Adobe Town Wild Horse Movements and Habitat Selection Research

Bureau of Land Management
Wyoming High Desert Office
Adobe Town Area Scoping Statement Comments
Attn: Wild Horse and Burro Specialist,
BLM Rawlins Field Office
1300 North 3rd Street, Rawlins, WY 82301.
Fax: 307-324-4224

DATE: October 31, 2016

Subject: DOI-BLM-WY-D030-2016-0104-EA Adobe Town Wild Horse Movements and Habitat Selection Research

Dear Wild Horse Specialist: On behalf of The Cloud Foundation (TCF), a 501(c)3 non-profit corporation, and our hundreds of thousands of supporters throughout the United States would like to thank you for the opportunity to comment on DOI-BLM-WY-D030-2016-0104-EA.

The Proposed Action is to implement a five (5) year research study (Appendix 1) that would document habitat selection, movement between habitats, seasonal use, and migration patterns of wild horses, within and outside of the ATHMA. The research objective is to understand how horses move across the Colorado-Wyoming border, how the removal of horses from the checkerboard portion of the HMA influences the movement of mares from non-checkerboard portions of ATHMA (i.e. creation of a void), how horses select landscape resources relative to their proportional availability, and how site fidelity of horses is influenced by season.

The Cloud Foundation respectfully submits the following Comments, Concerns and Recommendations:

The goal of this research project is not only of questionable need but is also unclear. Is the goal of studying the movement of the herd to establish a Wildlife Corridor or to determine need for range improvements or water catchments to enhance the quality of the range? Does the goal as stated in the EA justify the outrageous expense of a helicopter roundup since costs will not be shared with the removal of horses elsewhere in the in the Checkerboard? In our opinion the Adobe Town research project is unnecessary, vague, potentially dangerous and we believe its goals can be achieved using volunteers.

The Cloud Foundation recommends Direct Observation by volunteers and student Interns who would document the herd, identify migratory patterns, record bands and each member of the band, and assist in gathering horses via bait trapping for applying fertility control vaccine and to obtain hair samples for genetic analysis. . .bait trapping to be done in the spring of 2017. Using these techniques, the worthwhile purpose of bait-trapping and gathering of horses is an opportunity to establish “on the range” management information critical to the subsequent use of PZP or PZP-22.

Local volunteer groups or livestock permittees (with excellent background on the area) could help with bait trapping, documenting horses and applying fertility control. We recommend that PZP-22 or native PZP primers be applied to all mares to be released. Non-invasive tools available would be a much better way to achieve the goals described in the EA. Use of student scientists—interns who would observe and track the horses to understand not only the movements but the band structures which will allow for the development of a successful PZP program.

If bait trapping is used and band integrity maintained, fertility vaccines applied, and data collected costly helicopter roundups would be avoided. No additional horses would be added to costly short term holding facilities, and an established long-range plan for managing the horses on the range would begin.

The Cloud Foundation would help to recruit volunteers to work with the BLM to manage the Adobe Town wild horses “on the range.” Volunteers could monitor the herd; develop charts of the band members, including descriptions of each animal in the band. These could be college interns, local and regional adult volunteers, which could include livestock permittees who would already be well versed on the likely locations and seasonal grazing patterns of the wild horse bands. Volunteers could determine mares to be darted (those that have contributed their genetics to the herd by producing a live foal that survives to become a yearling). Volunteers could assist in bait trapping, and, if they are certified, volunteers could administer PZP each year.

The Cloud Foundation continues to encourage management of wild horses “on the range” using the safe fertility control vaccine PZP or PZP-22. By managing wild horses on the range the BLM avoids the expense of housing wild horses for the remainder of their lives at a very high cost to American Taxpayers. Given that Short Term Holding costs for the BLM account for the largest portion of its budget, roundups and removals should be avoided entirely.

The Cloud Foundation strongly opposes radio collaring of wild horse mares. This is obviously a very dangerous practice for wild horses and unnecessary as there can be (and are) observers of the herd who can provide information more than what would be learned with radio collars. While the collar can be remotely removed, there is no way to ascertain the presence of problems. How will mares in trouble be identified so that help can be sent to prevent further injury or death? From what distance, can the collars be remotely removed? Who and how will collars be monitored, particularly during winter months when travel in the area is difficult? Why isn’t the study using break-away collars?

Simply put collars are dangerous. In a 2014 joint BYU/ Oregon State University/USFW/BLM study 11% of collars failed to detach correctly.

