Muddy Creek Wild Horse Gather Plan EA

Chris Conrad, Field Manager
BLM Price Field Office,
125 South 600 West,
Price, UT 84501

Subject: Muddy Creek Wild Horse Gather Plan EA

Dear Mr. Conrad,

On behalf of The Cloud Foundation, a 501(c)3 nonprofit corporation, and our hundreds of thousands of supporters throughout the United States, we would like to thank you for the opportunity to comment on the Muddy Creek Wild Horse Gather Plan EA.

It is alarming to us that a roundup of this size has been proposed. We implore you to consider that removing 148 wild horses from this HMA is a devastating proposal. This would be a 66 percent decrease in herd size, rendering this herd genetically unviable, particularly concerning because the herd began suffering dangerously low genetic variability more than 17 years ago, according to expert equine geneticist Dr. Gus Cothran.


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 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 148 Muddy Creek HMA wild horses could condemn many of them to an uncertain, and potentially lethal, fate.

Additionally, the proposed removal of 148 horses will render the Muddy Creek HMA herd genetically unviable. This proposed removal to the low appropriate management level of 75, as previously stated, would be a 66 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 reproducing 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)

In fact, Dr. Cothran began citing concerns about the genetic variability of this herd almost two decades ago:

“Genetic analysis from 62 individuals gathered during the 2001 gather showed a very low Observed Heterozygosity (Ho) or individual variability (Cothran, 2002). Dr. Cothran states that Ho in the Muddy Creek herd is below the proposed critical value for feral horses of 0.31, and 11 of the 50 genetic variability measures are below the mean values for feral populations.”
Muddy Creek Wild Horse Herd Management Area Gather Plan, p. 37

Regardless, roundups have regularly continued since then, with roundups conducted in both 2008 and 2009 to bring the herd down to low AML of 75 animals (Muddy Creek EA, p. 5). As a result, horses from other HMAs have had to be introduced from other areas to improve the genetic variability of the herd (Muddy Creek EA, p. 37). By this office’s own admission, “The AML is not large enough to maintain a good genetic health without introduction of horses from outside the HMA” (Muddy Creek EA, p. 37). In a time when Congress is calling for this agency to reduce its costs, it seems counterintuitive that the Price Field Office (PFO) would conduct a costly roundup and removal of animals it only later must replace through costly and time-consuming transport of other animals for the genetic health of the herd. The Muddy Creek EA document states that one management action used to implement Alternative 2 will take the form of introducing new animals:

“Every 4-5 years, 1-3 studs or mares from a different HMA … would be released to maintain the genetic health on the HMA.”
Muddy Creek Wild Horse Herd Management Area Gather Plan, p. 16

The EA also states that “the long-term goal is to reduce the need for gathers and removals, without jeopardizing the genetic health of the population” (Muddy Creek EA, p. 16). While we agree with this sentiment, we do not understand how attaining low AML in the long-term is something that this office sees as contrary to jeopardizing genetic health of the herd, when this office has already admitted that the AML does jeopardize the genetic health of the herd.

If the sole reason the PFO is conducting roundups of these animals, then replacing them with other animals to increase genetic variability, is to achieve AML, we suggest the PFO consider the findings of the BLM-commissioned National Academy of Sciences report from 2013:

"How Appropriate Management Levels are established, monitored, and adjusted is not transparent to stakeholders, supported by scientific information, or amenable to adaptation with new information and environmental and social change."
Using Science to Improve the BLM Wild Horse & Burro Program: A Way Forward, National Academy of Sciences. 2013. (Emphasis added.)

Incurring additional costs to the already costly and inefficient BLM Wild Horse & Burro Program in order to enforce a number deemed arbitrary and unscientific by the nation’s leading scientific body seems counterintuitive and ill-advised.

We believe the Muddy Creek HMA AML could and should be higher. Aside from issues of genetic variability, we feel the size of the HMA can support many more animals than are allowed. Even with the population inflation projection on p. 6 of the EA for the end of summer 2018, there would still be 932 acres per animal on the HMA.


The Muddy Creek EA states that the proposed roundup is necessary “in order to prevent undue or unnecessary degradation of the public lands” (Muddy Creek EA p. 7). 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 wild horses. In the case of legitimate problems with the health of the range, it is critical for the PFO to take a look at all of the users of the land and their relative impacts, including livestock grazers.

