“This herd is not even above AML by the BLM’s own count, only 648 adult horses in the flyover count in April 2016”
The BLM is planning to roundup wild horses in the Adobe Town Herd Management Area in 5 separate locations in order to put radio collars on 30-40 wild mares. The study will begin in December 2016 and end in 2020.
This study, which will be conducted by the University of Wyoming’s Department of Ecosystem Science and Management has the following purpose:
“The Proposed Action is to implement a five (5) year research study (Appendix 1) that would document habitat selection, movement between habitats, seasonal use, and migration patterns of wild horses, within and outside of the ATHMA. The research objective is to understand how horses move across the Colorado-Wyoming border, how the removal of horses from the checkerboard portion of the HMA influences the movement of mares from non-checkerboard portions of ATHMA (i.e. creation of a void), how horses select landscape resources relative to their proportional availability, and how site fidelity of horses is influenced by season.”
Originally they were considering using bait trapping to capture the mares which would have much less chance of injuring or killing the horses than a helicopter roundup. They do not even discuss it as an option in the EA despite the response to the public’ comments to the Scoping Document which requested them to use this much less stressful and harmful method. Bait trapping also allows the family bands to be kept together, intact, much more easily.
The BLM dismisses very easily any impact on the wild horses that are rounded up using helicopters. Many will be injured and die, most will lose their families, foals will be separated from their mothers, and they will most likely be disrupted in a very substantial way from their normal areas and routines which DOES impact the outcomes of the study. Helicopter roundups use fear to drive the wild horses which is inhumane and also leads to extreme fear of helicopters.
This herd is not even above AML by the BLM’s own count, only 648 adult horses in the flyover count in April 2016.
My second biggest problem with this study is the use of radio collars which in past studies have led to injury and death when horses become entangled with brush or on fences or get a hoof caught. They say that they have remotely detonated release mechanisms on the collars so they can release the collar if the collar stops moving – but there are a tremendous number of questions that are unanswered:
- Why are they not using breakaway collars that break if the horses re in trouble, which have been used successfully before?
- How close to the collar does the person have to be to trigger the remote release mechanism?
- Does it work from say 70 miles away at the Rawlins BLM office or does the person have to be within view?
- What happens in winter when it is impossible to drive into the area?
- If they cannot drive into the area do they have the funds to charter a helicopter to fly over so they can detonate the remote release? If so, have they considered the stress upon the horses when a helicopter gets near them?
- Will it work when the temperatures get below -10 Fahrenheit? I was at a “gather” in Adobe Town in December 2013 when they released 40 wild mares and it was -19 degrees before I got to the highway.
- Does it hurt the horse when the release remotely “detonates?”
- What if the remote release fails? How can they help the mare that is in trouble?
- How often are they monitoring the collars to see if one has stopped moving? What about weekends?
- What about the reactions of the mare’s family members to this strange device now around her neck? What if she is rejected by the other horses because of it?
(They cite testing the collars at a short term holding facility, Palomino Valley. This is a completely different situation than the horses will face in the wild. Horses are not in families in holding facilities and there are not brush and fencing to get hung up on).
- Why can’t they use a small GPS under the skin? This would be so much safer and less intrusive for the mares. These “collars” are very old and low tech.
For all of these unanswered questions and because wild horses have been injured and died because of radio collars in previous studies: https://www.nap.edu/read/18466/chapter/5 I again suggest that they do NOT use radio collars but instead use Interns to follow, track, observe and photograph horses from specific areas.
This would remove the need for a helicopter roundup, which would provide far less stress and injury on the horses, and if would also provide more accurate data from people on the ground. Ten horses in Adobe Town are very colorful, and easily distinguished, so it would not be impossible to follow specific horses. It does not matter than some horses are less easy to find and see because if they have a few horses from each area, it does not matter which horses are less easily observed. If you round them up by helicopter this will be a complete disruption to the horses’ families and movement patterns. If you observe them without rounding them up you will obtain much more accurate data on where the horses are and move to.
My final argument is that this study is in no way, shape or form in the best interests of the horses. The researchers are seeking to prove that wild horses will “move into a void” created by rounding up and removing horses from the Checkerboard, so they can “prove” that it impossible to remove horses from the Checkerboard and keep them out. They are also hoping to “prove” that wild horses degrade riparian areas. There is no attempt to account for livestock grazing. They do not care about wild horse behavior or band fidelity, or they would use human observers. This cruel and dangerous study which is slanted toward proving that wild horses have no place on the HMAs in the Checkerboard should not be allowed to move forward. Since BLM has now formally withdrawn the 2016 Checkerboard Removal Decision Record – which was not the case at the time it issued the Draft EA – BLM should not move forward with the radio collar research because a major underlying premise (that 500+ wild horses would be removed from the Checkerboard before the radio collar research began) has now been eliminated. In other words, the entire purpose behind this roundup was to see how horses move in response to a Checkerboard roundup; since there will be no Checkerboard roundup, there is no legal basis for the radio collar research as currently described in the Draft EA.
Please select alternative 2.2 No Action
This study is poorly conceived and planned and does NOT take the well being and humane treatment of the wild horses involved into proper consideration. This is not managing wild horses in the least invasive way possible, as they are mandated by the 1971 Free-Roaming Wild Horse and Burro Act. They should spend the next few months revising the study and if then they do decide to move forward they should use another capture method, which is bait trapping which they said they would discuss in the EA but failed to do. It is far more humane and will result in many less injuries and deaths. They should come up with a new EA including Bait Trapping or no rounding up at all but using direct observation as alternatives. And they should use a newer, safer technology if they do wish to proceed with tracking the horses and eliminate the proposed use of radio collars.
The earliest they could start this roundup is December. They should not do it in December – it can get very cold, the horses are at greater risk of colic and injury when run in extremely cold temperatures. They should wait until next year in late summer or fall and address the questions that I have listed about the study and issue a new EA.
Please send your comments to the BLM here by November 1, 2016 at 4pm Mountain Time:
Wild Horse and Burro Specialist
Bureau of Land Management
Wyoming High Desert District
Rawlins Field Office
1300 North Third Street
P.O. Box 2407
Rawlins, Wyoming 82301
Fax: (307) 324-4224
Electronic comments must be sent to the following email address to be considered:
blm _ wy _ adobetown _ email@example.com
(Please include “Adobe Town EA Comment” in the subject line.)
From the BLM: Public comments are most helpful if they are specific. The regulations (40 CFR 1503.3), state that comments on a proposed action ‘ shall be as specific as possible and may address either the adequacy of the statement or the merits of the alternatives discussed or both.” The most valuable comments are those that cite specific actions or impacts in the document and offer informed analysis of what is presented.
Also, pleased do send personalized comments in your own words. The BLM will count all of the form letter comments as one, which is not helpful for the horses.