2017 AML Gather – Adobe Town, Salt Wells, Great Divide Basin

BLM Rock Springs Office
2017 AML Gather – Adobe Town, Salt Wells, Great Divide Basin
280 Highway 191 North
Rock Springs, WY 82901

DATE: March 22, 2017

Subject: 2017 AML Gather

Dear Mr. D’Ewart:

On behalf of The Cloud Foundation (TCF), a 501(c)3 non-profit corporation, on behalf of our thousands of supporters throughout the United States, we would like to thank you for the opportunity to submit scoping comments on DOI-BLMWY-D040-2017-0022-EA.

According to the Scoping Letter the BLM proposes to round up and remove 1,029 wild horses from Adobe Town (AT), Salt Wells Creek and Great Divide Basin HMA’s to achieve low AML in the fall of 2017. The proposed roundup is to be completed by helicopter driving.

Census Required

TCF strongly opposes the removal of any wild horses from these HMAs without conducting an accurate aerial census using the latest and most reliable techniques. You project that AT may be 20 horses over the High AML. It is very possible the herd is within the parameters of the AML. And, conducting a helicopter roundup in an area currently being studied the natural movements in the HMA makes no sense to us. The disruption of a helicopter roundup will skew any results of this collaring and tracking project, rendering any research conclusions inaccurate.

On the Range Management

The Cloud Foundation continues to encourage management of wild horses “on the range” using safe fertility control vaccines PZP or PZP-22. By managing wild horses on the range the BLM avoids the cost 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 when possible.

We strongly recommend applying PZP-22 to all mares captured and released. Roundup should be band-by-band, retaining only adoption age animals of 5 years and under with an emphasis on removing only 1-2 year olds, which are the most adoptable ages. Numbers removed should be reduced to only the number of wild horses that can reasonably be adopted.

Provide a halter training program for all young horses capture to increase their chance of adoption. Only remove the number of young wild horses that can be trained.

The Cloud Foundation will help to recruit volunteers to work with the BLM to manage the three HMAs “on the range.” Volunteer photographers positioned at the trap sites could begin documentation of the herds. This would provide a basis to chart horses for ongoing management on the range.

In future years volunteers could monitor the herd; keep charts of the band members, including descriptions of each animal in the band, determine mares to be darted (those that have contributed their genetics to the herd by producing a live foal that survives to be a yearling), could assist in bait trapping and, if they are certified, could administer PZP in future years. Volunteers could include livestock permittees, hunters, and frequent visitors who would already be familiar with likely locations and seasonal grazing patterns of the wild horse bands.

Use of PZP-22 would serve as a primer for all mares so that subsequent doses of native PZP can be delivered via field darting or bait and dart methods.

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. Volunteers could support this activity.

Bait Trapping instead of Helicopter Roundup

The Cloud Foundation recommends bait trapping instead of helicopter roundup as a means to capture horses for the application of PZP. Helicopter roundups are physically damaging to the horses and fracture the family units, which can contribute to an increased reproduction rate.

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.

Local volunteer groups or livestock permittees could help with bait trapping for any future applications of PZP or for removals of small adoptable numbers of young horses.

Land Swaps

Negotiations with private landowners should begin with the goal of consolidating public and private lands to streamline management and mitigate the constant acrimony with private landowners and the BLM.

Wild horses are a protected species, granted legal rights in 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 public lands grazing and should exercise this authority to encourage the consolidation of the checkerboard.

Consolidation of public lands and private lands would allow BLM better flexibility in managing these three herds. Such swaps and consolidations have been successfully negotiated in California, Oregon and Nevada.

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 massive removals of wild horses from the three HMAs.

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.

Genetic Variability

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.

As requested in scoping comments submitted in 2016 for Adobe Town Collaring, the EA or EIS must include genetic reports for the three HMAs. Including the most recent assessment by geneticist E. Gus Cothran will allow the public to assess the genetic health of the herd and population of the herd when that assessment took place.

Please provide the most recent genetic reports 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. I realize that this information would typically come from Wyoming Fish and Game but we believe that BLM should look at holistic, on the range management. This includes all possible ways to manage, including natural management.

Additional Information for inclusion in EA/EIS

  • We request that you provide up-to-date and accurate data regarding the three HMAs per NEPA in the upcoming EA or EIS. The data should include actual grazing use reports for the past five years, allotment management plans, improvements for the exclusive use of livestock, season of use by livestock as well as grazing patterns, AUMs, other lands uses, and recreation uses including recreational off road use.
  • Please include all census data, supporting a 20% annual growth rate of all three wild horse herds. You repeat the 20% increase in population but fails to cite the actual census figures, and how and when the census took place. 
  • What is the rate of mortality? Is the yearly death rate of foals and adults calculated in some way?

Thanks again for the opportunity to comment. We look forward to hearing from you. Please don’t hesitate to call if you have questions regarding 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


TCF CommentsJesse Daly