Onaqui HMA Scoping Notice Comments

Below are TCF's comments on the BLM's scoping notice for the Onaqui Herd Management Area. 

October 30, 2017

Matt Preston, Field Manager
BLM Salt Lake Field Office
2370 South Decker Lake Boulevard
Salt Lake City, UT 84119

Subject: Population Control, Gather, and Research for the Onaqui Mountain Wild Horse Herd Management Area Project

Mr. Preston,

On behalf of The Cloud Foundation, a 501(c)3 nonprofit corporation, and our hundreds of thousands of supporters through the United States, we would like to thank you for the opportunity to comment on the Population Control, Gather, and Research for the Onaqui Mountain Wild Horse Herd Management Area Project.

It is alarming to us that a roundup of this size has been proposed. We implore you to consider that removing “over 325” wild horses from this HMA is a devastating proposal that will wreak havoc on this herd. This would be a 72 percent decrease in herd size, making this herd no longer genetically viable, and it would be tragic for the people who enjoy viewing this very popular herd in the wild and know individual band stallions, mares, and their offspring.


First and foremost, we are concerned about any proposed removals on any herd management area, nationwide, after the National Wild Horse and Burro Advisory Board (NWHBAB) meeting on October 18-19, 2017 in Grand Junction, CO. There, the board made it quite clear that mass killing is still very much on the table as an option for clearing out the horses in short- and long-term holding. The removal of over 325 Onaqui HMA wild horses could condemn many of them to an uncertain, and potentially lethal, fate.

Additionally, the proposed removal of over 325 horses will render the Onaqui HMA herd genetically non-viable. This proposed removal to the low appropriate management level of 121, as previously stated, would be about a 72 percent reduction in herd size. Equine geneticist, Dr. Gus Cothran, has long stated that in order to remain genetically viable, herds must be 150-200 animals in size at a minimum. The National Academy of Sciences Report from 2013 cites Dr. Cothran’s work as a helpful tool for BLM management of herds.

“The Cothran studies are excellent tools for BLM to use in managing herds to reduce the incidence of inbreeding…”
National Academy of Sciences 2013 Report: Using Science to Improve the BLM Wild Horse and Burro Program – A Way Forward (p.192)

Based on information shared by the Wild Horses of America Foundation (WHAF) (a group partnering with the BLM to deliver PZP treatments to the Onaqui herd), these horses operate in five distinct groups with limited interaction as they occupy different geographic areas within the HMA. Each of these five groups contains less than 180 animals, the smallest of which has as few as 30 members. To achieve low AML on this HMA, BLM would not only render the entire herd genetically non-viable, but could put the smaller groups into a genetic free fall.

The scoping notice dated September 27, 2017 states the proposed roundup comes in response to several issues affecting the HMA, including “resource impacts due to over-population of wild horses.” After our conversations with members of WHAF who spend a good deal of time on the Onaqui HMA, we feel it would be extremely difficult to point to any direct damage to the land that could be resolved only by reducing the number of horses. If, in the eyes of the BLM, there are legitimate problems with the health of the range, it would be critical to take a look at all of the users of the land and their relative impacts – including cattle and sheep.

We believe the Onaqui AML could be and should be higher. A low AML of 121 is not a genetically viable number. The current BLM population estimate of 450 horses throughout the HMA translates to 1,128 acres per horse on the 507,681-acre range, and provides the wild horses with an adequate forage base while leaving resources for other wildlife, including critical habitat for greater sage grouse.


This scoping notice cites the preservation of sage grouse territory as mandated under the Utah Greater Sage-Grouse Approved Resource Management Plan Amendment (ARMPA) as a significant reason for a massive roundup. However, the area of the Onaqui HMA where wild horses roam is not an area of high sage grouse activity, and the sage grouse territory only overlaps about 50 percent of the HMA, according to the map provided by the BLM entitled “Onaqui Mountains Wild Horse & Burro Areas with Sage Grouse Habitat” (see attached). It is also not listed as a High Priority Sagebrush Focal Area in ARMPA. Instead it is listed as a Priority Habitat Management Area (PHMA) (see attached).

In ARMPA, it is stated that using fencing to separate sage grouse territory from livestock on the land is an acceptable way to enhance the habitat, specifically in PHMA.

ARMPA, Section 2.2.4:
MA-LG-9: “… Where recovery or maintenance is not occurring… reduce pressure on riparian or wet meadow vegetation used by GRSG in the summer by adjusting grazing management practices (e.g., use fencing…)”
MA-LG-14: “In PHMA, design new structural range improvements to have a neutral effect or conserve, enhance, or restore GRSG habitat…. Structural range improvements, in this context, include but are not limited to: …fences, exclosures…”

We believe this would be an effective approach for wild horse use, as well. This is a much less costly approach than a massive roundup putting horses in short- and long-term holding, which cost the taxpayer $43,201,677 in FY16. It is also more humane, considering the potential for destruction of wild horses and burros in short-and long-term holding. According to cost figures shared during the BLM presentation at the NWHBAB meeting in Grand Junction, entitled “Wild Horse & Burro Program Overview,” the cost of putting 325 additional horses in short-term holding would be $600,242 per year, and long-term holding would be $233,691.25 per year. Congress has indicated to the BLM that there must be a reduction in holding costs for these wild horses and burros. It seems counterintuitive to add more wild horses to holding through a roundup, thereby increasing holding costs, when there is another, more cost-effective option indicated in the very amendment the BLM cites as a reason for this roundup.

It also seems illogical to propose a massive reduction to a wild horse herd size on the Onaqui HMA in the name of sage grouse protection when the BLM recently announced intent to reexamine its sage grouse protection plan across 10 western states, including Utah.

