Friday, June 3, 2011

In Conclusion

After much reflection and meditation of this five-year journey regarding my research and involvement in the Department of the Interior/Bureau of Land Management’s execution of the Wild Horse and Burro Program, I have reached a decision and am announcing my retirement.

While I will no longer be involved in any new analysis, please continue to read, review and build upon the documents, links and prior postings in American Herds as sources of information, education, history, and interconnected relationships in what appears to be the ongoing perpetuation of a broken, inhumane and fraudulent Program whose criminal activities have been swept under the rug and covered up for decades.

Over this time, I have accumulated a wide variety of environmental assessments, reports and related documents that I hope to periodically upload to American Herds in order to make them available for those who seek to know more of the truth about what has – and is – really occurring behind the scenes of the sound byte propaganda continually regurgitated by industry related enemies of America’s remaining “free” wild horse and burro populations. Please check back occasionally for new material that may be of assistance in learning and knowing more about these issues.

I would also like to deeply thank the untold number of citizens and grass roots activists I have had the distinct honor and pleasure to work with during this time. Your dedication to the well being of our herds, pursuit of the truth, and infinite sacrifices has been truly humbling.

Cindy MacDonald

Saturday, April 2, 2011

Sunday, March 6, 2011

For High Crimes & Misdemeanors

Last week, Vivian Grant, founder and president of International Fund for Horses in conjunction with Michael Blake, screenwriter of "Dances With Wolves" and two-decade long wild horse and burro champion, released a powerful call to citizens and advocates across the country to exercise their Constitutional rights for the sake of our wild horses and burros.

The timing of the call could not have been better as it coincided with the release of BLM Director Bob Abbey's approved "new" Wild Horse and Burro Proposed Strategy; a regurgitated and misleading pack of cow manure that continues to promote an unyielding agenda of spin and bureaucratic "substantiation" for continuation of their crimes.

"I believe crimes are being committed against our wild horses", says Grant. "Crimes that must be prosecuted and the federal officials responsible removed. We are asking Congress to do just that, starting with BLM Director Bob Abbey."

"Article Two, Section 4, of the United States Constitution states that "The President, Vice President, and all Officers of the United States shall be removed from Office on Impeachment for, and Conviction of Treason, Bribery, or other High Crimes and Misdemeanors."

International Fund For Horses then goes a step further by providing citizens and advocates alike an easy-to-follow, step-by-step guide to initiating Impeachment proceedings against BLM Director Abbey.

At a time when the BLM is extending its hand with promises of reform, why should those who are trying to implement change demand the Impeachment of Director Abbey?

I'll tell you why.

BLM has been promising reform and using their bureaucratic weight to generate these kinds of smoke and mirror tactics for decades now while our mustangs and burros have suffered and continue to suffer with no end in sight.

How bad is it?


> After the Wild Free-Roaming Horse and Burro Act was passed to protect America's wild horses and burros from harassment, capture, branding and death, between 1971 and 1980 the BLM allowed over 69,000 animals to be taken off the range by private individuals claiming them as their own.

> In 1986, 20,000 horses went to large-scale adopters and were sold to slaughter or abused as a result of weakened adoption standards, fee waiver programs and sanctuaries used as fronts for commercial exploitation; many of these while still owned by BLM employees.

>In 1992, Michael Blake funded and organized an independent census of wild horses in Nevada conducted by the Public Lands Resource Council. At the time, the BLM was reporting over 33,000 wild horses were on Nevada rangelands but the independent found less than 8,300. The results of the census were dismissed by BLM officials based on the assertion that BLM used a superior method to count the animals via helicopter while the independent census used a fixed wing aircraft. Today, BLM is making "progress" on new census techniques using fixed wing aircrafts.

> In 1992, an investigation by BLMs own law enforcement officials resulted in the accumulation over 3,000 pieces of evidence being compiled about what amounted to little more than a highly organized horse-to-slaughter trade run by the BLM now known as Del Rio. The DOI, Department of Justice and Office of the Inspector General were all implicated in a large-scale cover up at the highest level through a systematic dismantling of a Grand Jury convened to try the DOI for alleged crimes. After the successful shut down of the investigation and trial proceedings, those involved in uncovering the truth about the BLM's Wild Horse and Burro program pleaded with then Attorney General Janet Reno to re-open the case. This request was denied.

> In 1997, Associated Press reporter Martha Mendoza began a series of articles filled with investigative research exposing more corruption within the DOI's BLM, which touched off a firestorm of press about the Program.

>In 1998, a Congressional Field Hearing before the Subcommittee on National Parks and Public lands regarding Range Issues And Problems With The Wild Horse And Burro Act, which current BLM Director Abbey attended, quotes Congressional representative Faleomavaego raising the question: "And is it true that some 32,000 horses cannot be accounted for since we implemented this program?" Mr. Abbey failed to answer the question nor was an investigation ever initiated to determine their fate.

> In efforts to placate public outrage, the National Wild Horse and Burro Advisory Board was re-established after a lengthy hiatus. Predominately stacked with those who had glaring conflict-of-interest, staunch pro-BLM supporters were reappointed time and time again as the list of their recommendations justified each new step in extinction of the herds that continues unabated to this day. Public requests for investigations and removals of Board members were denied.


In March 2000, a Senate Subcommittee on Energy and Natural Resources held a hearing where long-time National Wild Horse and Burro Advisory Board member Larry Johnson submitted a statement in concert with BLM urging support for a mass cleansing campaign of wild horses and burros throughout the West under the "Restoration of Threatened Watersheds" proposal. Wild horses and burros, not livestock, were cited as one of the top three threats to watersheds in the West. The official testimony has since disappeared but was preserved HERE and was instrumental in launching the largest removal campaign of wild horses and burros since the passage of the Act, which is still ongoing today.

