Brian Novosak, Field Manager Northern California District

Eagle Lake Field Office

2550 Riverside Dr, Susanville, CA 96130 

Subject: Twin Peaks Herd Management Area Wild Horse & Burro Gather Plan 

Dear Mr. Novosak, 

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 Twin Peaks Wild Horse & Burro Gather Plan: DOI-BLM-CA-N050-2019-0011-EA. 

It is alarming to us that a removal of this size has been proposed. We implore you to consider that removing 3,058 wild horses and 560 wild burros from this HMA is a devastating proposal for the Twin Peaks herds and for the American taxpayer. This would be a 91 percent decrease in herd size, leaving only 448 wild horses and 72 wild burros on 789,852 acres, rendering each distinct herd in their “home range” genetically unviable. (Table 1-1, DOI-BLM-CA-N050-2019-0011-EA, Pg. 4) 


First and foremost, we are concerned about any proposed removal on any Herd Management Area, nationwide, especially after the National Wild Horse and Burro Advisory Board meeting of 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 3,058 Twin Peaks wild horses & 560 burros could condemn many of them to an uncertain, and potentially lethal, fate. 

The Cloud Foundation generally opposes helicopter roundups. Helicopter roundups are inherently traumatic for the animals, often resulting in injuries and deaths. Foals are left behind or run until they can’t walk. Mares abort their foals as a result of the stress and previously healthy horses are euthanized due to “previously existing conditions”, which only occur as a direct result of being terror-stricken and stampeded for dozens of miles by a helicopter. 

We strongly encourage BLM to employ large bait and water traps instead. This is a far more humane alternative and can easily be done over time. With such a vast HMA, the land can be divided into parcels, each with its own trap. The traps could be quite large, and could even be permanent fixtures, as the removals will take place over the course of the next ten years. Since there is no imminent danger to the animals or the land - as noted in the EA, very few horses are in poor body condition - this more humane option is more cost effective and more likely to be supported by the American public and advocate groups. 


If helicopters are to be used, we would argue that small cameras, such as a GoPro or similar device, should be attached to the front of the aircraft. A precedent for this has been set in law enforcement, where dash cams and body cams have become the norm. In 2012, a U.S. Court of Appeals ruled that photojournalist Laura Leigh should be allowed unrestricted access to document a wild horse roundup in the Silver King 

HMA. They noted that restricting her access was unconstitutional, and an infringement upon the public’s right to observe their government in action. ( horse-roundup/) In a 2018 lawsuit in Burns, Oregon, a federal court judge also upheld the public’s right to meaningful observation of government projects, in this case a highly controversial experiment to spay wild mares in a procedure called ovariectomy via colpotomy. 

A concrete precedent has been set to argue that meaningful observation of government activities, BLM helicopter roundups included, is a first amendment right. In order for observation of a roundup to be meaningful, opportunity to observe must be provided from the start of the roundup to the finish; from the time the helicopter engages wild horse bands to the time they are driven into a trap. We now have simple, affordable technology readily available to provide such an experience. The Cloud Foundation even offers to purchase cameras to collect footage of this roundup - if it takes place - in order to allow for meaningful observation by the general public. If BLM and their preferred contractors have nothing to hide, there should be no viable argument against this type of observation. It will allow the American public to see clearly how wild horses and burros are treated during a helicopter roundup, hold the operators to humane standards, and go a long way in creating transparency between the American government and the citizens it serves. 


Given the fact that the home ranges are fenced or separated topographical boundaries, it’s clear that an adjustment to AML is necessary. The proposed removal intends to reduce and maintain each subpopulation to their low AML, which ranges from 46 at the low end to 155 at the high end in each individual “home range” of the HMA. Of the five, discrete home ranges, only one would be left with a population that would meet the minimum standard for genetic variability. The other four sub-populations are far below the scientific standard for a minimally viable population. 

