BLM Advisory Board Meeting Signals Dark Clouds Ahead for Wild Horses & Burros

By Suzanne Roy, AWHPC

The BLM held its second, and final, Wild Horse and Burro Advisory Board meeting of 2015 on September 2nd and 3rd in Oklahoma City, OK.  Of all the board meetings I have attended since 2009, this was by far the most ominous. Emboldened by years of BLM’s crisis-creating, the pro-slaughter majority on this board is now openly endorsing slaughter as a solution to the BLM’s budget woes. These members, who overwhelmingly represent livestock interests, are also aiming to reduce wild horse numbers below the already ridiculously low allowable population levels.

The BLM Wild Horse and Burro (WH&B) program, under the leadership of Dean Bolstad, a long-time BLM bureaucrat, seems only happy to comply. In fact, after the pro-slaughter board members spoke explicitly about the need to overturn Congressional ban that prevents the BLM from selling wild horses and burros for slaughter, Bolstad commented that, of the 49 board meetings he has attended since 2003, this was the best one yet.

In 2013, the National Academy of Sciences evaluated the BLM’s WH&B Program and concluded that “continuation of ‘business as usual’ practices will be expensive and unproductive for the BLM and the public it serves.” Undaunted by this warning, the BLM is continuing down the same destructive path, announcing at the meeting:

-         Expansion of helicopter roundup contracts to include three companies, including Sun J Livestock, which was found previously to have engaged in “unprofessional” conduct, including the electro-shocking of wild horses.

-         Scaling up removals under the guise of sage grouse protection.

-         Spending over 70% of the budget to round up and warehouse horses, while continuing to spend less than 1% on humane fertility control to manage wild horse populations on the range.

-         Spending millions on research, much of which is aimed at perfecting techniques to permanently sterilize wild horses on the range.

-         Meeting with Congress to share its self-inflicted budget woes, with the goal of overturning the ban on selling captured wild horses and burros “without limitation” that would enable kill buyers to purchase large numbers of wild horses and burros for slaughter.

Much discussion at this board meeting by the vocal, pro-slaughter majority was centered on achieving “AML,” or Appropriate Management Level, which, the BLM has set at 26,715 WH&B with a 2015 population estimate of 58,150. To attain that goal, nearly 22,000 wild horses and burros would have to be removed from the range!  This ridiculously low AML is almost the same as the number of horses and burros that existed when Congress determined that the animals were “fast disappearing” from the range in 1971. While any discussion of raising the AMLs for wild horses and burros was quickly shut down, the BLM was more than happy to entertain discussion about lowering current AMLs. Bolstad said AML was only a “goal,” suggesting that the populations could be taken lower than the “low AML” if necessary. Of course, that “goal” becomes a hard and fast number to be reached whenever wild horse populations exceed that arbitrary AML number.

In all, the bias of the BLM and its cattlemen allies on the board was more obvious at this meeting than at any meeting we have ever attended. The endgame for the WH&B Program is fast approaching, if not already here. The apparent goal of BLM, which was to create a crisis both on and off the range to justify slaughter as the only rational solution to their fiscal woes, is close to being attained. Now, they are clearly getting their ducks in a row to get Congress to agree. It’s up to us to make sure that doesn’t happen. We are literally the line that stands between the mustangs and burros and certain doom, and we must strengthen our resolve to stand up for public interest in protecting these American icons against the narrow special interests that seek their destruction. Fortunately, many members of Congress on both sides of the aisle will stand with us if we continue to ask them to do so.

Please read on for a detailed overview of this very troubling BLM WH&B Program Advisory Board meeting. Contact information for the members of the Advisory Board can be found here. The meeting agenda and related materials can be found here

1. Opening Remarks – Mike Tupper, Acting Designated Federal Officer, Deputy Assistant Director, Resources & Planning, BLM

Tupper is a long-time BLM employee who is new to the WH&B scene. In a meeting earlier this year, BLM director Neil Kornze described him as the “new CEO of the Wild Horse and Burro Program.”

Tupper presented some updates on the program. Highlights include the following:

OIG INVESTIGATION OF BLM’S SALE OF WILD HORSES FOR SLAUGHTER: The BLM is “still waiting” for the results of the Office of Inspector General (OIG) investigation into the agency’s sale of more than 1,700 wild horses to known kill buyer Tom Davis, a case that was exposed by the media four years ago. Davis was unable to account for the whereabouts of the vast majority of the horses he purchased from the BLM. It is presumed they were slaughtered in Mexico, in violation of the Congressional prohibition on the BLM’s sale of wild horses for slaughter. “Some of these things take a long time,” said Tupper of the nearly four-year-long investigation.

DEATHS OF WILD HORSES IN KANSAS FEEDLOT: A total of 160 wild horses perished in a Scott City, Kansas feedlot after the BLM relocated them from a long-term holding pasture after the operator of the facility declined to renew his contract with the BLM. This is a significantly higher death toll than previously reported. BLM had previously attributed the deaths to age, stress and changes in environment and feed.  Tupper stated that although “maybe we weren’t as prepared as we should have been,” the situation has been stabilized and lessons were learned. 

BLM ROUNDUPS ON THE HORIZON: BLM has committed to rounding up wild horses to the low Appropriate Management Level (AML) in 22 Herd Management Areas (HMAs) that have been identified as Sagebrush Focal Areas (SFAs).

BLM EMERGENCY ROUNDUPS: At the time of the meeting, these were underway in Cold Creek, Nevada, where horses are in poor condition due to lack of forage, and in three Idaho HMAs where the Soda Fire burned 100 percent of two HMAs and 30 percent of a third. The Soda Fire claimed the lives of 30 wild horses. In Cold Creek, the BLM removed 234 wild horses and euthanized 28 of them due to “poor prognosis for recovery.”

BLM ON CAPITOL HILL: The BLM has been “doing outreach” to the House and the Senate and the Office of Management and Budget.

2. BLM Response to Advisory Board Recommendations – Dean Bolstad, Acting Division Chief, Wild Horse and Burro Program

The BLM’s response to the recommendations of the Advisory Board, made at its last meeting can be found on page 56-60 of the pdf file at this link

Of note is the BLM’s rejection of the Advisory Board recommendation that “BLM should pilot reintroducing a non-reproductive herd into a zeroed out Herd Area (HA).” After leading a board working group on for several years about investigating HA territory that might be suitable for repatriation of wild horses, especially those in holding, the BLM now claims that “there are very few opportunities where it would be appropriate.” Since 1971, the BLM has removed all horses and burros from 40 percent of originally designated wild horse and burro habitat. The BLM claims that wild horses cannot be managed in these areas, although livestock grazing continues in full force on most of the zeroed out lands.

3. BLM WH&B Program Update – Dean Bolstad, Acting Division Chief

PZP PROGRAMS: BLM is working with Humane Society of the U.S. (HSUS) and The Cloud Foundation to identify HMAS where PZP birth control darting programs could take place. BLM is also working with HSUS on a PZP trial on burros, using darting and bait trapping, to asses “if it is feasible or not.”

SAGE GROUSE: Wild horse and burro management in sage grouse habitat is the program’s top priority.

NEW HELICOPTER CONTRACTS: BLM has awarded new helicopter contracts to three Utah-based companies:

·        Cattoor Livestock Roundup, the BLM’s longtime roundup contractor

·        Sun J Livestock, the contractor previously used by BLM and found to have engaged in “unprofessional conduct” at the BLM’s 2011 Triple B roundup: “horses were repeatedly shocked with an electrical animal prod, sometimes in the face, and in one case, the use of this electrical prod led to a horse becoming stuck in a panel at the loading site. Some videos reveal horses being struck in more than one instance with the trailer gate to induce loading, and in one instance a horse appears to have been kicked in the head by a Sun J employee. In one video it appears that a horse was dragged into a trailer by a rope around its neck.”

·        Sampson Livestock, the company that the BLM used to round up Cliven Bundy’s “trespassing” cows in 2014.

COMPREHENSIVE ANIMAL WELFARE STANDARDS: The new standards have been written into the new helicopter roundup contracts, and contractors are required to take an online training class about them.

4. Shade Research Update – Paul Griffin, Research Coordinator Information

Paul Griffin comes to the BLM from the U.S. Geological Survey (USGS) where he previously worked with BLM on improving the agency’s wild horse and burro census methods. At this point in the meeting, Griffin made a presentation to the Board about the BLM’s shade research.

