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August 4th,
2007
Bureau of Land Management
Las Vegas Field Office
4701 North Torrey Pines Drive
Las Vegas, NV 89130
Re: 4700 (NV052)
Attn: Lisa Christianson, Acting Field Manager, Recreation
and Renewable Resources &
Jerri Bertola, