Eagle Complex Roundup Preliminary Environmental Assessment

Chris Carlton, Field Manager
BLM Caliente Field Office,
PO Box 237
1400 South Front Street
Caliente, NV 89008

Subject: Eagle Complex Wild Horse Gather Preliminary Environmental Assessment

Dear Mr. Carlton,

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 Eagle Complex Wild Horse Gather Preliminary Environmental Assessment.

It is alarming to us that a roundup of this size has been proposed. We implore you to consider that removing 2,075 wild horses from this HMA is a devastating proposal. This would be a 90 percent decrease in herd size, leaving only 145 wild horses on 743,042 acres, effectively rendering this herd genetically unviable.


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 2,075 Eagle Complex wild horses could condemn many of them to an uncertain, and potentially lethal, fate.

Additionally, the proposed removal of 2,075 horses will render the Eagle Complex herds genetically unviable. This proposed removal to a population of 145 horses, as previously stated, would be a 90 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)

If the sole reason these two field offices are proposing roundups of these animals is to achieve AML, we suggest these offices 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 Eagle Complex 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 estimate of 2220 including the 2017 foal crop, there are still 334 acres per animal in the complex. The low AML for this complex allows for an incredible 5,124 acres per animal.


The Eagle Complex Preliminary EA states that the proposed roundup is to “protect rangeland resources and to prevent unnecessary or undue degradation of the public lands” (Eagle Complex 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 these two field offices to take a look at all of the users of the land and their relative impacts, including livestock grazers.

According to table 3.2 provided in Section 3.3.5 of the EA, four of the eight livestock grazing allotments in the Eagle HMA alone are in use year-round. According to this table, the average use of those four allotments accounts for an incredible 27,602 AUMs used on average per year over the last decade. How is it that this office has determined the Eagle HMA can sustain AUMs equivalent to 55,204 cattle or 138,010 sheep year round, but can only sustain an AML of 100-210 wild horses? The other four allotments in the Eagle HMA are in use between five and ten months per year, and account for an additional 1,208 AUMs used on average. And these numbers don’t even represent the number of livestock AUMs granted by this office, just the average use. It is unfathomable to us that a determination was made that this land can support more than 55,000 cattle or more than 138,000 sheep but cannot sustain more than 210 wild horses.

According to table 3.3 provided in Section 3.3.5 of the EA, there are 1,581 AUMs in use for part of the year in the Chokecherry and Mt. Elinore HMAs. This number yet again accounts for an exorbitant amount of livestock on a parcel of land the BLM says can only sustain AMLs of 30 and 15 wild horses, respectively. We find this assessment to be extraordinarily misinformed.

We understand that the decisions about livestock grazing permits are not a part of this particular EA’s jurisdiction, 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 90% of this wild horse herd without considering the impact of hundreds of thousands of livestock that graze the Eagle Complex. Furthermore, statements made in the EA about the grazing impacts of wild horses have been proven inherently unfounded:

“Monitoring indicates that the current overpopulation of wild horses is causing resource degradation…”
Eagle Complex Wild Horse Gather Preliminary Environmental Assessment, p. 20

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 year round on the land at a minimum of 25 to 1. Further, the EA states:

“…there is insufficient water and forage for the number of horses present, resulting in their movement to public and private lands that are not managed for wild horses, and posing a public safety risk along Highways 93, 318, 322.”
Eagle Complex Wild Horse Gather Preliminary Environmental Assessment, p. 20

We believe it would be unfounded for this office to fail to consider that perhaps these horses are having to search outside the Eagle Complex for forage and water because they are sharing the land with hundreds of thousands of non-native grazing livestock.


We are appreciative the forward-thinking approach of these field offices in that all proposed removal actions include the immediate use of fertility control to control the population growth of the Eagle Complex wild horse herds

We believe a cost-effective, well-implemented population control plan in conjunction with roundup efforts will be more beneficial for these offices in the long-term, as fertility control will be applied in conjunction with roundups to start suppressing the growth of these herds immediately. Population control efforts are much more humane than roundups, which also, as you know, incur associated holding costs for a program that is already far over budget.

We are hopeful that an adjustment to the AML will be considered in conjunction with these fertility control efforts. The roundup and removal approach to 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 300 acres per horse, would appear to allow for the use of fertility control vaccines simultaneously with smaller roundup efforts in order to curb population growth in the Eagle Complex.


The Eagle Complex wild horse herds are popular with wild horse advocates, photographers, and tourists. These horses provide an economic benefit through tourism dollars, both locally in Lincoln County, NV and Iron County, UT, as well as for the entire states of Nevada and 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. We feel an adjustment to the AML for the Eagle Complex is warranted before the removal of any wild horses. The AML should be adjusted upward to take genetic viability into account, as the current low AML for the individual HMAs and the entire complex are not genetically viable.
  2. 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.
  3. If a roundup does occur, we implore these offices to reduce the number of horses they plan to remove so the herds remain genetically viable.
  4. 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 Eagle 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