate as outlined in the Federal Land Policy and Management Act of 1976 (FLPMA). Indeed, public land grazing is a privilege and not a right and the USFS is mandated by law to protect wild horses and burros. Therefore, the agency’s management and Draft EA should reflect these priorities and legal requirements.
Grazing on public lands is a privilege, and not a right See 43 U.S.C. § 315b & 16 (1943 Taylor Grazing Act, stating that grazing preferences "shall not create any right, title, interest, or estate in or to the lands" belonging to the U.S. Government); 43 U.S.C. § 580l (FLPMA similar provision); Omaechevarria v. Idaho, 246 U.S. 343, 352 (1918) ("Congress has not conferred upon citizens the right to graze stock upon the public lands. The government has merely suffered the lands to be so used"); U.S. v. Fuller, 409 U.S. 488, 494 (1973) (grazing permittee does not acquire a property interest in grazing permit); Swim v. Bergland, 696 F.2d 712, 719 (9th Cir. 1983) ("license to graze on public lands has always been a revocable privilege"); Osborne v. United States, 145 F.2d 892, 896 (9th Cir. 1944) ("it has always been the intention and policy of the government to regard the use of its public lands for stock grazing. . . as a privilege which is withdrawable at any time for any use by the sovereign without the payment of compensation"); Diamond Bar Cattle Co. v. U.S.A., 168 F.3d 1209, 1217 (10th Cir. 1998) (permittees "do not now hold and have never held a vested private property right to graze cattle on federal public lands"); Alves v. U.S., 133 F.3d 1454 (Fed. Cir. 1998) (holding that neither grazing permit nor preference is a compensable property interest).
E. Taylor Grazing Act (TGA)
The TGA provides the government broad discretion to decide whether to allow livestock owners to use the public lands i.e., the issuance of a grazing permit does not confer any entitlement or right to use the public lands; rather, it is a privilege that can be taken away if necessary to protect the health of the range and even if necessary to protect the wild horses. See 43 U.S.C. § 315b (BLM, is “authorized” to issue permits for the grazing of livestock on public lands “upon the payment . . .of reasonable fees”); id. (“the creation of a grazing district or the issuance of a [grazing] permit . . . shall not create any right, title, interest, or estate in or to” these public lands. Id. (emphasis added). Indeed, the TGA also provides that the Secretary “is authorized, in his discretion, to . . . classify any lands within a grazing district, which are . . . more valuable or suitable for any other use,” 43 U.S.C. § 315f, including use by wild horses that are required to be protected under the WHA (Wild Horse Act). See 16 U.S.C. § 1333(a); see also 43 C.F.R. § 4710.5(a).
Livestock grazing on public lands is a privilege that can be taken away if necessary, to protect the health of the range and even, if necessary, to protect wild burros.
F.Wild Free-Roaming Horses and Burros Act of 1971
Following is general definition of “range” in the 1971 Act and it applies to all BLM-managed public lands where the horses were “presently found” in 1971 and thus applies to all Herd Areas
“Definitions . . . (c) ‘range’ means the amount of land necessary to sustain an existing herd or herds of wild free roaming horses and burros, which does not exceed their known territorial limits, and which is devoted principally but not necessarily exclusively to their welfare in keeping with the multiple-use management concept for the public lands; . . .” [Public Law 92-195 § 1332]
VI. The EA Fails to Address Humane Standards for Helicopter Roundups and
Public Observation
A. Humane Standards for Helicopter Roundups
The “APPENDIX F - Standard Operating Procedures for Wild Horse and Burro Gathers” is inadequate: “The rate of movement and distance the animals travel shall not exceed limitations set by the COR who would consider terrain, physical barriers, access limitations, weather, extreme temperature (high and low), condition of the animals, urgency of the operation (animals facing drought, starvation, fire rehabilitation, etc.) and other factors. In consultation with the contractor the distance the animals travel would account for the different factors listed above and concerns with each HMA.”
This statement fails to address any issue regarding humane treatment – by providing absolutely no guidance whatsoever. When helicopters are to be used as a part of any management, the EA must consider, analyze and implement specific humane standards as outlined in the below recommendations. These recommendations are necessary to reduce potential stress and harm to the burros during a helicopter roundup. The following must be considered to minimize stress and injury to burros:
i. Limit the distance burros may be chased by a helicopter to no more than five (5) miles.
ii. Require that the helicopter not chase/move burros at a pace that exceeds the natural rate of movement of the individual animal. Every effort should be made to keep older, sick and young animals together with their companions or mothers as they are moved to the trap. The helicopter should not move or capture compromised, old, weak or young animals.
iii. Establish strict requirements for suspending helicopter roundup operations in temperatures below 32 degrees F (freezing) or over 90 degrees F. Roundups outside of this temperature range would be blatantly inhumane. (Attachments 2, 3, and 4)
B. Public Observation
The EA fails to consider and address the following with regards to public observation (First Amendment rights):
· Provide meaningful public observation of all agency actions – the “APPENDIX G - Wild Horse and Burro Gather Observation Protocol” fails to address whether or not the public will have any ability to document and observe the burros running into the trap, document and observe the treatment of the burros in the trap, document and observe the burros in the temporary holding pens. By keeping public observers so far from the trap and/or holding pens – the BLM intentionally is rendering public observation meaningless.
