Bureau of Land Management, Ely District Office
HC 33 Box 33500,
Ely, NV 89301-9408
Attn: District Manager, & Wild Horse Specialists:
Jared Bybee & Ben Noyes
RE: Wilson Creek Complex: Wild Horse Gather Plan and
Preliminary Environmental Assessment, Ely No.
NV-040-06-047

Dear Sirs:

Thank you for sending the Environment Assessment for the Wilson Creek Complex. Unfortunately your proposal would perpetrate a terrible injustice against the wild horses in their legal herd areas and I urge you to redo the proposal or to adopt the No Action alternative.

Do you really mean to tell us that the current population of 900 wild horses is an overpopulation in
legal Herd Management Areas (HMA’s) totalling 796,932 acres? This works out to about 900 acres per wild horse at present. This is hardly an overcrowded or overpopulated situation provided the wild horses enjoy their fair share of the water, forage, shelter, and other habitat resources here within their legal herd areas.

Yet, you remain silent on the crucial (and legally required?) point of the other utilizers of resources within the wild horses’ legal herd areas, especially the domestic livestock, cattle and sheep. Their relative proportions translated into forage usage (AUM’s) within the legal herd areas of the wild horses
(in this case Wilson Creek HMA containing 687,215 acres and Deer Lodge Canyon HMA containing 109,717 acres) should be clearly spelled out in order to give the public a much needed (and required) perspective. Can we be provided with this information?

The Appropriate Management Levels for the above two HMA’s which are areas already considerably reduced from their original 1971 legal Herd Areas (HA’s) (though by how much we do not know. – Can we be provided with this information?) – are (1) “not to exceed 160" for Wilson Creek HMA, which at most works out to 4,295 acres per individual wild horse and (2) 30-50 for Deer Lodge Canyon HMA, which works out at between 3,657 & 2,194 acres per horse.

Something is clearly wrong with these very lopsided allocations for wild horses within their vast legal
herd and herd management areas; and we would like to take this opportunity to strongly protest this gross injustice both to the wild horses in the wild and the thousands of Americans who support them in their free and natural state! It is apparent to me that one local public lands rancher receives more consideration from BLM than literally hundreds of thousands of U.S. citizens who want to see the wild horses treated fairly. They want to see the wild horse enjoying the use of their fair share of the resources within their own legal areas as established under P.L. 92-195, the Wild Free-Roaming Horse and Burro Act.

For the above and following reasons, we ask you to redo the Wilson Creek Complex Wild Horse Capture Plan and Preliminary E.A., so as to provide for a much greater number of wild horses, one that truly fits their vast legal herd area.

As our nation’s public servants, you are bound to uphold all the laws of the land and to treat fairly all the values, uses, interests, and presences in an equitable fashion that does not side with certain vested interests such as livestock and game hunters who would monopolize the public lands and their resources for their own ends.

You should leave the ca. 900 wild horses in this area and work at securing adequate habitat requirements for at least this small number, small for such a vast area. Then you should work at so managing the wild horse herd areas by judicious use of natural and, where necessary, artificial barriers, so as to allow the wild horse population here to self stabilize in balance with available resources.

As a “climax” species, the wild horse is capable of this, given density dependent controls which come increasingly into play as its ecological niche is filled. Then the true intent of the Wild Horse Act would be more truly realized and the returned North American native wild horses would prove themselves to be positive restorers and enhancers of the native North American ecosystem rather than the misfits that their detractors portray them as.

The following are specific comments with page references:

P. 2: Wild Horse Gather Plan slated for February., 2007. ... Fertility control could be applied to returned mares – we object! This is really setting the population up for die out considering the outrageously low AML’s (Appropriate Management Levels) for such vast legal areas. Please exposit relative proportions in terms of resource use by livestock, big game and wild horse herbivores as occurs within the legal herd areas and hma’s of the wild horses and give the size and a precise map of the original 1971 and still legal wild horse Herd Areas.

P. 3: Thank you for the map, though we would prefer a larger one. Details are too fine.

P. 4: Top: Livestock are clearly monopolizing the wild horses’ legal areas. A. Need for Proposed Action: To say wild horses are “overpopulated” appears to be a ridiculous assertion. Cattle and big game are being favored over wild horses in spite of the Wild Horse Act’s stipulation that wild horses shall be the “principal” presence within their legal herd areas. This is far from being the case!

P. 5: top: BLM gives the impression it is caving into local and state game hunter interests. The quotation from the Wild Horse Act concerning overpopulation is wrongly applied, since there is no proven overpopulation of wild horses within their vast legal area of the Wilson Creek Complex. It’s just that people in authority are allocating the resources to which wild horses are entitled to livestock and big game contrary to the law.

