Antelope and Triple B Complexes Gather Plan Assessment

August 17, 2017 Attn: Marc Jackson, Wells Field Manager

BLM Elko District Office

3900 Idaho Street

Elko, NV 89801


Subject line: DOI-BLM-NV-E030-2017-0010-EA

Antelope Valley & Triple B Environmental Assessment TCF Comments

Dear Mr. Jackson;

On behalf of The Cloud Foundation (TCF), a 501(c)3 non-profit 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 Antelope and Triple B Complexes Gather Plan Assessment.


  1. Appropriate Management Level:

It is our understanding that appropriate management levels in the two complexes have been set at 889-1678 horses for the Antelope & Triple B HMAs which is 3,007,743 acres in size. That is more than 1792-3383 acres per horse; an absurdly low level, which we feel should be amended dramatically upward. Even at the current estimated population of 7559 adult animals there are more than 397 acres per horse in the HMA.

The idea that these animals need to be removed to re-establish a thriving ecological balance is indefensible when there are so few horses on so much acreage. Again the AML is far too low for an area of such immense size and should be revised upward. And rather than continuously conducting roundups which attempt to maintain the unnecessarily low AML the BLM should fund a sustainable on the range management program utilizing the best fertility control methods available as recommended by the National Academy of Sciences in 2013.

  1. Decreased AMLs but increased HMA Size:

We request you provide an explanation for the changes in acreage in the Herd Areas over the years. And why, if the ranges increased in acreage, is there no increase in the AML? For instance in 1995 the acreage for Spruce-Pequop was 138,000 acres and the AML was 61 horses. Now the acreage is 223, 569 yet the AML is only 49-82. In 1995 Maverick-Medicine acreage was over 286,000 acres with an AML of 332, now it is 337,134 but the low AML is 166. BLM added 51k acres and reduced the AML by 56. In 1995 Goshute acreage was 250,800 and the AML was 160, now Goshute is 267,267 but the low AML is only 73. Antelope Valley is 97,070 acres and the low AML is 16. That is one adult horse for every 6,067 acres. In 1995 Cherry Springs WHT was 63,969 acres with an AML of 58, now Cherry Springs WHT is 23,794 acres with a low AML of 40.



  1. Genetic Diversity :

Despite the vast landscapes and millions of acres, the wild horse Appropriate Management Levels in four of the eight HMAs do not begin to meet the minimum standards for genetic diversity recommended by E. Gus Cothran, of Texas A&M University. He has indicated that 150-200 adult horses are necessary to maintain variability. Spruce Pequop has an AML range of 49-82, Antelope Valley AML is 16, Cherry Springs is 40 and Goshute is 73. Given the size of he HMAs and the available forage it is obvious that the horses will increase their reproduction rate to avoid extinction, a biological reaction called compensatory reproduction which was noted by the NAS in their report to BLM in 2013. When alleging overpopulation because the wild horse populations exceed AML, almost any reproduction will put the herd over AML when the limits are ridiculously and dangerously low.

If AMLs have been lowered due to range degradation, then historical sheep and cattle grazing data is essential to analyze which species have done the damage historically. We request that utilization information beyond what is included in this document be provided.

Although outside the scope of the EA it is important to raise the AML for Wild Horses in the Antelope and Triple B Complexes HMAs as the current AMLs are too low to maintain a healthy, genetically diverse for the Herd. With this in mind TCF supports alternative 2.6.5 Designate the HMAs to be Managed Principally for Wild Horse Herds Under 43 C.F.R 4710.3-2

TCF proposes starting an RMP process in the Antelope and Triple B Complexes HMAs in order to revise the AML for Wild Horses.

  1. Insufficient Forage and Water:

As to the claim that the data show that there is insufficient water and forage, it is nearly impossible to comprehend how this could be when there are more than 397 acres per adult horse in the HMA and many thousands of head of sheep and cattle.

If there is an issue with lack of water on an HMA the BLM offices which manage the Pryor Mountain HMA, and the Spring Creek HMA have elected to construct hillside water catchments, at relatively low cost and maintenance to ensure sufficient water for the wildlife present. These water catchments minimize evaporation by using large covered tanks at the bottom of a fenced area of black visqueen. These catchments are strategically sized and placed so that each tank is capable of accommodating a few horses at a time. The catchments are spread out to minimize impact to the forage available in the area and to encourage the horses to make use of underutilized areas of the HMA.

  1. Livestock Grazing 3.2.4


According to table 8 there are a mix of cattle, goats and sheep that are permitted to graze on the HMAs. If you break down the percent of Allotment in the HMA with the Ten Year Average AUM Use and the Season of use there is an annual average of 32508 AUMs in use in the HMA. This is a ratio of over 4:1 livestock to wild horses (7739 adult wild horses) in the HMA. How could there not be water and forage available for wild horses in the HMA if there is enough





water and forage for four times their AUMs in livestock? If livestock were at 100% of permitted AUMs they would outnumber wild horses by an even greater percentage.


If BLM chooses to remove wild horses from outside the HMA boundaries, all adult mares should be treated with fertility control and released back into the HMA. Any horses permanently removed should be only those 5 years of age or younger. These young horses should be offered for adoption. All stallions over 5 would be returned.


  1. Fertility Control:


3870 mares with PZP-22 and releasing them back into the HMA would have a positive impact on population growth if a comprehensive fertility control program is maintained in subsequent years. Leaving a post-gather population of 7739 adult horses in the 3,007,743 acres (only one wild horse for every 388.6 acres!) would ensure genetic viability in the Antelope and Triple B Complexes HMAs.