> After four years of massive removals, Senator Conrad Burns slips an eleventh hour amendment in an Omnibus Appropriations Act, without public notice or review, which allows the unlimited sale of our American heritage. BLM officially launches the legal sale of wild horses and burros to undisclosed individuals, a practice that continues today. The original language of the For Sale Authority clauses were found in a Nevada strategy document and linked to Nevada Senator Harry Reid. The majority of both advocates and citizens now consider the secret sales of wild horses and burros a legitimate function of the BLM and rarely call for its immediate repeal.

> Over the next decade the BLM continues to remove wild horses and burros at record levels while simultaneously reducing appropriate management levels and accelerating the elimination of habitat without accountability or review. As the costs of warehousing the now captured animals' skyrockets, in 2008 the BLM announces the Program is broke and they no longer have the funding to feed the animals. Euthanasia of tens of thousands of animals is proposed and strategies are developed to kill wild horses and burros en mass and sterilize the remaining herds in documents titled BLM Team Conference Calls and Alternative Management Options.

> In response to the BLM's declaration of considering mass disposal of America's wild horses and burros, Congress orders the Government Accountability Office (GAO) to review of the BLM's Wild Horse and Burro Program and answer questions about the status of the land that has been removed from wild horse and burro use. The GAO comes back with a report that freely admits the majority of the information and data used to compile the report has not been independently verified by the GAO. Instead, the GAO relies on BLM survey data to evaluate the Program and issue their conclusions and recommendations based on BLM personnel responses. With respect to questions surrounding the large scale habitat loss, again the GAO defers answers to BLM instead. After three years, the BLM has still failed to provide a comprehensive overview of the lands status and there has been no independent review as to the accuracy of BLMs summary reports.

> In response to Congressional demands for reform in September 2009, newly appointed Secretary of the Interior Ken Salazar responds with a new initiative a month later. A long-time cattle rancher with strong ties to the oil and gas industry, Salazar presents a vision that utterly fails to challenge the culture of corruption and history of abuse by pushing for so-called reforms that merely continue the trend of decimating America's herds.


> In 2008, U.S. District Judge Collyer rules the DOI/BLM has exceeded its authority by issuing decisions to declare all wild horses in the Colorado based West Douglas Herd Management Area as "excess" and zero the area out. After the ruling, the BLM proceeds to issue a bushel basket full of new Resource Management Plans that continue to eliminate at least 2 million acres of previously designated habitat and schedule the removals every wild horse and burro they can find.

> In September 2009, the BLM launches a roundup of the Pryor Mountain wild horses and The Cloud Foundation is instrumental in catapulting public awareness of the plight of the American mustang and burro into the spotlight. BLM responds to increases in public scrutiny by closing off public lands to conduct their activities and BLM Field Manager Jim Sparks tells the public, "This is not a democracy".

> In December 2009, the BLM signs the decision to launch the largest wild horse removal operation of the year in the Nevada based Calico Complex. The public submits over 10,000 comments with questions about the legality of BLM's environmental review process, discovers recent increases in cattle authorizations and that the BLM buried testimony and data from their own rangeland specialist to justify the removals. A lawsuit is filed by Bill Spriggs on behalf of In Defense of Animals, who argues that long-term holding is illegal. While the judge agrees this is most likely the case, the BLM moves operations on private land to keep the public at bay and almost 1,900 animals are removed before a verdict is rendered; the case loses on a technicality and answers about long term holding are left answered.

> Advocates and citizens attempt to gain access to wild horses removed from Calico and are greeted by a barrage of law enforcement escorts and restrictions. Despite this, over 100 horses are reported as dead as a result of the removals including known miscarriages and aborted foals. Citizen based photos and videos of the reality of roundups gain national media exposure and the BLM begins to scramble to find ways to justify how roundups are humane.

> In June 2010, the BLM hosts a public forum led by hired spin-doctors to sell the Salazar Initiative. This event will culminate in the newly released strategy document referred to above, which coincidentally found three main topics worthy of consideration out of 9,000 public comments, two of which are almost identical to Salazar's new vision.

> In July 2010, the BLM again closes all public lands during the Tuscarora roundup and is greeted by a lawsuit by Laura Leigh and Gordon Cowan demanding public access. After filing a request for an injunction, the BLM suddenly announces the wild horses are dying of thirst and a BLM emergency response team is created to provide testimony to the judge. As a result, the judge rules in favor of the BLM and the horses are removed with little to no independent scrutiny.

> In response to evidence of inhumane treatment and allegations of illegal activities, Congress sends a letter to BLM requesting a moratorium on the roundups and urges the initiation of a study by the National Academy of Science (NAS) to review the Program. Secretary Salazar and BLM Director Bob Abbey ignore the request and the roundups continue. While BLM did agree to a review of the program by NAS, signs are already becoming visible that the study will have strict controls on what it will be allowed to review and just last month, BLM refused to upload the prior NAS studies online for public access. (That's assuming NAS will actually be awarded the contract as it is currently up for Solicitation of Bid and may be awarded to another contractor based on a "viable response".)

> On December 3, 2010, the BLM releases what it hails as an "Independent Observers Report" on the methods and procedures used to remove wild horses from public lands. Questions surface as to the allegiance of the observers and their "independent status" due to long-standing ties to the BLM's National Wild Horse and Burro Advisory Board and pro-horse slaughter industry supporters comprising the team.

