Comments: Pine Nut Mountain Preliminary EA

Bureau of Land Management
John Axtell, Wild Horse and Burro Specialist
5665 Morgan Mill Road
Carson City, NV 89701

January 21, 2017

Comments: Pine Nut Mountain Preliminary EA DOI-BLM-NV-C020-2016-0020-EA

Dear Mr. Axtell:

On behalf of The Cloud Foundation (TCF), a 501(c)3 non-profit corporation, on behalf of our thousands of supporters throughout the United States; we would like to thank you for the opportunity to comment on DOI-BLM-NV-C020-2016-0020-EA.

The Pine Nut Mountains HMA encompasses approximately 90,900 acres of public lands and 14,692 acres of private lands. The Pine Nut HA consists of approximately 183,186 public acres and 68,504 private acres. The wild horse population based on 2016 population inventory estimates 579 wild horses (536 seen), 357 inside the HMA and 222 outside the HMA.

The purpose of the proposed 10-year plan is to address the following: Prevent degradation of public lands within and outside the HMA Address wild horses residing outside the HMA Address long term population trends within and outside the HMA Manage wild horses in a manner that supports meeting the Bi-State sage grouse habitat objectives.

We would like to re-emphasize the comments submitted by The Cloud Foundation on July 16, 2016.

The Cloud Foundation is strongly opposed to helicopter roundups and removals of wild horses from the range and supports “on the range management” of wild horse herds to manage wild horses. In doing so BLM can save taxpayers millions of dollars by avoiding inhumane and expensive helicopter roundups and warehousing of wild horses in overcrowded BLM holding facilities.

Furthermore, according to the National Academy of Science report: Using Science to Improve BLM Wild Horse and Burro Program, “it is clear that the status quo of continually removing free-ranging horses and then maintaining them in long-term holding facilities… is both economically unsustainable and discordant with public expectations.”

In Chapter 2, p. 81 the study goes on to state: “removals are likely to keep population at a size that maximizes population growth rate, which in turn maximizes the number of animals that must be removed and processed through holding facilities.”

The Cloud Foundation recommends the following strategies to address identified issues:

  • Prevent degradation of public lands within and outside the HMA and address nuisance and other wild horses that are residing outside the HMA in areas that are not managed for wild horse habitat or that contribute to public safety concerns such as property damage and vehicle collisions. Historically rangeland degradation by private livestock grazing far outstrips damages by wild horses as livestock far outnumbers wild horses on public lands. Even a population of 536 wild horses (AML of 119 to 179 wild horses) on the 90,900 acre HMA should not create significant damage. According to the EA, “livestock grazing is known to have occurred in the Pine Nut Mountains since the 1930’s under BLM permitting.” To expect mitigation of the long-term damages due to over-grazing domestic livestock within a period of 10 years is not reasonable. Allocation of AUMs to Wild Horses is 2152 in the entire HMA as compared to 3052 AUMs allocated to livestock in only 5 allotments with a small percentage within the HMA. This would indicate intense livestock grazing in those areas. Although livestock grazing in several of the allotments has been reduced or eliminated in recent years, the damages will take many years to heal. To expedite rangeland improvement, we recommend removal of all livestock within HMA’s for a period not less than ten years, at which time AUMs could be re-evaluated. While 222 wild horses were observed outside the HMA we recommend installation of smooth wire fencing along critical boundaries, water catchments and rangeland improvements throughout the HMA to decrease wild horse populations that interfere with roadways or private property as identified.
  • Address long-term population trends within and outside the herd area. See Fertility Control Program and Natural Measures outlined below. 
  • Manage wild horses in a manner that supports meeting Bi-State sagegrouse habitat objectives: Wild Horses have little impact on sage-grouse habitat. According to wildlife biologists we have consulted, historic and ongoing livestock grazing has far more impact on sage grouse habitat than wild horses.

Fertility Control Program:

We encourage continuing of the Fertility Control Program already in place, in conjunction with volunteers. An effective fertility control program requires extensive documentation of the herd, determination of mares to be darted, and follow-up darting to ensure success of the program. We strongly encourage you to include the following elements in the fertility control program for Pine Nut Mountain HMA.