“On October 5, the Department of the Interior announced its intention to revisit
land use plans in 10 western states in order to improve greater sage-grouse


“The BLM intends to consider the possibility of amending… the BLM land use plans that were amended or revised in 2014 and 2015 regarding Greater Sage-Grouse conservation in the states of California, Colorado, Idaho, Nevada, Oregon, Wyoming, North Dakota, South Dakota, Utah, and Montana.”
https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do? methodName=dispatchToPatternPage&currentPageId=134121

On October 5, 2017, the BLM announced 10 million acres in six western states including Utah will not be protected as sage grouse focal areas so that mining can proceed on that land. It does not seem logical that this herd will be decimated by the BLM in the name of sage grouse protection, when the extremely destructive practice of mining will be allowed by the same agency on sage grouse habitat.

The U.S. Fish & Wildlife Service (USFWS) issued the findings of a study regarding the endangered nature of sage grouse in 2012. Dr. Jeff Manning gave a presentation at the NWHBAB meeting in March of 2013 in Oklahoma City, OK regarding wild horses and sage grouse. According to eyewitness accounts from that presentation, Dr. Manning stated that the USFWS identified habitat loss caused by the following factors as top threats to sage grouse:

1.     Energy development
2.     Transmission right of ways
3.     Fire
4.     Invasive species
5.     Commercial development

The USFWS does not cite wild horses as one of the top five threats to sage grouse. Even former BLM Division Chief Joan Guilfoyle, at that same meeting in Oklahoma City, said, “There is a perception that wild horses have a big effect on sage grouse. We want to deal with reality, not perception.”


We feel that more emphasis should be placed on applying fertility control to the Onaqui Herd. At the NWHBAB meeting in Grand Junction, the board repeatedly discussed the benefit of the partnership between BLM and Friends of the Mustangs (FOM). BLM and FOM continue to implement a robust population control program in the Little Book Cliffs HMA. The BLM for the Onaqui HMA is also fortunate to have a partnership with the WHAF, and yet the partnership is not being used to its full potential. We have been told that the WHAF is prepared to enact a robust fertility control program. It seems short-sighted to opt for a costly roundup with subsequent holding costs when management on the range is available to you.

Members of the WHAF indicate the unofficial goal for FY18 is to dart 60 mares. We feel that in order to stabilize and reduce the horse population, this number should increase to at least 80-90 mares.

With this in mind, the cost of PZP treatments should be accurately discussed. $2,500 is often shared as the cost of treating a mare with PZP. However, this includes rounding up the mare, treating her, holding the mare for a few weeks before treating her again, and then releasing her. Volunteer darting of mares in the field costs about $30 a dose.

We believe a cost-effective, well-implemented population control plan for Onaqui is far cheaper and more humane than a roundup, which will incur associated holding costs for over 325 wild horses. This type of management has consumed two-thirds of the BLM budget, over $43,200,000 in FY16. We understand it takes time for PZP to begin to control the population growth of these herds, but the current population, allowing 1,128 acres per horse, would appear to allow for a long-term, cost-effective, on-the-range management solution.


The wild horse herd on the Onaqui HMA is extremely popular with wild horse advocates, photographers, and tourists. These horses provide an economic benefit through tourism dollars, both locally in Tooele County and to the entire state of Utah. The Onaqui Mountain Herd is regularly documented by the WHAF on their Facebook page, which has about 14,000 active followers interested in the health and wellbeing of these animals.

Furthermore, these horses are a federally protected wild species, and are credited with symbolizing the historic and pioneer spirit of the American West.

“That Congress finds and declares that wild free-roaming horses and burros are living symbols of the historic and pioneer spirit of the West; that they contribute to the diversity of life forms within the Nation and enrich the lives of the American people…”
Wild Free-Ranging Horses and Burros Act of 1971

They are beautiful creatures that deserve the opportunity to live their lives on their homeland, with their families. BLM has tools at their disposal to manage this population on the range without removing them.


1.     We propose an emphasis on population growth suppression programs, utilizing WHAF volunteers who are ready to implement a robust PZP program. We feel that a goal of at least 80-90 mares darted in FY18 would be a good start.
2.     We feel an adjustment to the AML for the Onaqui HMA is warranted. In particular, the low end of the AML should be adjusted upward to take genetic viability into account.
3.     In implementation and management of ARMPA, we propose that the BLM investigate the range impacts of all of the land users including livestock, not just wild horses, in order to appropriately carry out ARMPA in the extremely important task of preservation of sage grouse. Additionally, we feel it would be prudent to look at the lower-cost option of utilizing fencing to protect habitat rather than costly roundups and holding.
4.     We feel that signage on and around the Onaqui HMA to direct local traffic to stay on legal routes would be extremely beneficial. We have heard from advocates on the ground that there has been damage to the land because of off-roading ATVs and other motorized vehicles.
5.     If a roundup does occur, we implore the BLM to reduce the number of horses they plan to remove so the herd remains genetically viable. We would also ask the BLM to focus on rounding up only those animals of adoptable age (1-5 years) that regularly occupy sage grouse habitat, and to do so through the more humane method of bait and water trapping rather than helicopter roundups.

We are very grateful for the opportunity to offer our comments and, as always, we appreciate your willingness to listen to our thoughts. I know personally that you care about the wild horses you manage and will always be grateful for your kind and thoughtful consideration of these animals. I believe that Onaqui presents a special opportunity to showcase forward-thinking, cost-effective, humane wild horse management. We will help you in any way we can.

Please feel free to call us with any further questions about our comments.


Ginger Kathrens
Executive Director
The Cloud Foundation
107 South 7th Street
Colorado Springs, CO 8090

Kayah Swanson