I request that the following comments and recommendations be included in the record and

implemented to minimize the stress and trauma of helicopter roundups on wild horses and/or
burros:
1. Implement humane fertility control programs via remote darting or water/bait trapping whenever
possible in order to reduce the stress caused to the animals. Only AFTER it has been documented
that each of these two methods are not successful should helicopters be considered for use.
2. In addition to improving on-site public observation opportunities, install real-time cameras with GPS
on all helicopters used in roundup operations and live stream the video on the Internet. This will
improve the transparency of roundup operations and enable the Bureau of Land Management (BLM)
and public to monitor the direct impact motorized vehicle usage has on wild horses and the
environment.
3. Install real-time cameras on the trap, the corral and temporary holding pens, again, so that BLM
personnel, public and media can monitor the entire roundup operation and treatment of the
horses/burros. This will facilitate better assessment of the impact of the usage
of motorizedvehicles on wild horses/burros.
4. Restructure contracts with helicopter roundup companies to eliminate per head compensation. The
current structure provides a financial incentive to capture as many horses as possible in the shortest
amount of time in order to maximize profit. Contracts should be restructured to provide incentives for
a slower and less stressful capture.
5. Limit the distance horses/burros may be chased by a helicopter to no more than five (5) miles. At
minimum, the BLMs policy of limiting the helicopter chasing of horses to no more than 10 miles
should be reinstated.
6. Require that the helicopter chase horses/burros at a pace that does not exceed the natural rate
of movement of the slowest animal in the band. Every effort should be made to keep older, sick
and young animals together with their bands as they are moved into the trap.
7. Extend the definition of peak foaling season to March 1st to the end of August and continue the
prohibition on helicopter roundups during peak foaling season.
8. Establish strict parameters for suspending helicopter roundup operations during extreme weather
conditions (i.e. below freezing or above 90 degrees).