1. Bait trapping instead of helicopter roundup using volunteers to bait trap wild horses.

2. Field Darting at the Appropriate time of the year (from January through early spring, just preceding the breeding season in March/April. By darting with a booster dose 30-60 days following the initial treatment, the herd could then be treated annually with a single dose of one-year PZP.

3. Age Specifications: Fertility control program should contain age specifications of mares to be darted with a goal of allowing every mare on the range to give birth to one live foal. The ultimate goal of any fertility control program to be zero population growth i.e. reproduction=mortality.

4. Flexibility. TCF recommends specific language regarding flexibility in order to change course if unintended consequences occur or unanticipated events happen(i.e. a rise in predation or catastrophic weather event), or if the genetic health of the herd can be better maintained by eliminating a particular mare from treatment.

We suggest adding a sentence reserving the option to make changes, which is consistent with DOI Adaptive Management – learning by doing, and adapting based on what’s learned. Adaptive management encourages flexibility (

5. Horse Identification: If a photo database has not been completed we recommend that photos be compiled into books that could be taken into the field to identify mares by color, face, leg and coat patterns to ensure that identification errors do not occur.

6. Record Keeping: Accurate and timely record keeping is essential to the success of any fertility control program. We recommend monitoring mares after treatment in order to ascertain if any have adverse reactions to the vaccine to ensure that they are not treated again.

The goal of any population control program should be to manage wild horses “on the range,” in a way that will ensure the ongoing health and genetic viability of the herd, as well as insuring that all horses remain on the range where they belong.

Natural Measures:

We also encourage the BLM to take natural measures in managing wild horses by working with the Nevada Department of Wildlife to protect predators.

In addition to an effective Fertility Control Program and other Natural Measures we encourage the BLM to explore other possibilities including:

Pilot Program to allow interested HMA Permittees to contract to do the WH&B on-the range management.

Offer to compensate to LS Permittees financially for partial reduction of cow/calf pairs not grazed, and conversion of LS AUMs to Wild Horse AUMs. We recommend that the Nevada BLM work with interested Livestock Grazing Permittees with acreage inside the HMA to contract to do the WH&B on-the-range management, and to take part in planning, planning, application and decision making.

Livestock permittees should have the best knowledge of water sources and movements of wild horses within the HMA. Using their existing knowledge and input could possibly open positive and useful dialogues between advocate groups and permittees willing to embrace new ideas for managing wild horses on the range.

The Cloud Foundation recommends taking proactive measures to improve its management of wild horses by preventing them from straying beyond the HMA boundaries by installing smooth wire fence along the HMA boundaries where wild horses typically stray. We also recommend improvement of water resources available to all wildlife including wild horses to improve the usage of all lands within the HMA. horses.

Sterilization of Mares as a population control measure is completely unacceptable and should not be considered under any circumstances. It is not only cruel and reprehensible, the practice exhibits a lack of comprehension of the BLM’s responsibility to manage wild horses in the least invasive manner and in a way that ensures sustainable herds. . On this and other occasions, we state our complete distain for any such research and find it not only unacceptable but purposely cruel, irresponsible and a complete waste of taxpayer dollars.

The Cloud Foundation is strongly opposed to reducing the herd to low AML. A roundup of that magnitude would only serve to exacerbate herd size due to compensatory reproduction.


By taking positive steps to perfect “on the range” management of wild horses the Nevada BLM can save American taxpayers millions of dollars, and has the opportunity to serve as an example of how to transform current wild horse management.

Thank you for being open to our concerns and we trust you will do all you can to ensure that the Pine Nut Mountain mustangs persist and thrive into the future. If you have any questions about the contents of this letter, don’t hesitate to give us a call.

We are eager to help you develop a volunteer group of concerned citizens in the local area to aid in monitoring the herd and developing data. Taking these steps now will ensure humane management of the herd “on the range”, and ensure preservation of this valuable resource for future generations.



Ginger Kathrens
Volunteer Executive Director
The Cloud Foundation, Inc.
107 S. 7th Street
Colorado Springs, CO 80905


TCF CommentsJesse Daly