LET THEM SWEAT: These highly controversial studies, funded by BLM, aimed to determine whether or not horses need shade at holding facilities in the West. One study (pdf page 91 at this link), conducted by UC Davis scientists, looked at whether horses prefer having access to shade. The conclusion: when it is available, horses use shade (something any horse owner could have told the BLM for free). The second study, conducted by the U.S. Department of Agriculture looked at whether horses suffer from thermal stress in the summer if not provided with shade. Conclusion: As long as the horses can sweat 1.3 – 1.4 gallons per hour and have access to adequate food, water and trace minerals, horses can avoid thermal stress. The comfort level of these horses and burros, who in the wild had the ability to seek out shelter from the elements, was not a factor considered in this research. BLM’s overall conclusion: “Although wild horses and burros may prefer shade, it is not required for their well-being.”  Only compromised horses (ill, nursing mares) may require shade.

5. Off-Range Update – Holle’ Hooks, Off-Range Branch Chief, Wild Horse and Burro Program

The BLM has reorganized its WH&B program into an Off-Range Branch, based in Oklahoma City, and an On-Range Branch based in Reno, Nevada. Ms. Hooks, the head of the off-range branch, presented an update on developments relating to BLM’s numerous holding facilities.

SHADE GUIDELINES (INTERIM): BLM will provide shade in sick pens for compromised animals. Providing shade to other animals at holding facilities will be up to the discretion of the facility manager. BLM is developing a Comprehensive Animal Welfare Memo for its “off-range corrals” (formerly known as short-term holding pens).

Of significant note is the fact that since BLM has now determined that horses and burros prefer but do not need shade, it is re-evaluating its requirement that adopters provide shelter to wild horses and burros! Since the agency does not want to provide shade to the horses and burros warehoused in holding pens, it is considering changing the federal regulation that says shelter must be made available for all horses and burros adopted from the BLM!

MORE SPACE FOR WAREHOUSING: As of July 2015, the BLM warehoused 46,492 wild horses and burros in holding facilities. The total capacity of these facilities is 50,929 and the BLM is expanding its holding for captured mustangs:

·        4 new contracts have been awarded for new short-term holding facilities with the capacity to hold 3,100 horses and burros.

·        3 awards have been awarded for long-term holding facilities with the capacity to hold 1,200 wild horses and burros.

·        2 new “eco-sanctuary” contracts have been awarded in Oklahoma and Wyoming to house 250 wild horses.

·        BLM expects to lose long-term holding space for 3,750 animals in 2016. This will result in moving horses from long-term holding (which costs under $2 per horse per day) to short-term holding, which can cost $5 or more per animal per day.

·        BLM is considering 12 new holding proposals with possible capacity to hold 4,200 animals.

ADOPTIONS: BLM has adopted out 2,500 WH&B so far this year. This is up from the 788 placed by this time last year. (See pdf page 83 of this link.) Placements include:

·        Mustang Heritage Foundation adopted out 700 horses.

·        Inmate Training adopted out 300 horses.

·        HSUS adopted out 250 burros.

·        BLM put out a Request for Applications (RFAs) for burro training on Sept. 8


·        Ecosanctuaries – review current agreements, put out RFA for new proposals.

·        Conduct socioeconomic research to determine public demand for adopted mustangs and burros.

6. New Method for Monitoring Animal Use in Riparian Habitats– Scott Fluer, Wild Horse Specialist, Wyoming

Fluer presented very interesting results of a pilot project using trail cameras to monitor a riparian area in west central Wyoming. The study evaluated which animals were using the riparian area, when they were using it and what they were doing while they were there. The cameras took two photographs every 15 minutes between 4 am and 10 pm and they analyzed over 32,000 photos.

The study’s preliminary conclusions are:

·        Cows frequent riparian areas the most, spending “most of the day” there, and engaging in loafing behaviors more than 50% of the time.

·        Wild horses frequented the riparian area for shorter periods of time (a few hours vs. “most of the day”) and spent less time “loafing.” Wild horses showed more activity than expected in the evening.

·        Other wildlife species used the riparian areas for much shorter periods of time.

7. U.S. Forest Service Update – Barry Imler, Rangeland Program Manager, USFS

PLANNING BUT LIMITED FUNDING: The Forest Service (FS) has hired a WH&B specialist at the national level. The FS has stopped placing wild horses in BLM holding facilities and the proposed 2016 budget includes funds to reimburse BLM for the FS animals already in holding facilities.

