27 June 2010
Bureau of Land Management 
Elko District Office
Attn: David Overcast
Tuscarora Field Manager
3900 Idaho Street
Elko, NV 89801
tuscarora_horse_gathers@blm.gov
May 21, 2010
Re: EA# 4700(NVE0200)
Dear Mr. Overcast,
The Cloud Foundation, a 501(c)3 non-profit corporation, on behalf of our thousands of supporters throughout the United States; The Colorado Wild Horse and Burro Coalition; Front Range Equine Rescue; The Equine Welfare Alliance and the over 90 organizations represented thereby, respectfully submit the following comments for your consideration.
In reviewing the Owyhee, Rock Creek, and Little Humboldt Herd Management Areas Gather Plan and Environmental Assessment, I urge you to adopt alternative D (defer gather) in addition to reducing livestock grazing on these three designated Wild Horse Herd Management Areas. The planned roundup of 1,438 wild horses and the removal of 953-1,039 of these animals should be considered and offered for public comment again only after the cancellation of grazing permits and utilization of alternative management practices. It is notable that grazing authorization for over 4,000 head livestock are permitted while only 440 wild horses are allowed. We encourage you to reduce or eliminate livestock grazing on the Owyhee, Rock Creek and Little Humboldt wild horse herd management areas (HMAs) while increasing the “appropriate management levels” (AML) for the federally protected wild horses.
Nationally, the BLM does not include wild horses under one year of age in population counts and it is our understanding that AMLs are for adult horses only. While adult horses are generally defined as those of standard reproductive age, three years and older, BLM typically defines adult horses as those one year and older. When the AML is set for a HMA it is not to include foals. We ask that you remove foals and young horses from the official population count or adjust AMLs upward accordingly.
This EA and Gather Plan fails to adequately consider realistic alternatives to the permanent removal of 1,000 horses from the range. These include options for range improvements such as reseeding, water source enhancement and repair as well as fence removal.
In accounting for the need to remove some 1000 wild horses, you dismiss the idea of reducing livestock grazing as being insufficient. However, the BLM clearly has the authority to implement this alternative pursuant to 43 C.F.R. 4710.5(a), which allows for closure of livestock grazing on areas of public lands “if necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury.”
Further, the 1990 the Government Accountability Office Report underscored that wild horse removals did not significantly improve range conditions. The report pointed to cattle as the culprit as they vastly outnumber horses on BLM-managed public lands. They reported that wild horse removals are not linked to range conditions and mentioned the lack of data provided by BLM.
We are troubled by the fact that damage to fences is given as a reason to remove additional wild horses. Fences should be removed from the HMA and livestock grazing reduced or eliminated. The horses are to be managed as free-roaming wild horses on their legal range. Wild horses will rotate and manage their grazing if allowed the mobility.
It would make more sense to pay the permittees utilizing allotments within the HMA not to graze on the public lands and leave wild horses in greater numbers. Please consider that the removal of a mustang can cost already cash-strapped American taxpayers around $2,000 in short term holding per year if they are not adopted or sold. It is not our wish to harm the livelihood of the longtime residents and ranching families; however, the BLM must transition from managing for extractive uses to managing the land for the good of the public as a whole. In addition to the public lands ranching taking place on these public lands, we would like to receive more information on the oil and gas leasing mentioned for these HMAs and surrounding public lands.
Currently there is a clear lack of balance between livestock and wildlife, including wild horses. It would appear that wild equids are given less than a fair or remotely reasonable share of the public land which was designated by congress principally though not exclusively for their use. Although you state that “Wild horses require more forage supply as they use the forage less efficiently then cattle” you ignore the fact that wild horses utilize a wider range of plants and generally utilize no more forage than cattle. Most scientists and range managers agree that wild horses do no more damage than cattle to public lands and in fact, far less. In fact considerable evidence substantiates the multiple advantages of having wild equids on wild lands in the West.
Across the board the BLM fails to acknowledge the value of wild horses to their native environment. The horse, as a returned native species, fits into an environment from which they were missing for only 7,000 years—the blink of an eye in geologic time. The “green” wild horses should be embraced as part of the eco-system of this wild and beautiful area. Instead, they are marginalized. It is well known that the horse, with its post-gastric digestive system can reseed the range and greatly aid in building nutrient-rich humus, a critical component of healthy soils. The horses break frozen water, allowing pronghorn, deer, smaller mammals and birds to drink. Unlike cattle that ruminate— often near riparian areas where they defecate in the water—the horses keep moving for most of the day and night to assist in digestion.
