Pryor Mountain Wild Horse Range EA Comments

James Sparks, Field Manager
BLM Billings Field Office
5001 Southgate Drive
Billings, MT 59101

Subject: PMWHR Bait/Water Trapping Gather and Fertility Control Environmental Assessment

Dear Mr. Sparks,

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 PMWHR Bait/Water Trapping Gather and Fertility Control Environmental Assessment.

We support the premise of removing only young animals that will likely adapt to domestication. We are concerned that removals beyond the inbred brothers, Parry and Oak, will not allow for meeting the objectives outlined in the 2009 PMWHR HMAP.


Our records indicate a population of 153 wild horses on the Pryors one year and older (we believe there are likely 152 horses based on our December observations). This is 12 fewer horses than in 2016 when the population of horses one year and older was 165, according to Appendix 3 in the EA. The EA indicates a current population of 165 horses one year and older, but our records indicate it’s much lower.

Additionally, some of the population projections are problematic.

“In 2018, approximately 12 foals are anticipated to be born.”
Pg. 3, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment

We are concerned that the foaling projection is high considering there are only 5 surviving foals born in 2017. Even foaling projections of 12 births in 2018 would likely create zero population growth as foal mortality is a factor, and adult death rates will likely increase within the older age quadrants.

The EA states:

“Horses are long-lived, potentially reaching 20 years of age or more in the wild…”
Pg. 11, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment

However, it states later on:

“The long term average death loss for the herd is six individuals per year and this would remain the same.”
Pg. 17, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment

We believe that the adult death rate will exceed 6. In the past it has averaged 6-8 adult deaths, and that was with an age structure in the herd that did not include more than 20 horses over the age of 20. According to TCF records kept on this herd, there are currently 22 horses on the PMWHR that are 19 years of age or older. We believe that the death rate will likely exceed the average death rate of six to eight individuals. Even if the projection of 6 deaths next year is accurate, that is less than the number of surviving foals from 2017, meaning birth rate and mortality rate are relatively equal. Our records from 2017 show that 12 adult horses and two foals died, and one foal was removed. While just five 2017 foals remain, the birth rate is at less than half the mortality rate in the PMWHR (see Appendix 1).


We appreciate that this office has not proposed a roundup utilizing helicopters, but is rather focusing on the more humane method of roundup utilizing bait and water trapping. If the Hawk band continues to stay on Mustang Flat it is possible that only one trap will be needed to remove Parry and Oak.


Altering the current PZP protocols, as outlined in this EA, would allow for young mares to reverse sooner. TCF supports this change. We are hopeful that this will allow for the PMWHR to come closer to meeting the management objectives outlined in the 2009 HMAP:

“Manage for an age structure with the core breeding population primarily composed of 5-10 year old animals (bell curve).”
Pg. 27, 2009 PMWHR HMAP

The work done on the PMWHR shows that the on-range management in this area is effective and humane.

“Wild horse population recruitment under current management and fertility control treatments has been reduced from 17.5-8%.”
Pg. 3, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment

In looking back at our horse lists from the 1990s, over 30 foals were born each year so, from a historic perspective, the decrease in foaling rates with PZP would appear to be far greater than 8%.


The 2009 Herd Management Area Plan for the PMWHR (HMAP) states:

“During the long term (25 years), the number of wild horses in a herd area will be permitted to increase if monitoring shows that additional forage is available. Ultimately, the Pryor Mountain Wild Horse range (PMWHR) has the potential to support up to 179 wild horses yearlong. This assumes all areas now grazed by the wild horses will continue to be available. However, the projected long-term population increase in this action is considerably less than the potential level of 179 head since no rotational grazing systems will be in effect.”
Pg. 11, PMWHR HMAP 2009

With this in mind, we suggest that wild horse use be restricted in the upper elevations until early June so that those plant communities have an opportunity to grow before they are grazed. This can be accomplished by closing both Burnt Timber and Sykes Roads at the locations of the traps constructed in the mid-twentieth century to capture wild horses. These sites are in disrepair, but they can be improved and we would volunteer to help redo fencing and gates this summer so that horses cannot access the high country until June of 2019. The gates would be closed in the winter long after all the horses have migrated to the lower elevations.

Also, this seasonal closure would prevent people on ATVs, SUVs, and trucks from accessing the top of the mountain and driving off road. Damage to the top of the mountain has occurred in the winter months and particularly in the late fall and spring. At any time in the winter the gates could be opened to accommodate changing conditions and situations.

Grazing rotation was mentioned for consideration in the 2004 NRCS report: “It could be designed to allow for vegetative recovery following grazing, and seasonality of grazing could be somewhat controlled. This would allow for the greatest range recovery for the benefit of the horses in the shortest period of time.”

