Red Desert Gather Environmental Assessment Comments

July 1, 2017

Tim Novotny
BLM Rawlins Field Office
1300 N. 3rd Street
Rawlins, WY 82301
(307) 328-4311

Clay Stott
BLM Lander Field Office
1335 Main Street
Lander, Wyoming 82520

Subject: DOI-BLM-WY-030-EA15-63 Red Desert Gather Revision

Dear Mr. Novatny and Mr. Stott;

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 Red Desert Complex Environmental Assessment Revision.

Iberian/Spanish Characteristics:

It is our understanding that the EA was remanded back to BLM by Judge Freudenthal so that BLM might evaluate rare Iberian/Spanish characteristics in the Lost Creek HMA as well as the Antelope HMA. Specifically, we would like to comment on what appears to be a lack of consideration for these Spanish markers in both HMAs.

It is difficult, if not impossible, to retain rare genetics when managing at genetically non-viable numbers. Managing for 60-80 animals falls far short of a viable population number to achieve the goal of retaining genetic variability let alone rare markers. However, this recent comment by Gus Cothran updates the 2002 DNA study on Spanish characteristics:

“The first analysis of Antelope Hills using blood typing (done in 2002) suggested North American breed ancestry and no evidence of Spanish.  Using DNA in 2012, there was some evidence of possible Spanish background but it was not strong.  Herd appeared to be of mixed ancestry with possibly some Spanish.”

Dr. E. Gus Cothran, Ph.D., CVM, VIBS, 4458TAMU, Texas A&M University, College Station, TX 77843 USA

Although there may be some interchange with other herds, this has not been quantified to our knowledge and any such possible interchange is likely unable to prevent the significant and inevitable loss of rare genetics found in the Lost Creek Herd. The only prudent course of action is to allow for at least 150-200 animals in this HMA and to begin to chart the relationship of the bands and individuals within the bands. The only horses to be removed would be those that have living and reproducing relatives on the range.

We have over 20 years of experience in the Pryor Mountains where a Spanish colonial herd is present. Typically, only young horses are removed, if needed, those that have relatives on the range. In this way, the genetic lines are preserved.

We suggest that a similar plan be devised for Lost Creek and we would volunteer toassist you with this plan. I have served as a consultant in Canada to analyze the populations for the Spanish phenotype and would be happy to work with you at the trap site. Dr. Philip Sponenberg, foremost color genetics expert in the US, would be a valuable asset on assessing physical standards to determine which horses are returned to the wild.

Stewart Creek;

As we stated in our Scoping Comments, March 18, 2015, we are interested in helping you develop an effective and long-term “on the range” management plan that effectively uses reversible fertility control vaccine as a more humane and cost-effective alternative to roundup and removals. We are pleased that this proposal has been accepted in Stewart Creek HMA.

In order to make the Stewart Creek project work, it is important that we be present at the Stewart Creek trap sites when the horses are gathered. We will photograph and document all those returned and we encourage you to keep the family bands together, as this will help with identification and also lessen the regrouping and disruption of the family units to be returned.

We recommend that only young animals, five years and under, be removed from Stewart Creek as they will have the greatest chance for adoption.

We also request that all mares returned in the entire complex receive PZP or PZP-22. Specifically in Stewart Creek, this will allow us to dart most adult mares in subsequent years with only the PZP booster to all but the youngest females. Either PZP or PZP-22 will have served as both primer and booster. We request that you do NOT mark the mares as we will have a visual record of them for entry into the database. We will be promoting eco-tourism with local experts, which will include photography tours. Marking the mares will render them less attractive subjects for photography and will be unnecessary as they will already in the data-base with their physical markers, photographs, and band membership.

All HMAs within the Complex:


Remove all wild horses outside the HMA boundaries and utilize fertility control on mares released back into the HMA. Under Alternative 1, treating 713 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 1,800 horses in the 753,000 acres (only one wild horse for every 418 acres!) would ensure genetic viability in each of the 5 HMAs that make up the Red Desert Complex.

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 heacknowledged this as a Congressman in MT. This means that killer buys 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 an Environmental Impact Statement (EIS).

The following are suggestions on how to proceed in a humane way with management of wild horses in the Red Desert Complex, not just Stewart Creek.

  • Apply PZP or PZP-22 or a combination of both to all adult mares.
  • If a helicopter roundup is needed to capture most of the horses in the four herds, 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.

(HorseBase is 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.

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 great chance to find homes, whether it be in WY, NV 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 Wyoming 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.

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)

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.

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 EIS process so that a far more in depth analysis can be made.

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