The Cloud Foundation strongly opposes the use of helicopter roundups and recommends instead Bait Trapping of horse.

Helicopter roundups shatter the social order – any subsequent findings after a helicopter roundup will be useless. Helicopter roundups create a significant shuffling of members and conflicts as stallions attempt to create new bands. New bands would likely develop new migration patterns invalidating any information gathered from collars after a helicopter roundup.

Helicopter roundups are physically damaging to the horses and fracture the family units, which can contribute to an increased reproduction rate.

Helicopter roundup of wild horses in the spring should be avoided as they can result in mares miscarrying, small foals being injured from running long distances, and the herd as a whole being placed under unnecessary stress at an already stressful time of the year.

Bait trapping allows for capture of family bands so that bands can be documented and specific mares identified for fertility control application. Bait trapping can be conducted at the correct time of the year. If used in late winter-early spring when food is in short supply bait trapping can be very effective.

The EA states that hair samples would be collected for DNA analysis to assess the genetic diversity of the herd. Hair samples could just as easily be collected from mares gathered through bait trapping.

Fertility Control Recommendations

The NEPA description in the EA discusses rounding up mares and treating them with PZP but does not describe what type of PZP or how this fits into the broader picture of a continuing fertility control program. TCF recommends developing a plan for PZP applications and follow up monitoring to determine the impacts of using PZP. Haphazard and poorly planned PZP applications are not only ineffective but can lead to false conclusions regarding the effectiveness of PZP or PZP-22.

Direct Observation using volunteers would enable BLM could age the mares returned to the range after any bait-trapping operation and chart the age structure, take pictures of each captured animal to be returned to the range. Volunteers could be used as scribes to record and photograph the horses to be returned.

To determine the results of the “on the range” program, a follow up is critical and must be done to determine the effectiveness of the program, identifying mares that have foaled and at what approximate time, and which mares have not foaled. This activity could be supported by volunteers.

Livestock Grazing

Wild horses are a protected species that are granted legal rights to HMAs, while cattle grazing is a privilege and is a leasing program under the jurisdiction of the BLM. The BLM has the legal authority to decrease the amount of public grazing that occurs or retire grazing leases. Rather than opting for this course of action, the BLM seeks to resolve the problem in a way that allows horses zero access to private lands while privately owned livestock have 100 percent access to both public and private lands.

We suggest that BLM consider changing the management of the checkerboard as a whole. We suggest you include in the EA a plan to consolidate sections of the checkerboard, allowing ranchers to consolidate their holdings into single properties while public parcels are consolidated into solid blocks. Such swaps and consolidations have been successfully negotiated in California, Oregon and Nevada.

In 2014 over 100 wild horses lost their lives as a result of the illegal roundup and removal of horses from public and private lands in these same three HMAs. We do not believe that taxpayer funded actions to remove wild horses from public lands should be undertaken to accommodate private landowners.

If private landowners resist land swaps, BLM should consider closure to livestock (4710.5). This could be done seasonally or permanently. We would like to see a discussion of land swaps and closure to livestock in the EA or EIS as an alternative to the total removal of wild horses from both private and public lands.

Even the Consent Decree repeatedly stipulates that BLM retains the discretion to manage the wild-horse program as it deems proper, meaning the BLM is still charged with maintaining healthy, genetically viable herds. Removing such a high number of horses from the range would not achieve this goal. The goal should not be to manage down to the minimum viable population but rather up from it. The goal is not to keep the wild horse population as low as possible but as high as possible to ensure genetic viability. Wild horses are considered a protected natural resource. They have legal rights to exist on their rangelands in sustainable herds as established by the 1971 WHA.

We request that the EA or EIS include genetic reports for Adobe Town based on hair samples taken in 2014. Were hair samples pulled for testing in 2014? When did Dr. Gus Cothran last prepare a genetic analysis? Please provide his last report in the EA/EIS. Monitoring the health of the wild horse herds in question should include monitoring their genetic health.

Protection of Predators
We ask that you consider protection of mountain lions as a natural way to assist in the management of wild horse populations in the Adobe Town HMA.

Thanks again for the opportunity to comment. Please don’t hesitate to call if you have questions on our comments. We look forward to working with you in a collaborative way in future.


Ginger Kathrens
Volunteer Executive Director
The Cloud Foundation, Inc.
107 S. 7th Street
Colorado Springs, CO 80905

Kayah Swanson