The 2009 PMWHR HMAP states:

“Under this action the initial stocking level will be 121 adult horses.”
Pg. 11, 2009 PMWHR HMAP

Since then, Since 2009, the Administrative Pastures have been added to the PMWHR. They have an AML of 6-8 horses (see Appendix 2). The AML should reflect this additional number. Wild horses, as you know, are occasionally using the North Pasture this winter.

Taking the above into account, we believe the PMWHR AML could be and should be higher. A high AML of 120 is not high enough for a genetically healthy population, particularly if rare Spanish markers found in the Pryor Herd are to be retained. We believe the AML should be at least 150-200 adult animals, and the current AML should also be raised immediately, as the Administrative Pastures acreage has been made available to the herd.


We are concerned about the genetic viability of this herd. The proposed removal of 20 young horses will render the PMWHR herd genetically non-viable. According to equine geneticist Dr. Gus Cothran:

“Both observed heterozygosity and expected heterozygosity in the Pryor Mountains Wild Horse Range herd is above the feral mean. He is slightly higher than Ho which could indicate the very beginning of evidence of inbreeding.”
Pg. 4, Genetic Analysis of the Pryor Mountains Wild Horse Range, MT, E. Gus Cothran, 8.2013

Additionally, Dr. Cothran notes that the variability of the herd is in decline.

“Genetic variability of this herd in general is on the high side but compared to past sampling of this herd, variability levels for all measures has been in decline. This is likely due to the population size that has been maintained in recent years.”  
Pg. 4, Genetic Analysis of the Pryor Mountains Wild Horse Range, MT, E. Gus Cothran, 8.2013

Dr. Cothran has long stated that in order to remain genetically viable, herds must be 150-200 animals in size at a minimum (Ne50).

“The best way to maintain current [variability] levels [in the PMWHR] would be to increase population size if range conditions allow.”
Pg. 5, Genetic Analysis of the Pryor Mountains Wild Horse Range, MT, E. Gus Cothran, 8.2013

Dr. Cothran has been quoted many times over the last decade in reference to increasing the AML for what he calls “one of the most significant, wild-horse herds in the United States” (see Appendix 3):

“The concern in keeping only 120 horses on the range, Cothran said, is the threat of a potential die-off that could reduce the herd even further, reducing the herd’s genetic diversity.”
Billings Gazette, “Noted geneticist gives his two bits on significance of Pryor Mountain Mustangs,” Sept. 9, 2009

TCF feels that no 1-4 year old horses should be removed at this time due to the declining population and limited reproduction rate. The only exceptions would be the coming 3 and 4-year-old brothers, Parry and Oak, the offspring of a full brother/sister mating. As stated previously, according to careful documentation done by TCF and others on the PMWHR, 12 adult horses died last year, while 5 of only 7 foals born survived in 2017, putting the mortality rate at more than twice that of the birth rate presently for this herd. Removing horses in an already declining population is not warranted or, in our opinion, advisable.

Please note that Dr. Cothran does not refer to reducing dominant lines. Rather he speaks of increasing the population size. Dominance is a part of natural selection, a basic tenet of evolution. A dominant line is successful because it is genetically strong. The best way to allow for weaker lines to persist is to allow for a larger population in which weaker lines have a chance to exist in spite of being weak. It is essential to have as large a population as the range will support.

TCF has PMWHR records from 1968 forward and experiences which give us a historic perspective of BLMs attempts to manage a small herd for maximum genetic viability. For instance, the BLM has attempted to increase genetic diversity by physically moving horses from the mountain to the Dryhead, or vice versa. This has been largely unsuccessful, as the horses tend to return to their home range. However, in some cases, this has happened naturally. In the case of Pride, his matrilineal and patrilineal lines are from unrelated Dryhead horses. Banjo Patterson’s matrilineal line also traces to the Dryhead. This mix has allowed for genetic variation to take place naturally.


We have concerns with the current tiered structure of the proposed removal. While we understand that an effort is being made by this office to preserve genetic lines based on the matrilineal genetics, we do not feel that the current tiered system takes into account the equally important patrilineal genetic line. Focusing on only the matrilineal line could result in the accidental elimination of an important bloodline. This is especially important given the small size of the herd and the rare Colonial Spanish markers still remaining in the herd.

The tiered removal system indicating the number of foals a mare has had is irrelevant. What is relevant are the number of adult offspring still living in the PMWHR. Some mares listed as having multiple foals have had those offspring removed, or those offspring did not live to adulthood. In some cases, their offspring were not viable. Some Tier 1 and Tier 2 young horses are members of narrow genetic lines. The Pryor Mountain Wild Mustang Center would be an authoritative source on this topic.