> On December 13, 2010, the DOI Office of the Inspector General (OIG) releases a report extolling the virtues of Secretary Salazar's initiative and asserts that roundups are humane and necessary. Though OIG inspections are generally conducted at the request of officials, the OIG reports they initiated the inspection themselves due to public concerns. Evidence of a whitewash surfaces one month later and suggests the large scale cover ups of the 1990's attributed to the DOI's OIG are ongoing. At the same time, a collaborative effort by advocates release an alternative report based largely on BLM published information and data that outlines the potential fraud and abuse of the Program and urges for the Defunding of Roundups through 2012. In response, the BLM ignores the report.

> In January/February 2011, a coalition of advocates document and film multiple abuses of helicopter techniques used to drive wild horses to trapsites in the Antelope Complex in Nevada. ("Antelope Roundup a Disaster for Wild Horses" by The Cloud Foundation, "Pictorial Essay of Obama's Wild Horse Stampede at Antelope Complex" by R.T. Fitch/Straight From The Horses Heart, "Antelope Complex Wild Horse Roundup's Final Days - Heavily Pregnant Mares and More Horse Abuse by Contractor" by Herd Watch/Grass Roots Horse, "Antelope Complex Ends With 1,368 Mustangs Captured" by American Wild Horse Preservation Campaign).

> The BLM reviews the Antelope Complex roundups, contractors, methods and treatment exposed by citizens to address allegations of impropriety. The BLM clears itself and the contractors of any significant wrong-doing.

> Less than a month later, the BLM unveils its new plan and strategy for the future of America's Wild Horses and Burros filled with the same old rhetoric, misleading statements and craftily presented alternative "solutions". Promises of BLM's proposed reforms supported by well-heeled government lackeys ring hollow, both to America's wild horses and burros, as well as within every page of the strategy itself.








Friday, February 18, 2011

Thanks For Listening

Amy Hadden Marsh, publisher and producer of "From Western Colorado", recently aired a radio documentary titled "Wild Horses Caught in the Crossfire" on KDNK Community Radio in Carbondale, Colorado.

Probing one of the most fundamental questions in how America's mustangs and burros are managed, she describes the focus of the documentary as:

"Over the past year, From Western Colorado looked into how the Bureau of Land Management, which oversees most mustangs and burros, counts the herds. The following radio documentary shows that after nearly 40 years, BLM still can't get the numbers right and some believe this could lead mustangs to extinction."

Click Here to listen to what "From Western Colorado" found....

Saturday, January 22, 2011


Last month, Congress received two reports about the Department of Interior (DOI), Bureau of Land Management’s Wild Horse and Burro Program. One report was compiled by advocates and one report was compiled by the Office of the Inspector General’s Office (OIG), Department of the Interior division (yes, that means the DOI/OIG answers to the Secretary of the Interior).

With respect to the advocates report above, I have been told the following information – though must confess – I cannot verify a single bit of it.

Advocates had been in communication with Senator’s aides regarding their concerns about the BLM Wild Horse and Burro Program for well over a month prior to the reports release in early December 2010. The focus of these communications centered around not allocating the BLM any more money for roundups during the appropriations process that funds government budgets.

During this phase of the interaction, they were told by aides that they were very excited about seeing what evidence and proof the advocates could bring to the table and were anticipating its completion.

On December 1, 2010, the report was finally released to Congress and the Senate. Daily phone calls were made for over two weeks, requesting feedback, urging aides to read and verify the information, requesting information and status on the appropriations process, trying to find out information about the Senate Subcommittee on Interior, Environment and Related Agencies, which Senator Feinstein chairs, and getting concrete answers as to when the Subcommittee had reviewed the BLMs Wild Horse and Burro Program’s budget in 2010.

And guess what happened after the Congressional and Senator aides received the report?

Nothing….. The aides fell silent. Phone calls were no longer returned, emails not answered, and nobody could or would answer questions as to why the Senate never even looked at the BLMs WH&B Budget once throughout the entire fiscal year. The few responses that were received all said the same thing, “What does Feinstein’s Office say”? Apparently, Senator Feinstein has been holding the financial keys to the wild horse and burro kingdom and has now become the Pied Piper for the rest of the Senate and staff….

So, with no response from “our representatives”, the report was sent to at least 150 various news agencies and media publications. And guess what happened? Nothing…. Not one media outlet ever responded or even suggested they looked at the information in the report.

DOI/Office of the Inspector General:
Bureau of Land Management, Wild Horse and Burro Program
Report No.: C-IS-BLM-0018-2010

On December 13, 2010, the OIG released their report on the BLM Wild Horse & Burro Program. While the public will now find the OIG report plastered on every BLM website hailing its “findings” about the Wild Horse and Burro Program, which support in every possible instance both BLMs actions and overwhelming support for Secretary Salazar’s new initiative to decimate America’s herds, what the DOI won’t be telling the public about is what happened before the release of their final report.

The information posted below is an effort to increase transparency about what occurred behind the scenes of the OIG report. Granted, the information is very limited and should be considered a starting point towards an investigation to uncover the truth, if such an animal even exists in the halls of D.C. anymore.

It contains direct copies of emails received by me from the OIG during the time of their Inspection as well as personal notes regarding phone calls, information received second hand from others also involved during this process as well as some of my own comments and/or conclusions about what it all may mean.

So without further ado, let the stripping of the whitewash begin…..

On February 9, 2010, I was contacted by a group of advocates and concerned citizens wanting my help in assembling a case to submit to the OIG’s office regarding the ongoing abuse and corruption occurring by the DOI in relation to the Wild Horse and Burro Program and multiple-use.

