Seaman & White River Herd Area Comments
Bureau of Land Management, Ely District Office
702 N. Industrial Way
Ely, NV 89301
Subject: Seaman and White River Herd Area Wild Horse Gather Environmental Assessment
Dear Ms. Thompson,
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 Seaman and White River Herd Area Wild Horse Gather Environmental Assessment.
It is alarming to us that a complete decimation of these wild herds was proposed in 2008. The horses in the Seaman and White River Herd Areas were protected at the inception of the Wild Free-Roaming Horses & Burros Act of 1971. We implore you to consider that zeroing out these herds is a direct contradiction to those protections and will be devastating to the animals in these family bands. The federal government contends they cannot afford to care for the horses and burros currently in holding. The complete eradication of these herds will only add to that ever-growing financial burden.
First and foremost, we are concerned about any proposed removals on any herd management area after the National Wild Horse and Burro Advisory Board (NWHBAB) meeting on October 18-19, 2017 in Grand Junction, CO. There, the majority of board members 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 365 “excess” wild horses from Seaman and White River Herd Areas over the next ten years could condemn many of these animals to an uncertain and potentially lethal fate.
CLAIMS OF UNSUSTAINABILITY
The current BLM population estimate of 365 horses on these two herd areas translates to over 1,300 acres per horse on the 475,100-acre complex. We feel this is ample habitat, regardless of climate and terrain, to provide food and water for this horse population, especially considering the fact that they’ve managed to survive there since the passage of the Act in 1971. Removing every single one of these wild horses simply has no basis in fact or science, contradicts the protections these animals were afforded by the Act of 1971, and will senselessly add to the growing masses of animals under government care at taxpayer expense. We feel 1,300 acres per horse certainly provides the wild horses with an adequate forage base while leaving resources for other wildlife.
In Section 1.1 of the Environmental Assessment, it is stated:
“… no wild horses are to be managed within the three areas based on analysis of habitat suitability and monitoring data, which indicates insufficient forage and water is available to maintain healthy wild horses and rangelands over the long-term.”
It is simply unfathomable to us that these horses, who have been living in this area since the Act of 1971 was passed, do not have enough forage and water to survive. They have clearly managed to survive there for over 40 years with the available forage and water, and have done so in such a prolific manner that the Bureau of Land Management is concerned that the number of horses is allegedly damaging the terrain. If forage and water were all but unavailable to these animals, they would not be able to reproduce at a rate that has so alarmed the BLM.
Further on in Section 1.1, the Environmental Assessment states:
“The Seaman HA as well as White River HA have inadequate forage, marginal to very little water on public lands, and inadequate reproductive viability.”
We are confused as to why the BLM would list reproductive viability as a concern for these animals, when for many of the 177 wild horse and burro herds, the BLM has set an “appropriate management level” that renders most herds genetically non-viable. Renowned 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, paid for by the BLM, 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)
It is confusing to us that most of the appropriate management levels for other herds have been set well below this genetic viability threshold, but now the BLM is using an alleged concern about genetic viability to explain away the zeroing out of a herd that has managed to survive in this area for 47 years.
We are also concerned that no data was provided regarding range utilization in this environmental assessment, such as the percentage of offtake by individual species.
ALLOCATION OF RANGELAND
The Environmental Assessment for these herd areas points to trampling damage by wild horses, allegedly evident at most water developments and riparian areas, as well as heavy hedging of scrub species in Section 1.1, page 7. We feel it would be extremely difficult to point to any direct damage to the land that could be resolved only by eliminating the 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.
According to table 2 provided in Section 18.104.22.168 of the Environmental Assessment, over 50% (8 of 15) of cattle grazing and 37% (3 of 8) of sheep grazing AUM allotments are in use 6 months out of the year or more. Those allotments account for a total of 21,749 AUMs. Therefore, this Environmental Assessment alleges this rangeland can accommodate 21,749 AUMs worth of livestock at least half of the year, but it cannot withstand the impact of a single wild horse.
The allotments in use for more than half of the year account for a total of 8,157 AUMs used on average per year over the last ten years. If each of those AUMs is a cow-calf pair, how is it that this land can accommodate 16,314 animals, 8,157 full-sized cattle, at least half of the year, but it cannot accommodate a single wild horse? If each of the AUMs is five sheep, that’s a whopping 40,785 animals that the BLM determined this land can support, while in the same breath this agency claims this land cannot sustain the impact of a single wild horse. This ‘average use’ number does not even account for all of the AUMs granted for these herd areas. This is an egregiously ridiculous claim on the part of the government agency tasked with managing animals referred to by an Act of Congress as “living symbols of the historic and pioneer spirit of the West.”
We understand that water supply is of great concern to the BLM, and that many of these livestock permit holders cart in their own water or have well permits. However, in Section 1.1 of the Environmental Assessment on page 7, it is stated that Seaman HA has four spring sources, and White River HA has five spring sources. While it is also mentioned that three of the four and three of the five go dry in the summer, respectively, it is our opinion that these horses have managed to make do since 1971 and ought to be allowed to continue to make do. These HAs are their homes, and their right to remain in their home has been federally protected for 47 years.
THE VALUE OF WILD HORSES
The wild horse family bands in the Seaman and White River HAs are popular with wild horse advocates, photographers, and tourists. These horses provide an economic benefit through tourism dollars, both locally and to the entire state of Nevada.
Furthermore, these horses are a federally protected wild species, and are credited with symbolizing the historic and pioneer spirit of the American West2.
“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 a reexamination of the idea that this land cannot sustain any wild horse population whatsoever. Alleging that this land cannot sustain any wild horses when it can apparently sustain thousands of livestock is unfounded, illogical, and inaccurate.
2. We feel that signage on and around the Seaman and White River Herd Areas would be extremely beneficial. This would help not only identify the horses seen from the road as wild horses, but would also help to alert drivers to the presence of wild animals, similar to the signs seen on roads warning drivers to the presence of other passing wildlife.
3. If a roundup does occur, we implore the BLM to reconsider an eradication of this herd, and to be mindful of 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), 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. We believe that the Seaman and White River Herd Areas present a special opportunity to showcase forward-thinking, cost-effective, humane wild horse management in the state of Nevada. We will help you in any way we can.
Please feel free to call us with any further questions about our comments.
The Cloud Foundation