We do understand that gates are left open in the winter, after livestock have been removed and that in some spots, lower fences and wooden stiles have been inserted. In an HMA of roughly 1200 square miles, horses might have to navigate hundreds of miles to stumble upon a gate that would allow the distinct herds to intermingle. The idea that horses would jump a fence, even a low one, in order to cross from one area of this vast range to another, is an odd one to anyone with a real knowledge of equine behavior. We acknowledge that crossover may occur very occasionally by individuals such as bachelor stallions. However, without significant motivation, i.e. life-threatening circumstances such as a lack of water, these herds will stay within the boundaries of their homerange and have little opportunity to increase their genetic variance. 

Respected equine geneticist, Dr. Gus Cothran, has long stated that in order to maintain genetically viable populations, herds must have 150-200 adult animals at a minimum. This means that each distinct home range herd must be managed at the minimum genetically viable number of 150-200 individuals in order to be a “healthy, self-sustaining” herd, as mandated by the 1971 Wild Free-Roaming Horse and Burro Act. 

The BLM-commissioned National Academy of Sciences Report from 2013 strongly suggests that the agency should use Dr. Cothran’s work to inform the management of our wild 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) 

We also suggest that the 2013 NAS report findings be considered regarding AML: 

"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.) 

Dr. Gus Cothran noted in his 2011 genetic assessment of the Twin Peaks horses that “Observed heterozygosity in the Twin Peaks HMA herd is below the feral mean...” and that “Current variability levels are high enough that no action is needed at this point but the heterozygosity levels are near concern values.” (emphasis added) 

Lacking the minimum levels of genetic variability, we are likely to see these herds disappear over time. Ideally, the fences that keep the wild horse herds within their “home ranges” much of the year should be removed. We understand this is unlikely to happen as long as the HMA is managed for livestock first. Thus, the Twin Peaks home range AMLs must be higher in order to preserve a healthy level of genetic variability - which was already a concern in 2011. Maintaining these herds at such low population levels ensures their eventual extirpation or, at minimum, ill health in the years to come as a result of forced inbreeding. 

In addition to the AML’s being too low, the population is likely far smaller than the EA suggests. An independent aerial population estimation was conducted in 2017 by Johnston et al. The population was estimated through the “aerial, straight-line-strip-transect“ method, often used by population ecologists. (Link to the Johnston et al. 2017 report of the survey: content/uploads/2018/03/Twin-Peaks-Flight-Report-2017-1.pdf) 

This population estimation concluded that there were under 841-1,111 horses & 97-128 burros in Twin Peaks at the time of the survey. This number is far below the BLM projections for the same year. Given the large difference between the two counts, conducted through different methods, we suggest averaging the results of the two counts. We know that there will always be inaccuracies in estimating populations of wild species, but given what is at risk - the health and even survival of our historic wild horses and burros - we feel that erring on the side of caution would be prudent. This would also allow BLM to remove far fewer horses and burros, or to release more horses and burros back after treatment with fertility control. 


Five subpopulations are identified in the EA. However, since these subpopulations are either fenced in or confined by natural boundaries and there is little interchange, each subpopulation needs to be considered as an individual herd. This means that to maintain genetic diversity in each isolated population, 150-200 adult individuals needs to be the minimum AML for all five subpopulations (Cothran 2013; Singer 2000). 

However, If the BLM insists on managing subpopulations at these incredibly low numbers, immigration and emigration in and out of these populations needs to be made possible to foster gene flow and maintaining 

genetically viable healthy horses. To facilitate this movement, corridors could be created at frequent intervals in the fencing to connect the five subpopulations and can be laid out in such a way to manipulate wild horse distribution. 