This group stated that they had met with Senator Feinstein’s office in San Francisco and had a meeting with her head aide in California, James Molinari. They relayed that Mr. Molinari said “that the office would facilitate a query to the Office of the Inspector General” and “They agreed to help us with this”, and finally, “We are invited to submit a list of questions and concerns and products of research to support an investigation.”

I never saw any official communication from Feinstein’s office nor from Mr. Molinari that verified these statements were true. However, I have no reason to believe that those involved in this request fabricated it out of thin air. As a result, I sent a long list of information, links and documents to be forwarded to those coordinating this effort. I never received a concrete follow up from any of those within this group as to what they did with it, what response was received by Feinstein’s office, if any, or how this effort eventually ended.

In August, 2010, an advocate unrelated to the original group relayed to me that they had heard Feinstein’s Office had requested the OIG investigation. As a result, they asked James Molinari if this was true and Mr. Molinari denied Feinstein’s office had requested an OIG investigation.

On June 21, 2010, I filed a complaint with the Federal Bureau of Investigation (FBI) regarding all the complexities surrounding the Calico Complex wild horse removals. The focus of the complaint centered around reports that the BLM had removed approximately 400-500 more wild horses than they were authorized to remove and were now illegally auctioning off non-excess animals. I equated this with the unauthorized stealing of public property.

During my interview with the FBI, I was asked why I was submitting the complaint to the FBI instead of DOI law enforcement officers. To this, I responded, “Because the DOI has historically shown they are incapable of policing themselves and an outside, independent investigation needs to be conducted.”

I never heard from the FBI again, even though I sent a follow up request inquiring about the status of my complaint.

The following is the complete series of email correspondence between myself and Loralee Bennett, Deputy Regional Audit Manager, Department of the Interior, Office of the Inspector General.

JULY 28, 2010
I began communication with Loralee Bennett at the DOI Office of the Inspector General due to an email she initiated as a result of filing a complaint with the FBI. The following is Ms. Bennett’s correspondence.

Sent: Wednesday, July 28, 2010 10:42 AM
Subject: Inspection of Bureau of Land Management’s Wild Horse and Burro Program

Ms. MacDonald,

You filed complaints with the Federal Bureau of Investigations on the Bureau of Land Management's Wild Horse and Burro Program on June 21, 2010.

Based on a Congressional Request, we opened an Inspection of that program on May 25, 2010. As a result, your complaint was forwarded to me for review as part of our overall Inspection. To get a better understanding of your concerns, we would like to set up a time to talk with you. In addition, we're interested in obtaining any additional information, documents, studies, etc. that you'd like us to take into consideration as we conduct our Inspection.

I've included all my contact information below and I look forward to hearing from you.

Thank You
Loralee Bennett
Deputy Regional Audit Manager
DOI / OIG Central Region
134 Union Blvd, Suite 510
Lakewood CO 80228
Voice: (303) 236-924x
Direct: (303) 236-913x
Mobile: (505) 249-151x
Fax: (303) 236-821x

JULY 29, 2010
I sent Ms. Bennett the following unedited response:

Sent: Thursday, July 29, 2010 11:23 AM
Subject: Re: Inspection of Bureau of Land Management’s Wild Horse and Burro Program

Dear Loralee-

Thank you for contacting me regarding my concerns about the BLM Wild Horse & Burro Program and I appreciate the opportunity to share them with the Office of the Inspector General.

Regarding scheduling a time when we can discuss these issues, I will make myself available any day next week, beginning Monday, August 2, 2010, from 12:00 p.m. p.s.t. through 3:00 p.m. p.s.t. Please pick a time that is equally convenient for you during this time frame and I will confirm.

With respect to submitting additional documents, studies, data, etc., I have a vast amount of information I could potentially share with the OIG, so much so that I am concerned it could overwhelm you and/or your staff.

Consequently, in order to best streamline our efforts and time, perhaps you could better define the purpose of the Inspection and what types of information you are seeking to help me narrow the scope of your interests.

Also, I have a specific concern I would like you to address prior to any submissions, just so I am very clear as to what happens and the resulting status of any information submitted to the OIG.

Based on my understanding of what happened last time the OIG was involved in an Inspection of the WH&B Program, the DOI/BLM was able to use the OIG Inspection as a blanket reason to withhold information from the public about their activities, evoking some sort of clause about not being able to disclose information until the investigation was complete.

For the record, I have seen no evidence of the DOI/BLM doing this so far.

However, I am working on a variety of issues affecting wild horses and burros and do not wish to compromise my ability to obtain additional information due to “partial” submissions to the OIG that could possibly result in an informational “lockdown” by DOI/BLM.

Therefore, please address the issue of potential impacts, if any, of submitting information, data, documents, etc. to the OIG and either confirm or deny the possibility that the DOI/BLM may be able to use your Inspection of a particular subject as reason to withhold information from the public about their activities until the Inspection is complete.

Finally, I would like to know the current deadline for submitting information and the approximate time frame the OIG is projecting they will release the results of the Inspection.

The relevance of this question is, I was also involved in submitting information during the GAO inquiry in 2008. During the GAO process, they stopped accepting any additional input around May and spent the next three months preparing their report.

Having a sense of how much information the OIG can absorb and sincerely review will give me a better idea of what to submit so as not to waste our time.

For now, I have attached a few items for your review and consideration.

Thank you again for contacting me and am looking forward to talking with you.

Cindy MacDonald

AUGUST 3, 2010
Loralee sent the following unedited response. It was no longer addressed to me personally as two other advocates were now included in the correspondence, nor did she ever again reference speaking with me personally about my concerns that initiated the FBI complaint or address any of the questions I had posed above.