Given BLM’s current situation of 37,000 some wild horses in holding and a mere 20-25,000 at max left on the range, any proposed roundup must be carefully weighed. It is likely that only a small percentage of the wild horses removed from these HMAs would be adopted into good homes. The rest would be moved to short term holding at a cost of approximately $5.75/day and then to long-term holding facilities in Kansas and Oklahoma at a cost of around $470/year. In the recent opinion rendered by Judge Paul L. Friedman in the Calico Complex case, he stated the “BLM’s relocation of excess horses to those facilities for indefinite holding periods violates the plain language of Section 1339a.” He further stated, “Such a large number of confined horses raises precisely the specter of the ‘zoo-like’ developments whose formation the Act (1971 Wild Horse and Burro Act) was meant to prevent.”
The Judge did not mention the significant costs of the actions of the BLM, which are particularly vexing in these times of government budget deficits and economic uncertainty. It is unconscionable to take more wild horses from their legal, nearly “cost-free” ranges and place them in maxed out holding facilities operating at a cost to American taxpayers of over $110,000 per day. At the same time cattle by the thousands remain on the land, costing the taxpayers a minimum of $123 million a year to prop up a failed public lands grazing program. The taxpayer foots the bill for the welfare cattle and then pays for the welfare wild horses in holding. This is a fiscal train wreck and a disaster for the mustangs, particularly the older horses you contemplate removing from their families and their wild home. Removal of older wild horses should not be allowed given the future they face and the expenditure of taxpayer dollars to remove a horse that may live only a few more years.
Better alternatives exist than this constant cycle of roundup and removal, which stimulates a higher reproductive rate (compensatory reproduction) as the wild horses attempt to fill their ranks and repopulate their range. Although discounted in this EA as inadequate, “natural management” should always be the ultimate goal of your office and any BLM field office. I encourage you to work in coordination with Wyoming Game and Fish to stop issuing hunting permits for mountain lions in the area in order to allow for natural predation on the horse herds. In keeping with the protection of public lands and ecosystems, non-invasive management should be the ultimate goal.
Alternatives A and B include creation of an artificial 60-40 sex ration. We do not support this as skewing the sex ratio to control the population comes with significant social disruption to the herd and would likely result in compensatory reproduction as the herd works to re-establish a socially functional balance of males and females. In the wild, sex ratios usually vary slightly, but average 50% males and 50% females over time. There is a natural reason for this. Wild horses live in family bands with, normally, one band stallion who defends his group of mares from other males. By increasing the number of males and decreasing the females, the fabric of wild horses society will be torn apart. There will be increased competition among the stallions to win and keep a mare; the health of the stallions and mares can decline due to all the excessive fighting and running; more injuries will occur, not only to stallions but to the mares and particularly to foals caught up in the melee. Mares could be raped and passed from stallion to stallion. I saw and filmed this sad scenario in the Marietta Wild Burro Range in Nevada. I observed very few jennies in relation to jacks and one young jenny in heat who was being gang raped by a crowd of jacks. When I asked why there were so many males and so few females, the BLM Wild Horse and Burro specialist replied that “jennies are easier to adopt out.” BLM had intentionally left more jacks and removed the jennies.
If the relatively few number of females are also on infertility drugs, they will be coming into heat monthly during the spring, summer, and fall, They will be bred but will not settle and will come back into heat monthly. They will be eagerly and perhaps brutally fought over and pursued by the over population of males. It is easy to envision an unnaturally violent scenario replacing the relative calm and stability of wild horse society.
We appreciate the accounting of wild fires in this EA and Gather plan, but have the horses’ role as valuable fire suppressors not been considered?
The proposed removal actions contribute to an already broken system and underscore the National BLM’s lack of appreciation for the wishes of the American public who love their wild horses in the wild and want them protected on their home ranges.
Thank you for the opportunity to comment. We would appreciate any feedback to our suggestions and look forward to working with you now and in the future for the preservation of these treasured herds.
Sincerely,
Ginger Kathrens
Volunteer Executive Director
The Cloud Foundation, Inc.
107 S. 7th St
Colorado Springs, CO 80905
719-633-3842
ginger@thecloudfoundation.org
The Equine Welfare Alliance
Front Range Equine Rescue
Colorado Wild Horse and Burro Coalition
