Caliente Complex Environmental Assessment Comments

Below are TCF's comments on the BLM's Environmental Assessment of the Caliente Herd Area Complex.

January 4, 2018

Ben Noyes
Wild Horse & Burro Specialist
Bureau of Land Management, Ely District Office
702 N. Industrial Way
Ely, NV 89301

Subject: Caliente Herd Area Complex Wild Horse Gather

Dear Mr. Noyes,

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 Caliente Herd Area Complex Wild Horse Gather.

It is alarming to us that a complete decimation of this wild herd has been proposed. The horses in the Caliente Herd Area Complex were protected at the inception of the Wild Free-Roaming Horses & Burros Act of 1971. We implore you to consider that removing every single wild horse from this complex is directly contradictory to those protections and will be devastating to the animals in these family bands. The federal government cannot afford to care for the horses and burros they currently have in holding. The complete eradication of this herd will only add to that ever-growing financial burden.


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 1,700 “excess” wild horses from the Caliente Complex over the next ten years could condemn many of them to an uncertain, and potentially lethal, fate.

The current BLM population estimate of 1,744 horses throughout the Caliente Complex translates to over 522 acres per horse on the 911,892-acre complex. We feel this is ample habitat, regardless of climate and terrain, to provide food and water for this horse population. Removing some of the animals would be a precautionary measure at best, but 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 522 acres per horse certainly provides the wild horses with an adequate forage base while leaving resources for other wildlife, including critical habitat for the greater sage grouse in the area.

In Section 1.1 of the Environmental Assessment, it is stated:

“… no wild horses are to be managed within the Caliente HA Complex based on in-depth analysis of habitat suitability and monitoring data. This analysis 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 about the herd’s population numbers. 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. 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.


The Environmental Assessment for the Caliente Complex points to shrub species being heavily hedged by horses, and trampling damage across the area including riparian areas. 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 3.2 provided in Section 3.2.7 of the Environmental Assessment, 35% of livestock grazing allotments for cattle, sheep, and domestic horses are in use 12 months out of the year. Those 9 allotments account for a total of 18,649 AUMs, with an average of 5,429 of those utilized over the last ten years. Therefore, this Environmental Assessment alleges this rangeland can accommodate 18,649 AUMs worth of livestock year-round, but it cannot withstand the impact of a single wild horse.

In total, 73% of those grazing allotments are in use at least half of the year. That 73% of allotments, a total of 19 different allotments, accounts for an incredible 35,616 AUMs according to the numbers in this table. The average use of those AUMs over the last year has totaled 8,857 AUMs. If each of those AUMs is a cow-calf pair, how is it that this land can accommodate 17,714 animals, 8,857 full-sized cattle, at least half of the year, but it cannot accommodate a single wild horse? And this ‘average use’ number does not even account for all of the AUMs granted for the Caliente Complex. 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.”


If the BLM feels that the population in the area is too high, rather than completely eradicating the herd, we feel that more emphasis should be placed on applying fertility control to these animals. At the National Wild Horse & Burro Advisory Board 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 office in Ely is fortunate to have many wild horse advocates at their fingertips who are ready to implement a similar program, but those relationships are not being utilized. Groups like the Pine Nut Wild Horse Advocates on the other side of the state of Nevada are doing such great work that their fertility control efforts have been included in the new Pine Nut HMA Management Plan. We know of many advocates on the eastern side of the state who would also love to implement a robust fertility control program. It seems short-sighted to opt for a costly 10-year roundup with subsequent holding costs when management on the range is certainly an available option.

In Section 1.1 of the Environmental Assessment, it states:           

“In the past two decades, goals have also explicitly included conducting gathers and applying contraceptive treatments to achieve and maintain wild horses populations…”

However, according to the BLM’s database of “Wild Horse and Burro Completed Management Actions” on the BLM’s website1, it shows that not a single contraceptive effort has been made within the Caliente Complex to control the population. If the BLM is truly concerned about the health of the rangeland because of the population of this herd, it is baffling to us that a roundup of 1,744 animals is being considered rather than contraceptive treatments. According to the BLM’s own numbers shared at the National Wild Horse & Burro Advisory Board meeting, these animals will cost $5.06 per day in short-term corrals and $1.97 per day on long-term government pastures, whereas volunteer darting of these animals costs a total of $30 per mare per year.

We believe a cost-effective, well-implemented population control plan for the Caliente Complex is far cheaper and more humane than a zeroing-out roundup, which will incur associated holding costs for nearly 2,000 wild horses. This type of management has consumed two-thirds of the BLM budget, over $43,200,000 in FY16. These animals alone will add either $8,824.64 per day in short-term holding, or $3,435.68 per day in long-term holding, to this already bloated “management” budget. We understand it takes time for PZP to begin to control the population growth of these herds, but the current population, allowing 522 acres per horse, would appear to allow for a long-term, cost-effective, on-the-range management solution.


The wild horse family bands in the Caliente Complex are extremely 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. While we understand population control measures may need to be enacted in the area, alleging that this land cannot sustain any wild horses when it can apparently sustain thousands of livestock is unfounded, illogical, and inaccurate.
2.     In managing this wild herd, we propose a robust population control program utilizing PZP fertility control which is a much more cost-effective, and overall more humane, approach to preserving these wild horses and their way of life on our public lands.
3.     We feel that signage on and around the Caliente Complex, specifically near highways 319 and 93, 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.
4.     We propose a cost examination of a fencing program around highways 319 and 93. We feel certain that installing fencing to mitigate traffic accidents will be much more cost-effective than paying for short- and long-term holding for 1,744 additional animals.
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), 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 Caliente Complex presents 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.


Ginger Kathrens
Executive Director
The Cloud Foundation


Kayah Swanson