Sent: Tuesday, August 3, 2010 7:48 PM
Subject: OIG Meeting on Wild Horse and Burro Program

The OIG has scheduled a meeting to hear concerns about BLM's Wild Horse and Burro Program and to obtain copies of any documents, studies, pictures, or other supporting documentation that individual's would like to share. The meeting is scheduled for:

August 23, 2010
from 10am -1pm

Belmar Library
555 S Allison Parkway
Lakewood City Commons
Lakewood CO 80226

If you have any questions, please let me know.

Loralee Bennett
Deputy Regional Audit Manager
DOI / OIG Central Region
134 Union Blvd, Suite 510
Lakewood CO 80228
Voice: (303) 236-924x
Direct: (303) 236-913x
Mobile: (505) 249-151x
Fax: (303) 236-8211

AUGUST 3, 2010
I immediately responded to Ms. Bennett’s newest email by sending the following:

Sent: Tuesday, August 3, 2010 7:56 PM
Subject: Re: OIG Meeting on Wild Horse and Burro Program

Dear Loralee-

Does this mean that you are no longer interested in setting up a time to talk with me about my concerns – unless I can fly to Colorado to meet you personally?

Cindy MacDonald

AUGUST 17, 2010
The next correspondence received by Ms. Bennett now included a handful of additional individuals and various organizations known to be involved in wild horse and burro advocacy and/or issues.

Sent: Tuesday, August 17, 2010 7:13 AM
Subject: Inspection of BLM’s Wild Horse and Burro Program – and Meeting Cancellation

First ...
Michael Golembeski of the WindDancer Foundation provided me with each of your e-mail addresses and requested that I contact each of you related to our ongoing inspection of BLM's Wild Horse and Burro Program. I know I have e-mailed many of you, and spoken with a few of you on the phone, about concerns that you have with the Program (and I do have 3 phone messages I need to return). However, for some of you, this may be the first time you've heard from me so let me give you a little background. Based on an e-mail from a Senator's staffer and pending legislation, our IG decided to implement an inspection of BLM's Wild Horse and Burro Program. We are looking at every phase of the Program as it currently operates (visiting HMAs, attending gathers and adoption events, visiting both short term facilities and long term pastures, etc.) as well as evaluating the "studies," "science," and "other" support behind its current policies and procedures. While we are both (1) talking with BLM and reviewing the documentation, studies, etc. that it has and (2) performing as much independent research as possible, we want to be as fair, objective, and inclusive as possible. Therefore, we are also interested in hearing from each of you about any studies, research reports, scientific papers, etc. that you're aware of that provide insight into either how BLM currently operates - or how you think BLM should operate - the Program. We would also be interested in any suggestions you might have about improving the Program. Any such information and/or recommendations you'd like OIG to review and/or consider can be e-mailed to me at the address below.

Second ...
Unfortunately, we need to cancel the meeting we had scheduled in Denver CO for August 23. Despite being forced to cancel the meeting, we are VERY interested in your perspectives and in reviewing any documentation, studies, etc. that you have to ensure that we have the most complete and accurate picture of the Program as possible. We need to cancel the meeting because, as we enter the end of the fiscal year and face a possible continuing resolution, several competing priorities have arisen that have required us to take a serious look at what work can and cannot be completed on numerous ongoing reviews. Our priority on this Inspection is to attend as many gathers and visit as many holding facilities as possible in the time we have remaining to complete this inspection. Additionally, these competing priorities have required me to be in Washington DC extensively over the last several weeks (hence the reason I owe 3 of you return phone calls). I had thought I'd be back in Denver the week of August 23rd but, these trips to Washington DC are expected to be required until at least mid-September. Therefore, unfortunately, we have no one available to conduct a meeting before our report is scheduled to be completed.

Thank you in advance for any information you can provide that will help us ensure this report is the most complete and accurate assessment of the Program possible. Given my extensive travel schedule and multiple priorities, it is often difficult to contact me on the phone. Therefore, the best way to contact me is via e-mail. Each day (sometimes not until mid-night but ...) I do my best to get through all the e-mails I received that day - something I can't always do with phone messages.

Loralee Bennett
Deputy Regional Audit Manager
DOI / OIG Central Region
134 Union Blvd, Suite 510
Lakewood CO 80228
Voice: (303) 236-924x
Direct: (303) 236-913x
Mobile: (505) 249-151x
Fax: (303) 236-8211

AUGUST 19, 2010
I responded to Ms. Bennett’s email with the following:

Sent: Thursday, August 19, 2010 6:44 AM
Subject: Re: Inspection of BLM’s Wild Horse and Burro Program – and Meeting Cancellation

Dear Loralee-

Thank you for this additional info and update.

Based on the information you have provided, I feel compelled to ask:

How is it that the IG is expected to perform a thorough review of the complex and long standing issues concerning the Wild Horse & Burro Program when it is obviously understaffed and given too short of a deadline to accommodate a serious and in-depth investigation? Or is that perhaps the plan - to prevent an in-depth investigation from occurring?

In my last email communication, I had asked you to address the issue of "the scope" of what the IG was mandated to review so that I would not inundate you with information that fell outside the parameters of the investigation.

However, since this response seems to cover "everything", then that is what I will submit.

I apologize in advance if these submissions may prove to be a bit overwhelming - but I have been studying this Program, day and night, for over four years now and have accumulated quite a bit of information that may have relevance.

I will also try to organize them as best as possible but due to the sheer volume of documents I would like to submit, some may come in rather rag tag due to time constraints.

