About The Cloud Foundation

The Cloud Foundation, is a Colorado 501(c)3 non-profit corporation, that grew out of Ginger Kathrens' knowledge and fear for not only Cloud's herd but other wild horses in the West. "I began to realize that we were losing America's wild horses," Ginger says. "They are rounded up by the thousand, losing in an instant what they value most--freedom and family. I realized that even Cloud and his family were in danger."

BLM Tres Rios Field Office Attn.: Lindsey Eoff 29211 Highway 184 Dolores, CO 81323 January 13, 2015

Dear Ms. Eoff;

Thank you for the opportunity to offer comments concerning bait trapping for the purpose of managing the Spring Creek Basin Wild Horse Herd.

The Cloud Foundation (TCF) wholeheartedly supports bait trapping in lieu of helicopter drive trapping. Bait trapping, unlike helicopter roundups is a practical, economical and humane way to capture wild horses.

In 2012 we witnessed and filmed bait trapping in the Pryor Mountains of Montana. This method proved to be highly successful and was far safer for the horses. Jared Bybee, the Pryor Mountain Wild Horse specialist, supervised the operation in house. It deviated from the decades long helicopter drive trapping method.

Tricia Hatle in the Cody WY BLM office discussed with us the successful bait trapping operation in the McCullough Peaks HMA. I believe she will be conducting the trapping in house for future operations, with the assistance of volunteers. We are confident that, with your impressive cadre of volunteers, you will be successful in the Spring Creek Basin HMA as well.

On the Pryors, TCF assisted as volunteers in the field darting of selected mares in 2013. Most mares can be approached on foot because wild horses in the Pryors see humans who come to view and photograph them on a regular basis in the non-winter months. For the most part, human visitors are respectful. As a result, the horses view people as neutral elements in their environment. We understand that this is also the case with the Spring Creek Basin Wild Horse Herd.

Our philosophy is that a wild horse is better off not being born than experiencing the distress and danger of removal. When removed from their home, the wild horse loses all they value—their freedom and their families. They run the very real risk of losing their lives as well if they are adopted/purchased by individuals who have no business owning a wild animal. Far too much of our time here at TCF is spent trying to rescue once wild horses from abusive, dangerous situations and placing them in appropriate homes. I have said for a very long time that the safest place for a wild horse and burro is in the wild.

While the Spring Creek Basin wild horse herd is well known and the horses are considered to be outstanding candidates for adoption, the market in general is saturated largely due to massive removals in the past decades. We personally know how difficult it was to find good homes for 45 wild horses removed from the Pryor Mountains in 2012. TCF and our Board Members were responsible for the adoption of 15 of those 45 animals from arguably one of the most famous wild horse herds in America. These 15 might have been added to the over 50,000 animals currently warehoused at taxpayer expense, many in dirt corrals with no shelter.

We support your decision to adopt a plan in which wild horse mares are darted on a selective basis with PZP with the goal of balancing reproduction with natural mortality. We believe that this goal could be achieved in Spring Creek Basin in just a few short years because of your recent far-sighted management decisions.

Concurrently, we encourage you to expand the range for the Spring Creek Basin Herd, at the very least restoring the acreage lost since the range was designated in 1971. The herd could then be allowed to expand to safer numbers, avoiding the inevitable loss of genetic variation.

TCF believes that BLM has the legal responsibility to manage for “self-sustaining” herds in which augmentation from outside herds is not essential to prevent inbreeding.

We believe that a sustainable herd in an expanded herd area should be a goal. A commitment to do so would surely be applauded by the many people who follow the Spring Creek Basin Herd.

Finally, we suggest that mountain lions be protected in the HMA and that BLM work with Colorado Parks and Wildlife to reduce the hunting of the big cats in the area. After all, nature is the true “silver bullet”—a natural environment in which predators like mountain lions are protected to stimulate a natural predator-prey balance. You only mimic nature as best you can with the PZP vaccine, artificially creating a dynamic equilibrium in which predator and prey balance each other out.

If mountain lions are protected and predation rises, BLM can act accordingly, reducing PZP applications on mares. For four years in a row, reproduction and mortality were roughly equal in the Pryor Wild Horse Herd until the previous wild horse managers called in mountain lion hunters from Idaho, thereby unbalancing reproduction and mortality.

A natural balance can happen in Spring Creek Basin, too. Nature can work, if given a fighting chance.

Thanks very much for considering our comments.


Ginger Kathrens Volunteer Executive Director
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