There is significant public interest in the agency’s management of wild horses and burros and its management of these protected animals. The NAS specifically recommended to the BLM to improve the transparency of its management of the Wild Horse and Burro Program. The treatment of the wild horses/burros and agency transparency are paramount.
· Real-time cameras must be installed on any traps, corrals and temporary holding pens, again, so that USFS personnel, public and media can monitor the entire roundup operation and treatment of the animals. If meaningful public observation, as described above, is not provided real-time cameras are necessary to ensure the public has the ability to observe the government action. THE OMISSION OF ADDRESSING THIS ISSUE IN THE EA WILL BE CONSIDERED A DENIAL OF THIS REQUEST.
The recommendation of real-time cameras is also supported by a report commissioned by Cattoor Livestock Roundup, a long-time roundup contractor hired by the BLM which states:
“Video monitoring of animal operations is a good way to ensure humane handling is taking place on a daily basis. Video cameras mounted in helicopters and in the capture and holding pens can also render the activists’ videos as simply nothing more than proof that your business ‘walks the walk’ when it comes to upholding animal welfare standards.” The report was prepared by Mark J. Deesing, Animal Behavior & Facilities Design consultant for Grandin Livestock Handling System. Deesing was an assistant to the highly regarded livestock industry consultant Dr. Temple Grandin. (Attachment 5)
Video cameras will improve the transparency of the operations and enable the BLM and public to monitor the direct impact motorized vehicle usage has on wild horses/burros and the environment. TCF would be happy to provide technical assistance and financial assistance to establish these real-time cameras as described above.
· All removal operations must be located on public lands to allow public observation of all activities. No government operations should be located on private lands for which the owners will not give permission for public observation of activities.
· Real-time cameras with GPS must be installed on all aircraft and/or helicopters used in operations and video should be live streamed on the Internet. This will improve the transparency and accountability of roundup operations and enable the BLM and public to monitor the direct impact motorized vehicle usage has on wild horses and the environment.
VII. National Academy of Sciences and National Research Council
The Bureau of Land Management (BLM) cannot discount or ignore the sentiment of the public. Ignoring or burying public comments submitted by Americans by labeling their comments “form letters” is the BLM’s attempt to silence Americans’ strong support for wild horses and burros. The California Desert District Office must, as recommended repeatedly by the National Academy of Sciences, acknowledge and listen to the changing societal values when it comes to the management of America’s wild horses and burros.
The NAS states:
“Horse and burro management and control strategies cannot be based on biological or cost considerations alone; management should engage interested and affected parties and also be responsive to public attitudes and preferences.” p. 292
The 1982 National Research Council report on the BLM’s wild horse and burro program stated:
“Attitudes and values that influence and direct public priorities regarding the size, distribution, and condition of horse herds, as well as their accessibility to public viewing and study, must be an important factor in the determination of what constitutes excess numbers of animals in any area… [A]n otherwise satisfactory population level may be controversial or unacceptable if the strategy for achieving it is not appropriately responsive to public attitudes and values…”
“Biologically, the area may be able to support 500 cattle and 500 horses and may be carrying them. But if the weight of public opinion calls for 1,000 horses, the area can be said in this context to have an excess of 500 cattle. For these reasons, the term excess has both biological and social components. In the above example, biological excess constitutes any number of animals, regardless of which class above 1,000. Social excess depends on management policies, legal issues, and prevailing public preference...”
According to the White House Council on Environmental Quality (CEQ), under National Environmental Policy Act (NEPA), “agencies are required to determine if their proposed actions have significant environmental effects and to consider the environmental and related social and economic effects of their proposed actions.”
As stated by the NAS, NRC and CEQ the BLM must consider the prevailing public preference which in this case is TCF and our supporters. We strongly oppose the Proposed Action and sufficient Alternatives were not considered as discussed herein.
The Draft EA should consider recommendations and reviews from the NAS and NRC – while directed to the BLM Wild Horse program, these positions are applicable to the USFS management of Congressionally-protected wild burros.
The NAS Report also supports the above requirements of FLPMA:
“It is unlikely that all the values involved can be monetized in a way that is satisfactory to all parties, so use of economic policy tools such as benefit-cost analysis and contingent valuation, although potentially informative, is not able to resolve value differences fully and is not adequate to support decisions.” p. 273
“Horse and burro management and control strategies cannot be based on biological or cost considerations alone; management should engage interested and affected parties and also be responsive to public attitudes and preferences.” p. 292
VIII. Conclusion
We appreciate that the wild burros living in the Centennial, Panamint and Slate Range Herd Areas are in a somewhat unique situation given the Department of the Navy’s overlapping jurisdiction. However, we strongly urge the BLM to initiate sincere discussions with the Department and outline the dire situation wild burros face today (as described earlier) and to work to identify actions that could be taken to enable these burros, or a portion of these burros, to remain on their Congressionally-designated habitat.
Thank you for your consideration,
Dana Zarrello
Executive Director
The Cloud Foundation
Attachments
1. “Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward,”
National Academy of Science, July 2013
2. Dr. Hutchinson letter
3. Dr. Garretson letter
4. HSUS Report: Recommendations on the Bureau of Land Management’s Standard Operating
Procedures for Wild Horse and Burro Gather Operations
5. Temple Grandin letter dated 2012