Cindy MacDonald

From this point on, I submitted multiple documents, links, reports and information to Ms. Bennett totaling nineteen emails beginning on August 19th through 31st, 2010. A complete list of what I sent the OIG is included at the bottom of this post.

AUGUST 20, 2010
I received a "group" email from an advocate who introduced herself as Susan addressed to myself and others involved in wild horse and burro issues. Susan alerted us to the fact that the OIG was conducting an Inspection of the WH&B Program. The following quotes received during her alert have been edited for relevance.

I have learned today that the OIG is preparing another investigation into the issue of inhumane handling by BLM, but they must amass a body of evidence---video, photos, testimony of observers, etc. and this must be submitted ASAP. They want the report ready for Sept. Mr Kris Kolesnik, associate inpector general for External Affairs, is the man I spoke with. He said no one has to have any 'professional' standing i.e. be a vet or official, just have personal or photographic documentation”.

Please, any of you I am writing, send whatever you have for conducting this expose' on BLM's lack of humane treatment. I am just a interested horse advocate, but I know the damning lack of scientific data to back up their claims and the exposure of their methods of handling are the weak spots to attack”.

Mr Kolesnik is doing a lot of stuff with the Gulf Oil spill indictment, too… This is the contact man.”

Because of this information, I also forwarded each email sent to Loralee about the Wild Horse and Burro Program to Kris Kolesnick as well. I also followed up by calling Loralee to ask for confirmation as to whether another Inspection had been initiated merely to focus on the gathers and humane treatment or if this was the same investigation that had been opened on May 25, 2010. I left a voice message and requested either a return phone call or an email to answer this question. I received no response.

Throughout this process, Michael Golembeski of the Wind Dancer Foundation and I communicated rather frequently about progress, questions and information related to the OIG Inspection. According to Michael, Deputy Bennett and he communicated quite regularly as well. He relayed to me around the end of August, early September that the OIG was in the process of completing their report and it was expected to be released before the end of the fiscal year, which would be on or before September 30, 2010. Michael’s information matched what Susan had said; the OIG intended for their report to be ready by September.

As a result, I saw no further reason to send the OIG any additional information as, Loralee had already stated on August 17th that, “Our priority on this Inspection is to attend as many gathers and visit as many holding facilities as possible in the time we have remaining to complete this inspection.”

What these two pieces of information said to me was,
a) no matter what I had sent, the OIG didn’t have any time to review the information anyway so it was just a waste of time on my end and,
b) they were going to spend their remaining time in the field and not actually auditing the Program.

I saw Ms. Bennett’s request for information as outlined in her last email - despite admitting they would not make its review a priority - as just a way for the DOI to get the advocates attention away from more meaningful work and to see what advocates might be holding in terms of information that the DOI could develop a counter strategy too.

According to Michael, in the last phone communication he had with Deputy Bennett, she relayed that the OIG had begun to review the BLMs new Wild Horse and Burro Policy Manual and had run into some problems. What they were, she didn’t say. From this point on, Loralee became inaccessible and never returned his phone calls or emails again.

Throughout September, Michael checked the OIG website and each day, no report was posted. As we now know, it wouldn’t be released for over two more months – just days before Congress and the Senate were to vote on the BLMs Wild Horse and Burro Program’s budget and whether they were going to give Salazar millions to purchase private lands for the Salazoos.

SEPTEMBER 29, 2010
This was the last and final communication from Ms. Bennnett, which included Michael, one other advocate and three individuals with email addresses. It stated:

Sent: September 29, 2010 1:08 PM
Subject: Wild Horse and Burro Program Inspection

With all the additional work associated with the Special Assignments put on my desk, management of the Wild Horse and Burro Program Inspection has been transferred from Central Region to our Western Region Office. Therefore, any questions on the Wild Horse and Burro Program Inspection should be directed to either the Western Region Regional Manager (Mike Colombo) or the Western Region Deputy Regional Manager (Chuck Wiebe). The number at the Western Region is (916) 978-565x.

Loralee Bennett
HQ Operations, Special Assignments

From here, Michael reported he contacted the Western Region Office personnel provided by Loralee’s email. While I cannot verify this personally, Michael relayed to me that his contact with them was greeted by both surprise and criticism as they stated he was not to contact an OIG inspector directly. The Western Region then referred him to a Public Affairs Specialist in Washington D.C., to which all future public communication would be funneled.

When Michael asked why the Inspection had suddenly been transferred to the Western Region, the response was something to the effect of, “The Inspection was always being conducted by the Western Region and Loralee was just a point of contact.” As to Michael’s concerns that everything formerly sent to Ms. Bennett was also included in the Western Region Office Inspection, he was assured all information had been received and would be considered.

On December 13, 2010, the DOI/OIG publicly released their long awaited report. Instead of following the general outline described by Deputy Bennett in prior communications, which was to include all phases of the Wild Horse and Burro Program, what the pubic got was an official propaganda piece extolling the virtues of Salazar’s new Program and the parroting of an overpopulation problem that continues to be unsupported by the BLM’s own records and statistics.

According to the OIG, in the first page of their report titled, “Memorandum” and addressed to BLM Director Bob Abbey, the OIG’s “objective was to determine if wild horse and burro gathers are necessary and justified, and if wild horses and burros are being mistreated.”

The “objective” now seemed a far cry from what its original purpose was as previously outline by former lead, Deputy Regional Audit Manager Loralee Bennett, whose last communication now sported a new title of “Head Quarters, Special Assignments”.

JANUARY 18, 2011
So in efforts to try and nail down a definitive answer to these two conflicting stories, I submitted a Freedom of Information Act Request (FOIA) to the DOI OIG requesting the source document of who initiated the Inspection.

