February 14, 2000

Mr. Al Pierson
State Director
Bureau of Land Management
5353 Yellowstone Road
Cheyenne, WY 82009
Dear Mr. Pierson

It is my understanding that the Wyoming BLM plans to round up wild horses
with a helicopter beginning February 28, 2000. For the past two Februaries
there have been significant protests regarding a helicopter round up
beginning in late winter. In both years the round ups were canceled. Again,
there has been significant concern expressed which points out just how
controversial and contentious rounding up wild horses is at this time of the
year.

Using a helicopter to round up wild horses, in and of itself, is stressful.
Add to this the significant stress on the animals at this particular time of
the year, I would like to cite Dr. Joel Berger's research as reported in the
book Wild Horses of the Great Basin To my knowledge, Dr. Berger's work is
the only comprehensive study to be published regarding the natural history
of wild horses in the United States.

Dr. Berger states "old bachelors were the most emaciated following
winter...those (mares) that lactated emerged from the winter in the poorest
condition...In the Great Basin, winter is the most stressful period. Horses
in all sex and age categories were in the worst condition at the end of
winter and in the best during summer. Females with foals suffered obvious
lactational costs in the winter as illustrated by their poor body conditions
when compared to better conditioned, non-lactating females. These findings
agree with those presented for New Forest ponies or for domestic horses that
lost winter weight when raised on Montana rangeland."

In regard to pregnant mares, Dr. Berger says "because of the winter-related
stresses and because the last trimester of pregnancy demands the most
nutritionally, mothers weaned their offspring during winters."

According to field studies conducted in Wyoming 1978 - 1979, well over half
of the wild horse foals are born prior to May 30th. According to Dr. Werner
McFarland (DVM) concentrations of foaling activity occur in mid to late May.

For the purposes of this discussion then, we have used May 15 - May 30th as
the peak foaling period.

UpThe BLM review of 1999 stated that the gestation period for horses is
eleven months which is incorrect according to knowledgeable sources like Tim
Hawcroft, DVM, in his book The Complete Book of Horse Care. The gestation
period for domestic and wild horses is 342 days give or take 10 days. An
older mare might foal at 12 months while a filly might foal early. 342 days
equals 49 weeks less 1 day.

On page 6 of the 1999 BLM review it states "from these data and
consultations, it was confirmed that avoiding unaccustomed stress after the
onset of the 38th week of pregnancy was an appropriate safeguard to avoid
stress-induced abortions..."

If you subtract 38 weeks from 49 weeks you come up with 11 weeks in which it
is not safe to unduly stress pregnant mares without risk of harm. If peak
foaling is mid to late May, the latest date to avoid this period is March 1.
After this date the majority of mares will be past their 38th week of
pregnancy.

This then, gives the Wyoming BLM one day to safely round up wild horses
according to their own documentation!

Aside from the inaccurate gestation stat, the review data contains other
inaccurate, misleading, and contradictory material. For example, percentages
don't add up to 100% in the case of foaling dates. A significant percentage
of the foals are missing.

Aside from the science which does not add up, what responsible horse breeder
would allow his or her pregnant horses to be driven by a helicopter in late
winter for miles over broken terrain?

How then, can BLM justify treating wild horses in this manner? It is a cruel
and inhumane practice at this time of the year.

At our February 10, 2000 meeting with the BLM regarding this very practice
(spring round ups), BLM officials admitted that private land owners where
wild horses are to be removed in the spring, are not asking for them to be
removed in the spring. Even BLM has admitted that this is not the best time
of the year for this kind of operation. It makes no sense then, to proceed
with this helicopter round up at a time of the year when the risks are so
great.

Wild horses are a national treasure to be held precious. Millions of
Americans would abhor what BLM proposes. I hope you reconsider your spring
gather operations and let science, your conscience, and common sense guide
you.

Best Regards,


Ginger Kathrens
Co-Chair, Colorado Wild Horse and Burro Coalition
Co-Founder, Wild Horse and Burro Freedom Alliance