We cannot stress this point strongly enough: older animals removed (those over 5 years of age) could be sold without limitation if the President’s Budget is implemented. We realize the Secretary of the Interior is pro-slaughter as he acknowledged this as a Congressman in MT. This means that kill buyers would be allowed to purchase horses from your HMAs. 

We implore you to only remove young horses that have an opportunity to become human partners. It is the only humane alternative. 

It is our belief that an action with the scope and longevity of this one requires examination within the thorough analysis of a Resource Management Plan (RMP).

  1. A Humane Way Forward

The following are suggestions on how to proceed in a humane way with management of wild horses in the Antelope and Triple B Complexes HMAs.

  • Apply PZP or PZP-22 or Gonacon or a combination of both to all adult mares.
  • If a helicopter roundup is needed to capture most of the horses in the herd, then wild horse bands should be brought in discretely, with a sorting process to keep the bands intact. We know this can be done as it has been accomplished in the past in several BLM-managed herds.
  • All horses returned to the HMAs will be cataloged in their bands and photographed with data entry by volunteers under the direction of the BLM team present at the roundup site. All data will be entered into HorseBase, a Windows program specifically designed to keep track of wild horses. (HorseBaseis a wild horse documentation spreadsheet that was created for the Sand Wash Basin, Colorado, wild horse herd, but can be used for any herd. It is very easy to understand and use, yet has significant search capability.)
  • Only horses five years of age or under will be removed, as was the case in decades past. They will be sorted from their family bands or from their bachelor bands. We strongly suggest that no horses over the age of five be retained.
  • Once any adoptable young horses are removed from a band, the remainder of the band will be released intact to avoid the chaos of reordering the family groups. Older wild horses

will not be removed. They have little chance of adoption and face the very real possibility of being killed or sold to kill buyers per the sale with out authority option.




  1. Horse Gentler Project: 

We suggest that a plan be devised for each herd in the complex similar to the Beaty’s Butte model. However, horse gentlers would be compensated as in the TIP program—i.e. after the successful adoption of that animal.

I am confident you have talented horse trainers in your region. Allowing them to halter train young mustangs and make a profit from the successful adoption of their young horses will stimulate local economies and will give the young horses a greater chance to find homes, whether it be in NV, UT or back East.

Yearling mustangs who are removed can be ideal projects for “junior gentlers” -local 4H/FFA and any youth horse clubs in the area. A qualified volunteer or a BLM employee would carefully vet potential youth mustang gentlers, as well as their adult counterparts.

If an adoption market does not exist in Nevada for the halter-trained mustangs, BLM (with the help of volunteers) would arrange for transport of young halter-trained mustangs to appropriate locations in the East where the market does exist. Fleet of Angels director, Elaine Nash has indicated that the thousands of haulers in her Fleet would agree to haul at reduced rates to either pick up points for adopters or facilities where these young horses can be housed, advertised, and/or receive additional training.


The Mustang Heritage Foundation should be consulted on how they can help in this endeavor, and TCF would try to assist as much as possible. Holly Hookes with BLM is an invaluable resource on adoption, of course.


  1. Field Darting/Trapping/Habituation:

Mature mares would be returned to the range once they have received dartable or hand-administered PZP or PZP-22. Subsequent treatments would be conducted in the field. Field darting or bait trapping would be carried out by certified BLM and/or volunteer darters. Darting can be implemented while mares are in a bait trap. Once habituation to humans has altered their fear response, mares can be darted in the field.

The process of habituating wild horses and burros to the presence of humans needs to begin now. Volunteers can take to the field to let the horses see the presence of humans as benign. In Sand Wash Basin in Colorado, the habituation process took only a few years. I remember visiting Sand Wash a couple of years ago and being able to view horses only from a distance through binoculars and, even then, they were moving away from me. Now, humans can walk around them within dartable distances in almost all cases. A link to Sand Wash Rendezvous story is here. (Rendezvous)


  1. Data Systems/High Tech Solutions:

As with the trap site information, volunteers will enter all field-data into HorseBase. Users can keep track of bands, their locations, and any changes in the makeup of the band, as well as fertility methods applied to individual mares with times and dates of application, which hip was darted, did the dart fall out, etc. Photos would have GPS coordinates in the metadata of each shot,



so the water sources and each band can be mapped. Drones can be used to map locations of mustang bands and burros. Trail cameras can reveal the movements and identity of bands in areas with trees or other structures where a mountable camera can be attached.

Each herd would have a dedicated volunteer who would view and organize live action footage on a YouTube Channel which is dedicated to Drone footage, and perhaps a second YouTube Channel dedicated to Trail Cam live action footage.


We believe the most important and prudent course of action is to begin the RMP process so that a genetically viable Wild Horse Population can be established and sustainably managed. In the meantime we suggest that there be no Wild Horse removals. If immediate action is required to preserve forage on the HMA we suggest temporarily limiting livestock grazing. Livestock grazing is a privilege, not a right. It is within the authority of the BLM to take action to limit grazing when required to preserve the health of the range.

Thanks again for the opportunity to comment. Don’t hesitate to give us a call to discuss any of the points we’ve included.



Ginger Kathrens

Executive Director

The Cloud Foundation, Inc.

107 South 7th Street

Colorado Springs, CO 80905

719 633-3842



TCF CommentsJesse Daly