15-Mile Herd Management Area Plan Update and Round Up Comments

Cameron L. Henrichsen
BLM Worland Field Office
101 South 23rdStreet
Worland, WY 82401

Subject: Fifteenmile Herd Management Area Plan Update and Wild Horse Gather

Dear Mr. Henrichsen,

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 theFifteenmile Herd Management Area Plan Update and Wild Horse Gather.

It is alarming to us that a roundup of this size has been proposed. We ask you to consider that removing roughly 300 wild horses from this HMA is a devastating proposal. This would be a 75 percent decrease in herd size, leaving only 100 wild horses on 70,527 acres, effectively rendering this herd genetically nonviable.


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 300 Fifteenmile HMA wild horses could condemn many of them to an uncertain and potentially lethal fate.

Additionally, the proposed removal of 300 horses – three quarters of the existing population - will render the Fifteenmile herds genetically nonviable. Equine geneticist Dr. Gus Cothran has long stated that in order to remain genetically viable, herds must consist of approximately 150-200 reproducing animals 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 2013Report: Using Science to Improve the BLM Wild Horse and Burro Program – A Way Forward (p.192)

"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."
National Academy of Sciences 2013 Report: Using Science to Improve the BLM Wild Horse & Burro Program - A Way Forward (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 both the nation’s leading scientific body and its foremost equine genetics expert would be counterintuitive and ill-advised.


We applaud you for increasing the Fifteenmile HMA AML, but we are concerned that this simple adjustment was made only to include foals in the total number. It does noteffectively increase the actual size of this herd. We believe the AML can and should be higher. Aside from issues of genetic variability, the size of this HMA can support many more animals than are currently allowed. 

The Fifteenmile Environmental Assessment states that “The removal of wild horses is needed because habitat conditions in the HMA, particularly water availability, will soon be insufficient to support the growing wild horse population.”Referring to Table 2 in the EA, the estimated population as of the November 2018 publication of this document is cited as 404 horses. The aforementioned quote implies that at a population of 404 wild horses, the habitat can and doessupport this herd. Insufficient resources, by your own words, need only be a concern if the wild horse population grows beyond this number. Therefore, AML can be increased to provide for a healthy, genetically viable herd.

We also question why this HMA retains only a paltry 70,000 acres of the 260,000 that were originally dedicated to these federally-protected animals? The return this originally designated acreage would allow for a stronger, healthier herd as supported by the Cothran statements cited previously. We question the legality of eliminating the majority of the Herd Area that was designated by the 1971 FRWHBA. If horses were roaming free on these lands when the Act passed, they should be a part of the present HMA. 

While we understand there are many challenges BLM faces in the management of America’s wild horses, we must point out that these animals belong to the American people whose tax dollars provide for their management and care. The BLM mandate per the 1971 WFRHBA states the horses:

“shall be managed as self-sustaining populations of healthy animals…”

Healthy herds cannot be maintained without each herd meeting the minimum standards for genetic variability (150-200, per Dr. Gus Cothran). And “self-sustaining” does not mean introducing mares from a different herd when genetic variability starts to suffer. These unique blood lines are not swappable. Instead, BLM has a responsibility to preventthat loss from happening in the first place. The HMA habitat has proven that itcansupport a genetically viable herd of 150-200, especially if acreage that was historically dedicated to these horses is returned to them. We call upon BLM to first and foremost consider its obligation as appointed caretaker to these wild horse societies and rise to meet the responsibilities they have been given.



While the Fifteenmile EA states that whatever decision is made, “the decision would not adjust livestock grazing use”, we strongly urge BLM to reconsider this position. The current forage allocation of 3,370 AUMS for domestic livestock and 2,300 AUMS for wild horses is grossly disproportionate, especially considering this is public land dedicated to this federally-protected species.

According to the EA, AML has never been adjusted to meet even the current meager and unfair forage allocation which is based on a population of 230 wild horses – your proposed new high AML. The forage allocation was established in 1998 – over 20 years ago – and has never been revised. These livestock allotments have been in “voluntary non-use” (EA pg 21) for several years, and within that time period, “Rangeland Health Standards are being met.” (EA pg 19) 

The BLM data that “97 percent of the public land acres within the HMA are meeting Standard 3 for Healthy Rangelands”, (EA pg 16) further validates the fact that a larger number of wild horses – theoretically as large as your current estimated population of 404 – can be sustained on this land with no negative consequences to the natural environment. Thus, we urge you to increase the unsustainable proposed low AML of 100-230 which does not allow for genetic viability. 

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, it would be imprudent to make decisions about the costly and inhumane removal of 75 percent of this wild horse herd without considering the fact that the rangelands are currently thriving in a healthy balance with well higher numbers of wild horses than AML allows for.


We believe that a well-implemented population control plan in conjunction with bait and water trapping - and using helicopter roundups only as a last resort – will greatly benefit the Fifteenmile HMA and the Worland Field Office in the long term. Fertility control can be applied in conjunction with the proposed roundup to start suppressing the growth of the Fifteenmile herd immediately. 

Population control efforts are inherently more humane and cost-effective than roundups and BLM has a duty to effectively use the tax payer dollars from which its budget derives. The costs associated with feeding and housing tens of thousands of once-wild horses in off-range corrals currently run into the tens of millions of dollars annually. This is fiscal irresponsibility of the highest level, as there are effective and far less costly solutions readily available. 

If an adjustment to the AML is considered in conjunction with proven fertility control efforts, it could result in the savings of millions of tax-payer dollars in the years ahead. The roundup and removal approach to management has consumed two-thirds of the BLM budget, over $52,800,000 in FY17. The program is over-budget, the roundup and removal plan is unsustainable, and Congress has tasked BLM to come up with sustainable solutions.

We understand it takes time for PZP to begin to control the population growth of a herd. However, since the rangeland supports the current population without degradation, it offers a perfect opportunity to start using fertility control vaccines simultaneously with smaller roundup efforts in order to curb population growth in the Fifteenmile herd.


The Fifteenmile herd is a classic example of the beauty and independent spirit embodied in our wild horses. Furthermore, these horses are a federally-protected wild species, living symbols of 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 out their lives on their dedicated land, in freedom as was provided for by the WFRHBA of 1971. These animals live in deeply bonded family bands within a complex society of intricate relationships. To rip them from their families and relegate them to life in a holding pen is inhumane and in opposition to the very spirit of the Act. 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 Fifteenmile HMA is warranted before the costly removal of any wild horses is undertaken. The AML should be adjusted upward to take genetic viability into account, as the current low AML for the HMA does not meet minimum standards for a genetically viable herd.

  2. We suggest restoring the original acreage to the HMA. The horse population should not suffer due to arbitrary exclusions of land that was designated for their use.

  3. In implementing this EA, we propose that the BLM take a science-based approach to revising the outdated forage allocation and low AML, taking into account the fact that “livestock grazing use within the HMA has averaged less than 1 percent of permitted use since 1984.” (EA pg. 21)

  4. If a roundup does occur, we implore these offices to reduce the number of horses removed to ensure the herd remains genetically viable.

  5. We hope this office will conduct roundups through the more humane method of bait and water trapping rather than the traumatic and injurious helicopter roundup method.

Thank you for the opportunity to offer our comments and, as always, we appreciate your willingness to listen to our thoughts. We believe that the Fifteenmile 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