In the case of a top Tier 2 removal candidate, Pele is one of just two offspring of Fools Gold. She is the only offspring of Amethyst. Amethyst’s mother Regina had only two surviving foals before she died. This is another example of how vulnerable this small herd is to removals of any kind.

Additionally, we are concerned that this removal structure does not take into account the important matter of preserving unique colors for the PMWHR. In the 2009 HMAP, it states that this office will:

“Manage to maintain rare or unusual (for the Pryor herd) colors in order to prevent any one color becoming dominant or being eliminated.”
Pg. 27, 2009 PMWHR HMAP

Unfortunately, 2 of the animals on Tier 1 for removal in the EA are buckskin and chestnut, colors represented by only a few other animals on the range. (see Figure 1).  

Figure 1

All data represented above was gathered by TCF representatives through in-person visits to the PMWHR.Dun varieties include coyote, red, and apricot duns. Roan varieties include bay, blue, buckskin, dun, grullo, chestnut, and red roans.

All data represented above was gathered by TCF representatives through in-person visits to the PMWHR.Dun varieties include coyote, red, and apricot duns. Roan varieties include bay, blue, buckskin, dun, grullo, chestnut, and red roans.

We have been closely observing the herd since 1994. In that time we have seen the loss of the sabino colored horses and a reduction in the number of sorrel horses. We have seen the reemergence of the buckskins, including Pride, a rare Isabella buckskin, revered by the Native people and one that is much admired by visitors to the Pryor Mountain Wild Horse Range. Pride’s Grandmother was named Isabella for her pale, almost white appearance.

Removal of any horses that are buckskin, chestnut, sorrel and palomino could result in the loss of these colors in the future as reported by foremost color geneticist, Dr. Phillip Sponenberg. He wrote in his Sponenberg Report on Pryor Mountain Mustangs, October 10, 1994:

“If the herd size is ever established at some specific number then that number would help determine the minimum number for each color. (The) working figure is somewhere in the neighborhood of six or seven. If there are six or seven animals on the range expressing a given color group then it is unlikely that the color will become extinct through genetic drift.”

Dr. Sponenberg also evaluated each horse living on the range in 1994, ranking them as Super horses (S), Average horses (A), horses to be Kept on the range (K), and Cull (C), for those that could be removed largely because they were “atypical” in conformation, deviating from the Spanish Colonial phenotype. Pride’s grandparents, Raven and Phoenix received the highest ranking of Super Horses as did his great grandmother, Isabella.

Sponenberg also acknowledges that color variation is one reason that the herd is popular with the public.

“These are everyone’s horses (since we all pay taxes), and need to be managed so that future everyone’s can enjoy this historic and unique resource.”
Sponenberg Report on Pryor Mountain Mustangs, October 10, 1994

I think we all can identify with this last quote.

In the past 24 years I have stood with visitors on many occasions and watched their faces light up when they see the horse color palette in full display atop the mountain.


Rangeland health is cited multiple times as a reason for removals. However, in the EA, it is stated that utilization has been meeting set goals in almost every area of the PMWHR.

“Based upon monitoring data collected in 2015, 2016, and 2017 the use objective was being met in the Dryhead, parts of the lower elevation areas, and has continued to be met in the mid-elevation areas until recently… Some use patterns of the wild horses are shifting as more time is being spent in the mid-slope areas due to guzzlers.”
Pg. 31, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment

Additionally, in the HMAP for the PMWHR from 2009, there were many methods of rangeland improvement suggested:

“Prescribed fire for the enhancement of forest health, wildlife, and wild horse habitat could occur primarily in the mapped area…”
Pg. 46, PMWHR HMAP 2009

“Aerial seeding with native species appropriate to the PMWHR would be used to supplement seed source and attempt to improve ecological conditions.”
Pg. 42, PMWHR HMAP 2009

We realize that a legal challenge was filed on prescribed burns. I believe it was the Clark’s Nutcracker that was not considered? What is the current status of the lawsuit?

We hope that BLM is planning to carry out this important part of range improvement on upper Sykes where the forest is dense, unproductive, and potentially dangerous in the event of a forest fire. Opening up the forest on upper Sykes Ridge would provide habitat and grazing for wild horses and increase plant and small mammal diversity. Has BLM moved forward in providing the necessary documentation so controlled burns can be used to improve habitat in the PMWHR?

Aerial reseeding can be done anywhere on the range, including the mid ridges which can be done in the summer when there are few horses in these areas. Temporary fencing can be constructed for reseeding in non-WSA (Wilderness Study Areas) where practicable. The health of the range can be improved without risking the genetic health of this unique wild horse herd.