Sent: Tuesday, January 18, 2011 08:36 PM
Subject: FOIA Request

Dear FOIA Officer:

This is a FOIA request for information related to the Office of the Inspector General, U.S.Department of Interior, Bureau of Land Management, Wild Horse and Burro Program,Report No.: C-IS-BLM-0018-2010, released December 2010.

The specific request is limited to only include the document(s) or email communication(s) identifying the source of who officially requested an investigation be initiated into the BLM WH&B Program, including the date of submission, as well as their description of the parameters to be covered in the investigation.

This request is being submitted by:
Cindy MacDonald (personal information has been deleted)

Due to the limited size of the request, most likely spanning merely one or two documents and/or emails, it is believed this request will fall within the fee waiver parameters. However, if not, the fee I am willing to pay is up to $30.00 dollars.

Also, I would prefer this request be provided in electronic format but will accept any format that is compatible with supplying the requested information.

Upon receipt of this FOIA request, please provide a FOIA response number to the email address listed above.

If you have any questions or issues you'd like to discuss, please feel free to contact me at any of the above provided contact information.

Thank you.

Cindy MacDonald

JANUARY 19, 2011
The next day, the following response was received by the DOI/OIG FOIA Office….

Sent: Wednesday, January 19, 2011 7:32 AM
Subject: FOIA Request

Good Morning Ms. MacDonald,

I have received your FOIA request in which you state you are seeking a "specific request is limited to only include the document(s) or email communication(s) identifying the source of who officially requested an investigation be initiated into the BLM WH&B Program, including the date of submission, as well as their description of the parameters to be covered in the investigation." Normally with an investigative report there is a specific complainant that we use to justify an investigation, this particular report happens to be an audit report which was a general response to public outcry. Therefore there isn't a specific event, for example a singular letter, phone call, or e-mail that started this process.

If there is anything else I can help you with please do not hesitate to contact me. For your convenience the link below will bring you to our electronic copy of the audit report you seek.

Thank you,
Patrick L. O'Boyle
Program Analyst
Office of Inspector General
Department of the Interior
(703) 487-544x

So there it is.

According to Loralee’s first email communication, the Inspection was initiated based on a Congressional request. She further added at a later time that the Inspection was, “based on a Senator’s staffers email”.

Was that staffer James Molinari of Senator Feinstein’s Office? Senator Feinstein was the Chair of the Subcommittee responsible for overseeing the BLM WH&B Program and budget allocations, so it seems logical to me that she has a direct interest in obtaining a review by the OIG. And maybe that would explain why she never brought the budget issues of the WH&B Program to the floor once for discussion throughout 2010 - because she was waiting for its results first.

But Mr. Molinari denied Senator Feinstein’s Office initiated the investigation. So who WAS the Senator’s staffer that requested this Inspection Deputy Bennett referenced?

But now, it would appear that the DOI/OIG FOIA Office is denying the existence of either a Congressional request or a staffers email, claiming this was their own idea, a response to “public outcry”, and finally, that the parameters of the Inspection were only limited to the necessity of roundups and humane treatment.

Well, based on what limited evidence I have seen, here is what I think the evidence points too.

James Molinari DID submit a query to the OIG as indicated by the group of advocates in February 2010. This resulted in an Inspection being officially opened in May that Loralee attempted to revolve around the parameters she originally outlined; the whole WH&B Program was on the table for review.

As information began coming in, Interior Secretary Salazar and various high ranking officials began blocking the Inspection, piling on additional workloads on Loralee in efforts to bury her, began manipulating the Inspection from behind the scenes and finally, took it out of her hands completely and transferred it to the more “friendly” Western Region. Here the process began of doctoring the OIG report to read like a Salazoo advertisement now officiated by “expert review".

Why would James Molinari deny the Inspection was initiated by Feinstein? Well, maybe one of those famous Congressional deals was struck at the back of the House. Salazar gives Feinstein what she wants and Feinstein turns her head regarding both the budget and the OIG Report. There is currently a lot of DOI related proposals on the table in California….

Perhaps it even went so far as a calculated strategy that always intended to assemble an official story strongly supporting the Salazar’s Initiative that would be strategically released just days before Congress and the Senate was to vote on the 2011 Budget. No time for advocates to counter that, right? And once BLM gets their money – no strings attached - well, sorry folks, but the roundups will still continue…

Did this really happen? Did a conspiracy occur behind the scenes of this report to whitewash the truth, tamper with the Inspection and prevent a real audit of the Wild Horse and Burro Program? Go back and read these emails again and you tell me what YOU think happened here.

Is this enough evidence to indicate an investigation should be opened regarding the DOI/OIG’s handling of this affair? And if so, who investigates the investigators?

Submitted to the DOI Office of the Inspector General
Documents, Links and Information

July 29, 2010
America's Mustangs and Burros: Summary: Alternative Populations Overview-Revised
The Wild Horses of Wyoming: A Tale of Tallies
The Jackson Mountains Wild Horses: A Case Study In The Mismangement of the BLM's Wild Horse & Burro Program