The FS is looking to partner with other stakeholders, including tribes and local authorities, on WH&B management.  “We do not have staff or funding for all the animals that probably need to come off the land.”

FS estimates they should have 2,200 – 2,400 head and they currently have approximately 7,000 animals.

 “PZP alone is not going to address overpopulation.” They are looking for “anyone interested in finding good homes for these [excess] animals.”

SALE WITHOUT LIMITATION: The FS is not under the same restriction as the BLM with regard to sale without restriction of any horse over the age of 10 or any horse put up for adoption three times and not adopted. In other words, the FS can sell wild horses and burros for slaughter. “We are under no obligation to sell those animals at auction to the highest bidder. Price is not an issue.” The FS is looking for advocacy groups to buy excess horses.

FS has developed a flow chart for its handling process for gathered wild horses and burros.

Editor’s note: The FS should incorporate into its management plans a policy of leaving horses over the age of 10 on the range. It’s not reasonable to suggest that advocacy groups will be able to take in the 5,000 wild horses the FS wants to remove so private livestock can continue graze in our National Forests in designated WH&B Territories.

AMLS OFF LIMITS: The FS is not willing to consider increasing the allowable management levels (AMLs) for wild horses and burros in an effort to decrease the number of horses considered to be “excess.”  They are looking only at territory plans, not amending Forest plans.

Editor’s note: Acting WH&B Division Chief Dean Bolstad helpfully interjected here that AML’s are not mandatory levels, they are just “targets,” and the BLM or FS can bring these population levels below these already ridiculously low levels if it wants.

8. General Research Update - Paul Griffin, Research Coordinator, Wild Horse and Burro

BLM’s research advisory team has re-formed after a two-year hiatus (when former program research coordinator Jeff Manning abruptly left his position). The new team includes Griffin, BLM Advisory Board member Dr. Sue McDonald, BLM “on-range” manager Brian Fuell, BLM WH&B specialist and former Nevada state lead Al Shepherd, and Al Kane, a USDA veterinarian.


·        Population growth suppression.

·        Improving models for predicting outcomes of management actions.

·        Improving understanding of WH&B populations, movement between HMAs, habitat use and impacts.

·        Improve understanding of adoption demand & public perception.

BLM has awarded 4 research grants for university led studies:

·        $850,000 study at Louisiana State University of “membrane disrupting peptide LHRH conjugates.” Looking for a longer-acting contraceptive gel.

·        $159,700 study at Colorado State University of revaccination with GonaCon to determine ideal timing of 2nd inoculation to achieve contraceptive effect.

·        $800,000 study at Colorado State University to develop a vaccine sterilant for mares. In theory this vaccine would cause the mare’s ovaries to release all of her eggs at once causing them to be sterile. Such a vaccine does not exist yet.

·        $300,000 Study at the University of Kentucky of tubal ligation via colpotomy. They are testing the use of cable ties to close off mares’ fallopian tubes.

BLM expects to finalize four additional university-led grants this month:

·        Minimally invasive tubal ligation.

·        Minimally invasive laser ablation of the oviduct.

·        Ovariectomy via colpotomy.

·        Improved strategy for long-term PZP delivery.

BLM-led research:

·        “Knowledge, Values, and Preferences Study” – assessing public’s knowledge of wild horse and burro issues and values placed on having them on public lands. Awaiting approval from OMB for information collection. Will conduct focus groups followed by national survey.

·        “Demand Study” – Assessing demand for adoption/sales of wild horses and burros, and the factors that affect these demands.

USGS Research:

·        Estimating population size through fecal DNA analysis.

·        Developing reliable radio collars. They have tested in pen trials and are ready to go in the field for mares and Jennies. For stallions and Jacks the collars did not work as well (their necks expand when they put their heads down) so they are looking at gluing microchips into their tails.

·        Carrying Capacity modeling for adapting to climate change.

·        SpayVac – trial stopped. Results were variable. The manufacturer is no longer interested in making SpayVac. Two University of Oregon researchers looking at taking it over – for now SpayVac is out.

·        Burro population estimating techniques – using radio collars to figure out how many burros are missed during censuses. Study initiated in September 2015 in Lake Pleasant, AZ and Sinbad, Utah.

·        Sentinel demography of burros – proposal is in the peer review stage.

·        IUD – designing a device specifically for mares.