According to table 3 provided in Section 3.3.1 of the EA, each of the 10 livestock grazing allotments in the Muddy Creek HMA is in use 5.5-7 months out of the year. The PFO provided a separate table noting the average AUM use for only five of the ten total allotments over the last six years. Those 5 allotments account for a total of 9,429 AUMs, with an average of 5,474 of those AUMS utilized over the last six years. Therefore, this EA alleges this rangeland can accommodate 10,948 cattle half of the year in extreme drought conditions, but that the HMA cannot withstand the impact of a projected 224 wild horses - and 10,948 cattle only accounts for half of the allotments in the HMA. We find this assessment to be extraordinarily misinformed.

Furthermore, we find it alarming that the Palmer Drought Severity Index placed the entire PFO in the “Extreme Drought” category in June 24, 2017 (Muddy Creek EA p. 12), but that livestock use will not be adjusted or revoked in any capacity.

“The authorized officer’s decision would not adjust livestock within the HMA, as this was set through previous decisions.”
Muddy Creek Wild Horse Herd Management Area Gather Plan, p. 10

We understand that the decisions about livestock grazing permits were made as a part of the PFO Resource Management Plan, and that an adjustment to these permits would be a part of a different process and are therefore are outside the scope of this EA. However, we feel it would be imprudent to make decisions about the costly and inhumane removal of 66% of this wild horse herd without considering the impact of tens of thousands of cattle that graze the Muddy Creek HMA. Furthermore, statements made in the EA about the grazing impacts of wild horses have been proven inherently unfounded:

“Available data also indicates that wild horse use – including where livestock use has been excluded – has resulted in excessive vegetative utilization."
Muddy Creek Wild Horse Herd Management Area Gather Plan, p. 28

A 2017 report by the Government Accountability Office (GAO) states:

“According to USGS officials and documentation, research that evaluates and separates cattle and wildlife impacts from wild horse impacts has not been conducted, and studies on horse grazing effects are needed.”
Animal Welfare: Information on the U.S. Horse Population, Government Accountability Office, Pg. 32.

Aside from the fact that the very reputable GAO explicitly states in a report less than a year old that the separate effects of cattle and wild horses on public lands are unexamined, it is unclear how wild horses could so disproportionately damage this land when they are outnumbered half the year at a minimum of 49 to 1.


We are appreciative that the PFO has such a forward-thinking approach to the use of fertility control to control the population growth of the Muddy Creek HMA wild horse herd, as noted in Alternative 2: Proposed Action. We are also appreciative of the PFO’s proposal to prioritize the roundup of young, highly adoptable animals. However, we hope that this office will consider the thousands of dollars of potential cost savings that would come from utilizing fertility control vaccines in conjunction with removal efforts, rather than only starting fertility control efforts after AML is reached. It seems short-sighted to opt for a costly roundup exclusively, with subsequent holding costs, when this office could immediately begin to slow the reproductive growth of this herd.

We believe a cost-effective, well-implemented population control plan in conjunction with roundup efforts would be much more beneficial for the PFO in the long-term. Population control efforts are much more humane than roundups, which would incur associated holding costs for 148 wild horses under Alternative 2: Proposed Action. Starting fertility control efforts only after the roundups have ceased could lead to a larger number of animals being rounded up over a longer period of time. 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 more than 930 acres per horse, would appear to allow for the use of fertility control vaccines simultaneously with smaller roundup efforts.


The Muddy Creek HMA wild horse herd is popular with wild horse advocates, photographers, and tourists. These horses provide an economic benefit through tourism dollars, both locally in Emery County and to the entire state of Utah.

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. If a roundup occurs, we hope the PFO will consider utilizing fertility control vaccines immediately, and in conjunction with roundup efforts, in order to save money and reduce the total number of animals that will need to go through the stressful experience of removal from their home range.
  2. We feel an adjustment to the AML for the Muddy Creek HMA is warranted. The AML should be adjusted upward to take genetic viability into account, as the current AML is not genetically viable by this office’s own admission.
  3. In implementation of this EA, 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 manage these public lands in a time of extreme drought.
  4. If a roundup does occur, we implore the PFO to reduce the number of horses they plan to remove so the herd remains genetically viable, without this office having to cart in animals from other HMAs.
  5. We hope this office will conduct roundups 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 Muddy Creek HMA 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

Kayah Swanson