August 19, 2010
WH&B Capture Status Report
Facility Codes – Updated 10/15/07
Article: Dead of Winter
PEER: Horses to Slaughter – Anatomy of a Cover Up
America’s Mustangs and Burros: Appendix III
America’s Mustangs and Burros: Inflated Populations – Update 2004-2009
Article: Horse Rustlers: How Scam Artists Abuse a Federal Adoption Program for Wild Horses
Gold Butte Field Trip 2001
Gold Butte Key Monitoring Sites (KMS) Summary Photo Doc. 2007
2006 Gold Butte Capture Status Report – Draft
2007 Gold Butte Capture Status Report – Draft
Gold Butte Post-Gather Report 2007
Dr. Russ Mason, Chief Game Specialist, Nevada Department of Wildlife 6/04/08
Bob Ross, BLM Las Vegas Field Manager, Public Scoping Concerns, 5/05/10
NPS/BLM MOU: Lake Mead NRA 2005
Gold Butte Herd Management Area Plan (HMAP) Preliminary 2008
Gold Butte Census History 2005-2007
Lake Mead Complex Final Gather Environmental Assessment NV-052-2007-69, March 2007
BLM Post-Gather Report, March 2007
OIG: Burros II - Muddy Mountains HMA Document
Letter from California Senator Feinstein, 9/20/05
Threats to Desert Tortoise Populations: A Critical Review of the Literature, USGS, 2005
Clark Mountain Herd Management Area/Herd Area, Decision Record and Finding of No Significant Impact (FONSI) for the Clark Mountain Herd Areas Burro Removal, Fiscal Years 2007-2012, CA-690-EA04-27
Wild Burros of the American West: A Critical Analysis of the National Status of Wild Burros on Public Lands – 2006
Director Pool-First Letter, Clark Burro Response, 5/31/07
Protest Letter to BLM California State Director, 6/16/07
Director Pool-2nd Ltr, Denial of Analysis, 7/10/07
BLM State Wild Horse and Burro Lead Amy Dumas, Clark Mountain Burro Population, 6/01/09
Statement of Range Conditions: Ivanpah Valley, Laura Cunningham, 8/25/09

August 20, 2010
Map of August 2008 Caliente Field Office “Emergency Wild Horse Gather”
Wild Horse Herd Management Areas in the BLMs Ely District
Acreage Comparisons Prior To The New 2008 Resource Management Plan (RMP)
Wild Horse Herd Management Areas in BLMs Ely District Prior To The New 2008 Resource Management Plan (RMP)
Ely Districts New 2008 Wild Horse Herd Management Areas
Letter From BLM Nevada State Director Ron Wenker, June 13, 2007
Wild Horse Herd Management Areas in BLMs Ely District Prior To The New 2008 Resource Management Plan (RMP): Livestock Allotments
2005/2007 Ely District Wilson Creek: Grazing Allotment Key Numbers Legend, Pastures and Authorized Use
Interior Board of Land Appeal (IBLA) 172 IBLA 128
Protest Letter Submitted to BLM Re: Ely Resource Management Plan, December 29, 2007
Ely Protest_Supplemental_5-15-08
Dunn_RMP Interested Party List_2-22-07 (Email Communication)
Ely Response_Ben Noyes_No HMA Legal Description_1-13-08
Request for Documentation_BLM Director Abbey_9-29-09
Ely_FLMPA_BLM Response Lt_12-16-09

August 21, 2010
BLM California National Herd Statistics Fiscal Year 2004
BLM Surprise Field Office: Massacre Lakes Rangeland Health Assessment (RHA) 2010
Massacre Lakes Monitoring Evaluation Report 4/6/10
BLM California WH&B Lead Amy Dumas Email Comm. 8/04/09
CO_Sand Wash Gather_BLM Article_11-05
Sheepherder Springs Grazing Allotment_11-05-08

August 23, 2010
Solicitation of Opinion_NWHBAB_Use of Helicopters
NWH&BAB-Board Recommendations-7-25-07
WHB Planning & Strategy_CRM_PC_7-29-10
SOWH Point paper-1
AHDF_Salazar Plan_Pro-Con_10-21-09

August 27, 2010
Article: BLMs National Adoption Day (with Supporting Comments)
Article: Doing Everything We Can
Article: Serious Concerns
Article: BLM Budgets
Article: No Animal Police For Them
America's Mustangs & Burros: What's Left, The High Cost of Miscalculating and Will They Survive? Part II, Financial I. pg. 35.
Nevada Commission for the Preservation of Wild Horses, April 7, 2005 Meeting Minutes.

August 28, 2010
Article: For Everything Else
Article: The Thriving Natural Ecological Balance
The Thriving Natural Ecological Balance Report
Elk Management in 5 Western States (Montana, Wyoming, Idaho, Colorado, and Utah)
Nevada's Mule Deer, Population Dynamics: Issues and Influences by Tony Wasley
Nevada's Pronghorn Antelope: Ecology, Management and Conservation by George K. Tsukamoto 1983, First Revision Edited
NOTE: The 1999 Lincoln County Elk Management Plan is too big of a file to provide via email.

August 31, 2010
Article: Buried, American Herds, posted
BLM Winnemucca Wild Horse & Burro Specialist Glenna Eckle Court Testimony
BLMs Response to 1994 Protests of SMA FMUD
Article: Calico: Past, Present and Future. Part I-The Past
Article: Calico: Past, Present and Future. Part II
Public_Calico Complex_Request For Stay_12-18-0
IBLA Stay Granted To BLM_CM_TCF_1-13-10
RS_Motion To Dismiss_IBLA_2010-46_1-13-10
Appellant Response_Standing-Separate Appeal_1-22-1
IBLA_Calico Complex_Final Ruling_2-04-10
NC_Soldier Meadows Allotment_Proposed Decision_7-11-07
Soldier Meadows_FONSI_1-14-08
Article: Calico: Past, Present and Future. Part V
Article: On Da Take
Draft Ruby Pipeline Migratory Bird Conservation Plan
Confidential Draft: Greater Hart-Sheldon Conservation Fund Agreement