·        Evaluating behavior of spayed mares. Proposal is in USGS review process. Will use ovariectomized mares. Dr. King is a behavioral ecologist who will be looking at behavioral impacts.

·        Behavior and ecology of geldings. Has been approved by BLM. Initial study to begin September 15 in the Conger HMA.

·        Sentinel demography of free-roaming horses.

·        Win Equus II – Developing a revised and expanded population model.

·        Testing efficacy of contraception methods on burros (proposal stage).

Aerial Surveys

This year surveyed 48 HMAs, 8 HAs and 9 Wild Horse Territories (WHTs).

GIS map

Jason Leuterman is developing a GIS map, which will "tell you everything you want to know about an HMA” except of course, the forage allocation between private livestock and federally protected WH&B.

9. On-Range Update – Bryan Fuell, On-Range Branch Chief, Wild Horse and Burro Program, BLM

Statistics presented:

·        National “Appropriate” Management Level: 26,715.

·        FY 2015 population estimate: 58, 150.

·        Increase of 8,947 animals over 2014 estimate.

·        1,857 WH&B removed in 2014.

·        3,289 WH&B planned to be removed in 2015.

·        384 mares treated with fertility control in 2014.

·        466 mares treated with fertility control in 2015.

FY 2015 Summer/Fall Roundups

Kiger, Riddle HMAs in Oregon.

West Douglas in Colorado.

Emergency or private land roundups:

·        Wood Hills, NV – outside HMA

·        Seaman HA, NV

·        Miller Flat HA, NV

·        Wheeler Pas HMA, NV

·        Hardtrigger, Black Mountain, Sand Basin, Idaho – emergency due to fire.

“Public safety” /Private lands – burros

·        Roundups in Nevada, Arizona and California

Fiscal Year 2016 Fall/Winter Roundups:

·        Beattys Butte (1500 horses to be removed!) – Sagebrush focal area.

·        Conger, UT

·        Frisco, UT

·        Sinbad, UT

Summer 2016 roundups to be determined.

Sage Grouse:

·        Fish and Wildlife Service decision regarding whether or not to list the bird as endangered expected this month.

·        Consolidated effort to head off listing by amending 98 BLM and FS Land Use Plans – 13 Environmental Impact Statements produced.

·        BLM has identified Sagebrush Focal Areas (SFAs) – areas with intact habitat for sage grouse; Priority Habitat Management Areas (PHMAs) – areas with good, medium to poor habitat; and General Habitat Management Areas (GHMAs)

·        106 WH&B Herd Management Areas identified that contain one, two or all three levels of sage grouse habitat.

·        BLM committed to reach AML in SFAs by 2020

Editor’s note: BLM has provided AWHPC with a list of HMAs in SFAs and PHMAs.



California – Nut Mountain, Bitner, Massacre Lakes

Idaho – Challis

Nevada – Owyhee, Rock Creek, Little Owyhee

Oregon – Beatys Butte, Coyote Lake-Alvord-Tule Springs, Jackies Butte

Wyoming – Divide Basin, White Mountain, Rock Creek, Muscrat Basin, Dishpan Butte, Conant Creek, Antelope Hills, Stewart Creek, Lost Creek, Crooks Mountain, Green Mountain, Little Colorado.



California – Fort Sage, Coppersmith, Buckhorn, Fox Hog, Wall Canyon, Carter Reservoir

Colorado – Sand Wash, Piceance-East Douglas

Nevada – Little Humboldt, Diamond Hills North, Maverick-Medicine, Antelope Valley, Spruce Pequop, Snowstorm Mountains, Black Rock Range East, McGee Mountain, Seven Troughs, Buffalo Hills, Granite Range, Calico Mountains, Warm Springs, Black Rock West, Tobin Range, Flanigan, Clan Alpine, Augusta Mountains, Antelope, Diamond Hills South, Eagle, Pancake, Silver King, Triple B, South Shoshone, New Pass-Ravenswood, Bald Mountain, Callaghan, Rocky Hills, Desatoya, Roberts Mountain, Whistler Mountain, Diamond, Hickison, Fish Creek, Seven Mile, Little Fish Lake, Stone Cabin.

Oregon – Paisley Desert, South Steens, Warm Springs, Riddle Mountain, Kiger, Hog Creek, Cold Springs, Sheepshead-Heath Creek, Sand Springs

Utah – Onaqui Mountain, Range Creek, Tilly Creek.