There have been a significant number of studies done in the PMWHR regarding the ecology of the range. In the discussion section of a paper submitted by Jace T. Fahnestock and James K. Detling, the two authors state:

“Mean annual precipitation in the PMWHR, especially in the lowlands, is closer to the dry end of the precipitation range in the above studies, and the responses of plants in both the lowland and upland communities of this study suggest a tighter coupling of these communities to abiotic factors, such as growing season precipitation, than to herbivory at the ungulate densities encountered in the PMWHR.”
Managers’ Summary – Ecological Studies of the Pryor Mountain Wild Horse Range 1992-1997

During the time the studies were conducted, the population of wild horses was similar to the current population.This would suggest that precipitation is a main factor in the success of plant growth in the PMWHR.


We continue to encourage you to expand the PMWHR. One candidate for expansion of the PMWHR is 6,000 acre Demi-John Flat, which was recommended for inclusion in Ron Hall’s original range survey in the early 1970s. He mentioned that Demi-John Flat had clearly been used by wild horses and that it would be an excellent place for the public to view the horses.

Historically, the Demi-John Flat was used extensively by the Native people and their horses. The old 1901 Mormon logging road went through the area as well. Crow Elder Howard Bogess and former Montana BLM State Director Mike Penfold have indicated their support for adding Demi-John Flat to the wild horse range, feeling it is long overdue and a very appropriate addition.

Additionally, we encourage BLM to work with the Bighorn Canyon National Recreation Area (BCNRA) to reopen the Sorenson Extension for wild horse use. The BCNRA reports that wild horse viewing is the number one activity in the BCNRA based on personal interviews with those coming into the visitor center. Wild horse viewing now surpasses other activities like boating, fishing, and hiking. If the Sorenson Extension was available for wild horses it is likely that there would be more reliable viewing at all times of the year.

TCF would gladly work to support any expansion plans which allows for a truly genetically viable population of wild horses in the Pryors.


As you know, the PMWHR is extremely popular with wild horse enthusiasts, photographers, and tourists. These horses provide an economic benefit through tourism dollars, both locally and to the states of Montana and Wyoming.

“Special recreation permits are becoming more prevalent as more people wish to pay for the opportunity to participate in guided or organized activities on public lands. Wild horse photography tours, viewing tours, and cattle drives are the primary recreation-permitted activities.”
Pg. 38, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment

The PMWHR is regularly documented by TCF on our website and our Facebook page, which has nearly 500,000 active followers interested in the health and wellbeing of these animals. The horses are regularly documented by photographers in the area on various Facebook pages, garnering thousands of additional unique followers.

“Recreation-related visitation has been increasing in the Pryor Mountains over the last several years and that trend is expected to continue. …. Recreation opportunities are primarily wild horse viewing during the warmer months of the year, especially during foaling season.”
Pg. 38, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment

Furthermore, these horses are a federally protected 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 a beautiful wildlife species that deserve the opportunity to live their lives on their homeland, with their families.


  1. We agree with the proposal in this EA to alter the PZP darting protocols, allowing mares to reverse sooner.
  2. We feel an adjustment to the AML for the PMWHR is warranted. In particular, the AML should be adjusted upward with the addition of the Administrative Pastures. The AML should be increased to protect and preserve rare genetics and colors. TCF feels the Demi-John Flat totaling 6,000 acres should be added to the PMWHR as was suggested in the early 1970s.
  3. We do not feel that any wild horses need be removed at this time, other than Parry and Oak, offspring of a full brother-sister mating pair.
  4. If a removal occurs, we believe that the current proposed tiered system should be reexamined to honor the objectives outlined in the 2009 PMWHR HMAP regarding the preservation of unique colors, and to take into account the patrilineal genetic lines.
  5. We agree with this office that if a removal occurs, the more humane method of bait trapping should be used.
  6. We hope this office will utilize some of the rangeland improvement methods outlined in the 2009 PMWHR HMAP, including reseeding and controlled burns, as well as our recommendation to repair/construct gates to delay grazing in the high elevations, allowing plants to mature.

We are grateful for the opportunity to offer our comments on this proposal and, as always, we appreciate your willingness to listen to our thoughts. I know personally that you care about the wild horses you manage and will always be grateful for your kind and thoughtful consideration of all the animals that call the Pryor Mountains home. I believe that the PMWHR presents a special opportunity to continue showcasing forward-thinking, cost-effective, humane wild horse management. We will help you in any way we can to achieve these goals.

Please feel free to call us with any questions about our comments.


Ginger Kathrens
Executive Director
The Cloud Foundation

APPENDIX 1: Click Here
APPENDIX 2: Click Here
APPENDIX 3: Click Here

Other Sources: 
Dr. Gus Cothran 2013 Study
2009 Pryor Mountain HMAP

Kayah Swanson