Bottom: Proposed Action: BLM to capture 775 wild horses leaving 125. How is the wild horse-interested public assured that even this very low 125 will not become a mere paper figure, and that even fewer will actually be left? ... A certain small portion of the horses will be released, particularly ages 6-15 years, and over 16 years. The released mares will be injected with PZP experimental fertility control drug. This is really undermining the wild horses “thriving natural state” though you make it sound like it is all the opposite – and we strongly object. ...Spanish Barb types will be released. Again this is artificial selection taking precedence over natural selection.

P. 6: 125-190 wild horses would remain in the Wilson Creek WH HMA’s Complex after the roundup. – This works out to between 6,375 and 4,194 acres per wild horse, an outrageously lopsided treatment of the wil horses here in their legal HMA’s and on top of BLM’s already having considerably reduced the original wild horse HA’s to HMA’s. It is clear that you are reducing the wild horses to mere token and non-viabl levels. This is a great injustice!

P. 7: Top: 20% increase seems exaggerated. But when you fail to allow the wild horse population to fill its niche in its legal herd area, then naturally it keeps trying to do so rather than reaching equilibrium, which it would at a higher population level, given natural barriers.

Bottom: Re: Environmental Justice: Your proposal is very unjust to that portion of the U.S. citizenry who appreciate the wild horses in the wild!

P. 8: Wild Horses: This is a very rosy statement. How can you characterize the cruel and draconian removal of wild horses from their natural homes that will render the remaining herd non-viable as “increasing herd health”?!

P. 10: 3rd paragraph: Helicopter roundups are very stressful for wild horses who are traumatized thereby. Many experience injuries; and a considerable percentage die from these. Other ailments, such as depression and disease transmission, are common in the unnaturally overcrowded and manipulated holding pens. In fact, some of the captured wild horses are now going to slaughter under the Burn’s Amendment. For this reason, you should opt for a much better (and more taxpayer friendly) alternative of non-manipulative field management where wild horses would be born, live out their lives, and die within their legal areas – in a predator- prey balanced environment. In this way the wild horse can play out their classic, positive, and beneficial role in a restored Western ecosystem.

P. 11: We favor the No Action Alternative. Let the herd stabilize within its legal herd area, provided with barriers and ALL the natural habitat requirements of water, forage, shelter, elevational migration
routes, etc., that it requires to survive in the long-term in this beautiful Great Basin desert area with which we are personally familiar.

P. 17: Affected Environment: The livestock numbers and amount of forage, water, etc., allocated to them should be reduced. By allowing permittees to monopolize the wild horses’ legal Herd Areas and even HMA’s, you are abrogating your responsibility to the wild horses in the wild and the considerable public who support them there.

P. 18: No Action Alternative: This is hyperbole – an exaggerated or misleading statement that strays far from a wise, just and factual overview of the situation! Obviously your tendentious statement is aimed at wild horse removal and displacement with livestock and big game, i.e. wild horse minimization.

P. 20: I notice much attention to livestock and game interests, including guzzler construction and very
little for the wild horses.

P. 21: Present Actions: Leave the 900 wild horses alone and free! This figure equates to ca. 900 acres
per horse in their legal HMA’s. This is not an overpopulation! ... Bottom: Wild horses are also a Returned Native Species in North America (See enclosed article).

P. 26: Fertility Control: Concerning the 12 gauge or 1.5" barbless steel needle injected by jab stick – there is much possibility of the wild horses receiving serious injury.

P. 33 ff: Your discussion of Population Modeling is very superficial, as you do not consider the many alternative possibilities for activating the wild horses’ own innate ability to stabilize their population through density dependent responses.

P. 36: Nearly 800,000 acres of HMA’s in this complex and no doubt much more in the original 1971 legal HA’s in this region (What is this figure please and can you provide a map of original 1971 HA’s here?) could easily sustain a few thousand wild horses on a year-round basis. This would be a truly long-term viable population that could become ecologically adapted to this region, rather than just the “minimum viable population” so often touted. This area could sustain a few thousand wild horses without ecological degradation, provided the BLM followed the law and treated them as the legal “principal” presences here. Instead, the BLM’s proposal would set the wild horses up for inbreeding and chance die out by reducing them to non-viable population numbers that would be unable to withstand the vagaries of weather, disease, predator killings, and illegal killings by humans which are now on the rise.

Enclosed please find a recently published article of mine on the subject of wild horses in the wild, their evolution and ecology, etc. Thank you again for listening to our views and please let us know what we can do to restore the wild horses in the wild in the vast Wilson Creek Complex. Thank you also for apprising us of your final decision.

Sincerely,


Craig C. Downer, Wildlife Ecologist,

Ginger Kathrens, The Cloud Foundation