A case can easily be made for the wild horse population in the Twin Peaks HMA to be considered a metapopulation. Smaller populations, like Dry Rally Rim, or Observation South, would be able to rely on input from the larger subpopulations, whereas the large subpopulations will experience release of pressure due to emigrating individuals. This theory of mutualism between subpopulations is called “Source-Sink” (Dias 1996). Source populations, where births outweigh deaths, rely on the emmigration of individuals to relieve pressure on resources. Sink populations, where deaths often outweigh or equal births, rely on the immigration of individuals for genetic diversity and resilience, known as “The rescue effect” (Dias 1996; Eriksson et al. 2014). 

These sophisticated interactions, considered crucial by wildlife population ecologists, need to be studied carefully before the entire population is subject to human-induced changes, and can be used as a helpful management tool. We urge the BLM to take into consideration the positive effects of creating corridors between subpopulations on the management of the entire population as a result of the establishment of source-sink relationships. 

Once source-sink relationships between distinct herds in Twin Peaks are established, only then can smaller populations fall slightly below their minimum viable population, since it will be supplemented with individuals from larger populations. The source populations, on the other hand, will need to have more individuals than the minimum viable population to form a buffer against emmigration. 

In conclusion, the AML’s that are desired by the BLM can only sustain healthy and genetically viable herds if a network of corridors between the “home ranges” is established. 


The Twin Peaks WHB Gather Plan states that the proposed roundup seeks to “protect rangeland resources from undue and unnecessary degradation and restore a thriving natural ecological balance and multiple-use relationship on BLM-administered public lands in the area...” (DOI-BLM-CA-N050-2019-0011-EA pg 4). 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 this field office to take a look at all of the users of the land and their relative impacts, including livestock grazing. 

According to bullet 1.6 on page 5 of this EA: Conformance with Rangeland Health Standards and Guidelines, BLM itself has completed land health assessments with the Twin Peaks HMA between 2000 and 2018. The result of these studies show, by BLM’s own statement, that the causes(defined as the “predominant current factor”) of sites not meeting standards are: “wildfire, activities on adjacent private lands, and historic (pre-1970’s) livestock grazing.” As this is the stated cause, we find it to be illogical that the BLM is not addressing and remediating these causes directly, but is instead rounding up thousands of animals which have not been cited as a predominant current factor for the rangeland not meeting standards. 

This section of the EA goes on to state that “high amounts of grazing and trampling” in riparian areas are a result of “excess numbers of wild horses and burros in the HMA.” However, there is a lack of citations from studies that prove this. It seems that there is no evidence in the EA that shows wild horses and burros are the sole cause of rangeland degradation in Twin Peaks, specifically caused by trampling, which could well be caused by livestock too. 

Endangered riparian areas have been identified in the EA. However, there is little mention in the EA of the possible construction of additional water catchments to alleviate pressure on riparian areas. Catchments have been used in many different HMAs with great success, such as the Pryor Mountain Wild Horse Range and the McCullough Peaks. Water catchments can also be used to manipulate wild horse, wild burro, livestock and wildlife distribution, thus not only protecting water availability in riparian areas, but allowing for recovery of trampling and soil compaction as well. 

It would be impossible not to acknowledge the diminished quality of America’s western rangelands due to climate change, human disruption of fragile ecosystems, and usage by multiple stakeholders. That being said, the way in which horses use the land differs greatly from the way cattle do, and thus their impact is very different. 

One difference between cattle and wild horses is that horses tend to use areas more heterogeneously than cattle. Wild horses typically create a set of trails used to travel the landscape, whereas cattle use the whole area in similar intensity (Beever 2003). Horses also restrict themselves to a set of trails when travelling to or from water. Consequently, horses move further away from the water at a much higher speed than cattle, which use trails far less frequently. Additionally, cattle generally stay in close proximity to the water throughout the dry season, whereas horses do the contrary and move on after they drink their fill (Beever 2003). 

