North Lander Complex Scoping Comments

Mr. Clay Stott, Wild Horse and Burro Specialist
BLM Lander Field Office
1335 Main Street
Lander, Wyoming 82520

Subject: Wild Horse Herd Management Plan and Wild Horse Gathers in North Lander Complex

Dear Mr. Stott,

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 Wild Horse Herd Management Plan and Wild Horse Gathers in North Lander Complex.

This scoping document’s proposals are alarming to us. We implore you to consider that removing up to 1,029 wild horses from this HMA to achieve low AML is a devastating proposal that will wreak havoc on this herd. This would be a 76 percent decrease in herd size. Additionally, the sterilization experiments proposed in this document are absurd and inhumane.


 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 up to 1,029 North Lander Complex HMA wild horses could condemn many of them to an uncertain, and potentially lethal, fate.

Additionally, we believe the North Lander Complex AML could be and should be higher. A low AML of 320 is absurd in an area made up of 380,000 acres. The current population estimate of 1,942 horses translates to almost 200 acres per horse, and provides the wild horses with an adequate forage base while leaving resources for other wildlife. We also feel this current population estimate is wildly overestimated. The low AML translates to nearly 1,200 acres per horse, which simply isn’t necessary for these animals to thrive, particularly considering the capacity of this area to support many more horses than less productive habitats in Utah and Nevada for instance.


We are extremely concerned about this scoping document’s proposal to use dangerous sterilization experiments on the North Lander herds. Currently, we’re seeing the BLM on a national level advocate for the use of a sterilization procedure called “ovariectomy via colpotomy," which rips the ovaries out of mares and jennies, and has shown to be extremely dangerous even in sterile conditions. The procedure has a high complication rate, causes behavioral changes and loss in bone density, and can be lethal according to expert equine veterinarians.

“In private practice, colpotomy is considered an inferior procedure with likelihood of post-surgical infections and complications (i.e., colic) especially in unsterile conditions. Post-operative care usually lasts several days, often weeks. In most cases, mares are monitored in box stalls or cross ties, which cannot be accomplished with wild mares.”
Dr. Don Moore, Equine Veterinarian.

This sterilization procedure is barbaric. Most veterinarians won’t even perform it in a sterile environment. Additionally, the creation of sterilized herds is something that has been struck down by the courts.

The BLM previously proposed the creation of a non-reproducing herd in the Saylor Creek Herd Management Area in Idaho. After a lawsuit was filed by plaintiffs including The Cloud Foundation, a District Court Judge struck down the BLM’s decision to manage herds in that way, citing a lack of effort on BLM’s part to understand the long-term effects of the management strategy they were proposing:

“… preventing births and reproductive capacity of the horses alters wild horse behaviors and the social structure of the herd. …. The NAS Report concluded that ‘absence of young horses itself would alter the age structure of the population and could thereby affect harem dynamics.’ …. Accordingly, the Court concludes the Defendants have violated NEPA by failing to take a hard look at these important aspects of its decision and failing to disclose and analyze the NAS Report in the FEIS.”
Case No. 1:16-cv-00001-EJL. United States District Court for the District of Idaho, 2017. Pg. 21-23.


We do not agree with this document that the use of GonaCon is a good management proposal. We feel that more emphasis should be placed on applying the safe, tested, and proven fertility control vaccines PZP or PZP-22 to the North Lander Complex HMA. According to our records, PZP was applied to the North Lander Complex herds but reapplication has not been done. This is very unfortunate, as a study in Cedar Mountain, UT has shown that reapplication of PZP is very effective in controlling wild horse populations on-range for far longer than anticipated. These efforts are also far less costly than the roundup and holding costs this scoping document proposes.

With this in mind, the cost of fertility control 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 with PZP costs about $30 a dose. Darting of mares with the successful, long-lasting PZP-22 is about $400 per dose.

We also suggest that an effort is made to keep the family bands together as much as possible during bait trapping and darting efforts. That will allow for the creation of a complete roster of the herds through careful photo documentation. Also, keeping the horses together will reduce the melee of regrouping into subsequent bands, which creates instability that can lead to more breeding and is counterproductive to reducing births.

We believe a cost-effective, well-implemented population control plan for the North Lander Complex is far cheaper and more humane than a roundup, which will incur associated holding costs for up to 1,029 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 and PZP-22 to begin to control the population growth of these herds, but the current population would appear to allow for a long-term, cost-effective, on-the-range management solution.


The wild horse herds in the North Lander Complex are extremely popular with wild horse advocates, photographers, and tourists. These horses provide an economic benefit through tourism dollars, both locally in Fremont County and to the entire state of Wyoming.

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, as the framers of the Act intended. BLM has tools at their disposal to manage this population on the range without removing them.


  1. We propose this office place an emphasis on the use of PZP-22 and native PZP as population management tools in lieu of massive, costly and inhumane removals.
  2. We feel an adjustment to the AML for the North Lander Complex HMA is warranted. In particular, the low end of the AML should be adjusted upward.
  3. This office should not consider the use of sterilization techniques to manage these herds.
  4. We propose that the BLM investigate the range impacts of all of the land users including livestock, not just wild horses when performing the extremely important task of monitoring and protecting rangelands.
  5. If a roundup does occur, we implore the BLM to reduce the number of horses they plan to remove. We would also ask the BLM remove 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. I believe that the North Lander Complex 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