August 7, 2018

Ed Roberson
Utah State Director
Bureau of Land Management
440 W 200 S #500
Salt Lake City, UT 84101
Sent via email: eroberso@blm.gov

cc: Gus Warr, Utah Wild Horse & Burro State Lead, gwarr@blm.gov
Bruce Rittenhouse, Acting Division Chief, Wild Horse and Burro Program, brittenh@blm.gov

Dear Mr. Roberson:

This letter is a formal complaint and request for action against the contractor currently conducting the BLM wild
horse roundup under way in the Bible Springs Complex and Sulphur Mountain Herd Management Area (HMA) in
Utah.

Our observer, Steve Paige, has been onsite at the roundup and has documented inhumane roundup practices
that we believe violate the BLM’s Comprehensive Animal Welfare Policy (CAWP) requirements for helicopter
drives. These include helicopters:

- Flying dangerously close to terrified wild horses.

- Driving wild horses along barbed wire fence lines, causing many to crash through the barbed wire
fencing.

- Driving horses at a distance and speed that is causing young foals to fall behind and be separated from
their mothers.

- Stampeding horses with previous injuries such as blindness and leg deformities for miles at strenuous
speeds

- Roping a 2-year old stallion to capture him and get him into the trap.

These incidents, which have been occurring routinely over the course of this roundup appear to be MAJOR
violations of the following CAWP requirements.

- B (1) requiring helicopters use pressure and release methods to herd the animals in a desired direction
without not repeatedly evoking erratic behavior causing injury or exhaustion in the wild horses and
burros. (flying dangerously close to helicopters; causing them to repeatedly crash into barbed wire.)

- B (2) requiring that the distance and rate of the drive “be determined … considering the weakest or
smallest animal in the group (e.g., foals, pregnant mares, or horses that are weakened by body

American Wild Horse Campaign | PO Box 1733, Davis, CA, 95617 | AmericanWildHorseCampaign.org
 condition, age, or poor health) and the range and environmental conditions present. (Driving and
pressuring horses in a manner causing foals to be left behind.)

- B (2)(a) requiring that weak or debilitated horses be identified and captured through appropriate
measures. (Stampeding injured and blind horses.)

- B (2) (c) requiring that the roping of a wild horses to be approved and primarily limited to the following
circumstances: to reunite a mare or jenny and her dependent foal; capture nuisance, injured or sick
WH&Bs or those that require euthanasia; environmental reasons such as deep snow or traps that
cannot be set up due to location or environmentally sensitive designation; and public and animal safety
or legal mandates for removal.

As a result, we call on the BLM to:

1. Suspend the roundup underway currently in Utah and ground the helicopters while an investigation is
undertaken of the BLM’s and Contractor’s conduct at the Bible Springs roundup.

2. Require any resumption of roundup activities in the Bible Springs Complex to strictly enforce CAWP
standards, particularly with regard to helicopters flying dangerously close to horses, the stampeding of
horses along or through barbed wire fencing, and the stampeding of lame, injured, weak horses or very
young foals.

In closing, we note that the horses are coming in from the Bible Springs roundup in Body Condition 5 – the
healthiest condition for a wild horse, dispelling claims from Rep. Chris Stewart and others of mass wild horse
starvation on the range. Additionally, your agency is spending hundreds of thousands of dollars to round up wild
horses from public lands where very few wild horses remain (in the Bible Springs HMA, the estimated horse
population is only six horses over the established population limit of 60 horses) but where over 1,400 privately
owned cows are allowed to graze thanks to our taxpayer subsidies.

This roundup exemplifies your agency’s inhumane treatment of wild horses, fiscally reckless policies and
continuation of the “business as usual” practices, which five years ago, the National Academy of Sciences called
“expensive and unproductive for the BLM and the public it serves.”

Mr. Roberson, we will appreciate hearing back from you as soon as possible regarding the CAWP violations and
trust that you will take swift action to address this critical situation. Thank you for your consideration.

Sincerely,

Suzanne Roy, Executive Director

sroy@americanwildhorsecampaign.org
919-697-9389

American Wild Horse Campaign | PO Box 1733, Davis, CA, 95617 | AmericanWildHorseCampaign.org