Horse droppings are biodegradable and enrich the soil, whereas cattle droppings have high concentrations of methane and are highly digested, leaving little nutrition for the soil and are a major contributor to global warming. A United Nations Food and Agricultural Organization report titled “Livestock’s Long Shadow” states “Livestock production is responsible for a greater proportion of anthropogenic emissions than the entire global transportation sector” ( If we are truly looking at causes of rangeland degradation, there is a strong case to be made for removing privately owned livestock from our public lands entirely. 

According to BEEF. Magazine, the average weight of cattle has increased almost 20% over the past 20 years, leaving a larger impact on the environment per individual. However, the AUM’s for livestock in Twin Peaks have not changed since the 1990’s. As far as our knowledge stretches, we have not heard of any changes in the average weight of wild horses, yet their AUM has remained the same. 

In the 2010 Twin Peaks EA, the reduction of the AUMs for livestock was rejected because livestock can be managed “in time and intensity”, whereas horses are on the range all year long. However, when livestock in this HMA is regarded as one entity, it seems to occupy the HMA almost year-round (fig 1.1). The EA also stated that “reducing livestock AUMs to increase wild horse and burro AMLs would not achieve a thriving natural ecological balance”, for it would simply replace cattle with horse presence. But, surely, if wild horses 

were to be managed with humane fertility control entirely on the range, their numbers could not possibly increase to the current level of livestock that now use the area. Thus, previous arguments made against reducing the AUMs for livestock and increasing AML, seem to be invalid. 

Schermafbeelding 2019-07-18 om 9.12.09 AM.png

Fig 1.1. Prepared by WHFF, based on data from BLM Rangeland Administration System Data. 

It must also be taken into account that horses and cattle impact a landscape in very different ways. This point must be considered carefully, because tackling the wrong problem will never provide an effective solution. To draw a single line between rangeland degradation and wild horse occupancy would be a false conclusion. 

This is a multifaceted problem that cannot, should not and will not be successfully solved by a single narrow-minded solution. Rounding up thousands of wild horses and burros addresses a minor contributing factor to the greater meta-problem. Instead, we need a multi-faceted, thoughtful and creative solution that addresses all of the contributing factors. As the predominant factors have been identified in this EA as “wildfires, activities on adjacent public lands, and historic (pre-1970’s) livestock grazing” (Pg 4), those issues should be addressed and remediated first. 

Horses can also have a positive effect on the landscape. Given the many wildfires that have occurred in Twin Peaks HMA, allowing horses to graze the dry, flammable vegetation, which cattle will not eat, would reduce the amount of flammable fuel. A possible correlation can be made between the Rush Creek Mountain fire in 2012, and the removal of over 1000 horses two years earlier. Many different areas throughout the world have used large grazers, including horses, to open up the landscape for reasons such as creating a specific habitat (like bird habitat), foster a more biodiverse landscape, and prevent large, detrimental wildfires due to fuel-buildup. A specific benefit of large grazers like horses is that thinning the understory vegetation enables light-demanding trees like juniper, aspen, pine, and cottonwood, as well as 

many shrub species, like black sagebrush, to flourish (Vera et al. 2004; Staver et al. 2009), consequently creating a more fire-resistant ecosystem. 

We suggest the BLM to take into consideration the opportunities to use wild horse grazing as a fire suppression tool, and the challenges the agency will face if horse grazing is severely reduced. We would hate to see a repeat of the tragic fires of 2018 which destroyed not only the town of Paradise, displacing thousands of people, but it decimated thousands of acres of native vegetation and killed countless wildlife, leaving a severely damaged ecosystem. 


We appreciate the forward-thinking approach of these field offices in that two of the four proposed alternatives include the immediate use of fertility control to control the population growth of the Twin Peaks wild horse and burro herds. We strongly suggest that gelding be avoided, as this can cause additional problems with herd dynamics and affect the stallions “wild free-roaming behavior”, a direct contradiction of the 1971 Act. 

Humane, reversible fertility control methods have been available for many years. While we understand this HMA is vast, employing teams of volunteers to document and dart the horses in each home range is one possible solution and The Cloud Foundation would be happy to assist in the development of such programs. Humane fertility control is not only cost-effective, it’s a plan that would be supported by both the public and the advocate communities. 