Wyoming – McCullough Peaks, Lost Creek, Sulphur, Choke Cherry,

In most of the areas listed above, the BLM allocates approximately 80% of available forage to livestock, meaning that cattle and sheep vastly outnumber wild horses. While BLM is prioritizing removal of horses from sage grouse habitat, it states that “no lands will be off limits” to livestock grazing. Further, BLM commits only to “consider” sage grouse conservation goals when grazing permits are up for renewal – something that could be a decade down the road for many grazing allotments.

In the discussion that ensued, humane advocate Tim Harvey questioned why, if sage grouse was endangered, states still have open hunting seasons on the birds.  He also spoke of the severe impacts that the oil and gas industry was having in sagebrush habitat, stating that he recently traveled 150 miles in one day on HMA land in Wyoming and at no point did he see fewer than 4-6 well pads. He also noted that everywhere he traveled, sage grouse apparently were thriving, which, he implied, could be why there is an open season on sage grouse in these areas.

10.  Budget Update – Holle Hooks’, Off-Range Branch Chief, Wild Horse and Burro Program

Hooks presented the 2016 budget in which 70% of funding is expected to be spent on holding horses, while 0% of the budget will be spent on fertility control.


 “What are you going to do when the money runs out?” asked BLM advisory board member Robert Cope, a livestock vet and slaughter proponent.

Hooks had no answer to the question, but she noted that in 2010, the program budget was $40 million, meaning it’s doubled over the last five years. “Throwing more money at the problem without a plan is not the solution,” one board member bemoaned.

Another board member noted that only $151,000 of $80 million is budgeted for population growth suppression tools that BLM has available, namely PZP. “BLM could put a whole lot more effort into using the tools it does have,” the board member observed.

Hooks replied, “Even if we had zero population growth, we’d still have 45,000 animals we need to get rid of.”

11. Advisory Board Discussion/Recommendations

Fred Woehl showed pictures of the Cold Creek horses that were in desperately poor condition due to lack of forage. He postulated that other horses are starving on the range, but never mentioned the BLM’s and FS’ failure to use fertility control on this herd, despite offers from the community (Spring Mountain Alliance) to partner with them.

Tim Harvey noted that the NAS had been critical of the BLM’s Appropriate Management Levels and asked whether the BLM was re-evaluating the AMLs for HMAs. Dean Bolstad shut down this line of questioning quickly – saying “that’s not happening anytime soon.” At another point in the meeting, Bolstad maintained that AML was “just a goal” and suggested that WH&B populations could be brought below the already ridiculously low AMLs if range conditions warranted.

The Resource Committee reported their findings:

·        #1 solution – get back to (low) AML.

·        No time to use population growth suppression.

·        Ban on sale without restriction (slaughter) has BLM’s “hands tied behind its back.”

The Board members then began to talk openly for the first time about what previously had always been the “elephant in the room”—the actual sale for slaughter of our wild horses and burros.

Robert Cope: “If we were dealing with a real wildlife species, we’d harvest them.”

Rick Danvir: “We need to get to AML in ALL HMAs (something that’s never been done in the history of the program) and we need funding and ALL the tools (slaughter) to make it happen.”

John Falen : “Sale authority is the whole key to getting out of this mess. Sale authority is huge. It’s imperative that we go to Washington to pursue this with all the ammunition we have. We have to demonstrate what’s going to happen if we don’t get sale authority on the table.”

Fred Woehl: “We need a recommendation for BLM to use ALL available tools.” It was clear what Fred, who is supposed to represent the public (80% of which is opposed to horse slaughter), was referring to – selling captured mustangs for slaughter.

Julie Weikel: Consider an option for no longer having a restriction on unlimited sale.

The meeting ended with a series of recommendations, that, if implemented, would spell disaster for wild horses and burros. Among them:

-         Manage wild horses like livestock through pasture rotation.

-         Reach low AML number as quickly as possible using ALL effective tools.

-         Bring back to the board 3 alternatives for reaching low AML number – one option should include use of unlimited sale authority and each should include an economic analysis.

After the strident discussion by the Board’s pro-slaughter majority about the need to reinstate the BLM’s ability to sell horses for slaughter, Acting WH&B division chief Bolstad happily stated that this was “a really, really good board meeting.”

“I’ve been to 48 board meetings since 2003, and this was a really, really good meeting.”