Checkerboard EA Comments

Bureau of Land Management
Wild Horse and Burro Specialist
BLM Rock Springs Field Office
280 Highway 191 North
Rock Springs, WY 82901
Re: DOI-BLM-WY-D040-2016-0135-EA Checkerboard EA Comments

Sept. 9, 2016

Dear Mr. D’Ewart;

On behalf of the Cloud Foundation thank you for the opportunity to comment on DOI-BLM-WY-D040-2016-0135-EA, calling for the removal of all wild horses (approximately 480-580 mostly from Salt Wells Creek and Great Divide Basin HMAs with about 25 to be removed from Adobe Town HMA as only a small portion of the HMA lies within the checkerboard) on both the public and private lands in the checkerboard lands along the I-80 corridor.

Despite a modest AML for horses in the checkerboard areas (200), all wild horses in the Salt Wells, Great Divide Basin and Adobe Town Herd Management Areas within the checkerboard are to be removed, further overburdening short term facilities. We do not believe you are justified in removing all horses in these areas. The horses will lose their freedom and the taxpayers will foot the bill.

We strongly protest to the roundup and removal of wild horses under the Proposed Alternative for the following reasons:

1. Public Lands should not be treated as privately owned lands. We strongly protest and disagree with the following characterization of the checkerboard: “For all intents and purposes, we consider all of the checkerboard private,” said Rock Springs Field Manager Kimberlee Foster. This is an outrageous statement and reveals how deferential the agency is to these powerful land barons. It seems straight out of a wild west movie.
While the BLM must honor a request to remove wild horses from private land, it cannot use this request to remove wild horses from PUBLIC LANDS. This action would gravely endanger the few remaining wild horse herds across the west. This action also treats publicly owned land as private which gives ominous power to livestock ranchers who wish to control public lands.
Anadarko Petroleum owns the surface mineral rights on a portion of the private lands within the checkerboard and the Rock Springs Grazing Assoc. leases that land from Anadarko. We have seen the damage done to the land first hand and are appalled at the lack of remediation by this privately owned company.

2. The population statistical data provided by the BLM is inadequate and highly questionable. According to the EA, the Census for April 2016 is as follows:

HMA                         Total within HMA     Total within Checkerboard
Great Divide Basin   542                          272
Salt Wells Creek       696                          187
Adobe Town             684                          25
Total                          1,922                       484

After the Oct.2014 Roundup the BLM used the following numbers:
Adobe Town: 519
Salt Wells Creek: 29
Great Divide Basin: 91

The figures from the 2015 April flyover were:
Adobe Town: 858
Salt Wells Creek: 616
Great Divide Basin: 579

The population increase from 2014 to 2015 bears no resemblance to reality. The 2016 Census actually shows a reduction in population. Therefore, the Census numbers provided by the BLM have no credibility.

Until an accurate census and documentation of the herds, complete with photos of all horses can be provided, no action should be taken. The Cloud Foundation will gladly assist with boots on the ground volunteers to help undertake this task.

3. The EA does not take into account Compensatory Reproduction which will take place after a roundup of so many horses. A roundup of this magnitude serves only to perpetuate the roundup and removal cycle that has been proven to be ineffective, costly and cruel.

The NAS Study specifically states that roundups and removals are not effective and actually exacerbate the problem of population control due to compensatory reproduction. Massive removals of wild horses trigger population increases in subsequent years, a biological response.

4. The EA makes no analysis of the impacts of livestock grazing. The EA describes in detail the impact of wild horses on every aspect of the environment but fails to consider the even greater impact of livestock grazing. The Appendix describing livestock grazing is not included in the EA.

The assertion that wild horses are damaging the resource is unsupported with any kind of believable data. Most scientists and range managers agree that wild horses do no more damage than cattle to public lands and in fact, far less. In 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 believe this conclusion is just as sound today as it was in 1990 when there were far more wild horses and burros roaming on public lands.

Allocating the lion’s share of Animal Unit Months (AUMs) to cattle that cost the taxpayers over 120 million dollars a year in administration fees alone is an insult to the American taxpayer. It seems fiscally irresponsible for the federal government to spend so much on administration fees plus the huge amounts paid to contractors to round up the wild horses

5. The wild horses of the American West belong to the American public. The public includes not only those living in the areas near these HMAs, but also people across the country from all 50 states. With objection spreading around the country, the BLM should not turn a deaf ear to the pleas of the American public for the sake of welfare livestock or other extractive users of the land. The cattle on public lands represent only about 3% of the beef market in the US.

6. The ongoing cost of roundups and removals is not sustainable. Earlier this year Neil Kornze, BLM Director, bemoaned the soaring cost of managing wild horses and burros on public lands, but the actions recommended by this EA only contribute to that cost and ultimately to the unsustainability of the program.

7. Helicopter drive trapping totally disrupts bands and social structures, which can accelerate herd growth due to an increase in breeding when stallions acquire new mares. Bait trapping is not only more humane but offers the least expensive and least invasive method to select young horses that might have the opportunity to be adopted.

By taking progressive steps now to ensure that HMA’s and HA’s are managed principally for the welfare of wild horses instead of livestock, by taking aggressive measures to curb population and manage wild horse populations “on the range “now, the BLM could potentially assure the future of wild horse herds in the Great Divide Basin, Salt Wells Creek, and Adobe Town HMAs.

Therefore, The Cloud Foundation strongly recommends Alternative 1, No Removals, combined with a comprehensive fertility control program using PZP administered with the help of volunteers, aimed at achieving zero population growth by balancing mortality with reproduction.

The only other alternative The Cloud Foundation would support is Alternative 3, again, combined with a comprehensive fertility control program using PZP administered with the help of volunteers, aimed at achieving zero-population growth by balancing mortality with reproduction.

Alternative 3: Remove all wild horses from Checkerboard and return to public lands of HMAs. Captured wild horses would be removed from the Checkerboard lands and returned to solid block public lands within each of the HMAs


Removal of wild horses from their native lands at the insistence of the Rock Springs Grazing Association perpetuates the State of Wyoming’s ranching mentality that views public lands as private. By removing wild horses under Alternative 2, the BLM continues to surrender its responsibility to protect wild horses on public lands and bow to the Rock Springs Grazing Association’s land grab which began over 100 years ago.


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

Kayah Swanson