We concede that it does take time for humane fertility control to begin to control population growth. However, the HMA rangelands, with their current population of horses and burros, is supporting the animals at adequate levels. This EA states that very few horses have been observed to be in poor body condition. 

Small, strategic bait and water trap removals can also be implemented to reduce the burden on the land in a much more humane way. Helicopter roundups are horribly traumatic to the animals, exorbitantly costly to the taxpayer, and incur additional associated medical & holding costs for the program. 

The roundup and removal approach to management has consumed two-thirds of the BLM budget; the United States now keeps over 50,000 once-wild horses and burros in corrals at enormous expense to tax-paying citizens. There is also much evidence to support the fact that large removals only cause population numbers to explode in a phenomenon called compensatory reproduction. Thus, the BLM has caused, rather than mitigated, the very “problem” it has been seeking to “solve” since America’s wild horses and burros were placed in their care in 1971. 

Incurring additional financial burden to the already costly and mostly 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 strongly suggest that BLM instead implement large-scale fertility control programs coupled with small bait trap removals over the next ten years. 


The Twin Peaks wild horses and burros are beloved by advocates, photographers, and tourists alike. One of The Cloud Foundation’s board members, Jamie Baldanza, recently spent more than a week documenting 

these herds for her upcoming docu-series showcasing America’s wild horses. Once this series launches to a nation-wide audience, it is likely that public interest will grow. When this same audience learns that thousands of these same wild horses were rounded up shortly after filming, it is likely to cause a public outcry. BLM has an opportunity to preserve and protect an American cultural resource and increase the potential for tourism and economic growth in the surrounding areas. 

Let us also not forget, 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 magnificent, spirited creatures; they are survivors who deserve the opportunity to live their lives in their homeland, with their families. BLM has the authority and tools to manage these animals on the range without removing them. 


  1. We feel an adjustment to the AML for Twin Peaks is warranted before the removal of any wild horses and burros. The AML should be adjusted upward to take genetic viability of each home range into account, as the current low AML for the individual home ranges leaves each herd well below the level of genetic viability.

  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 and burros, in order to appropriately and ethically manage these public lands.

  3. After identifying all the causes of land degradation, we suggest a multi-pronged solution be created. One of which should be limiting livestock, specifically sheep, on the HMA by lowering the AUM, or put a temporary stay on livestock grazing in part of the HMA. As a result of this, more horses and burros should be allowed to stay on the range, and less will need to be removed during the proposed roundups. This will ensure that livestock and horses will have equal access to the resources, and that pressure on the landscape will be released.

  4. A second part of the solution would be manipulation wild horse distribution to ensure gene flow, maintain healthy, self-sustaining herds, and allow the ecosystem to flourish. Corridors between home ranges are to be established so that wild horses and burros can easily travel throughout the entire HMA (which would not include low fences or remote gates). Additionally, water catchments should be installed throughout all the home ranges to protect endangered springs and riparian areas by manipulating wild horse, wild burro, livestock and wildlife distribution.

  5. Since an independent population survey returned a much lower total population estimate, this count should be averaged with BLM population projections to ensure that too many animals are not removed, endangering the very survival of the herds.

  6. If removals must occur, we implore this office to reduce the number of horses they plan to remove so the animals in each home range do not suffer ill health in the future as a result of low genetic variability. Unless corridors can be established to create a free flow between all the “home ranges” and foster the exchange of individuals, we fear eventual extirpation of these tiny herds. 

  7. We strongly suggest this office conduct removals through the more humane method of bait and water trapping rather than traumatic, injurious and often lethal 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 Twin Peaks HMA presents a special opportunity to showcase forward-thinking, cost-effective, humane wild horse management. The Cloud Foundation officially offers to provide help 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 

Elke Tukker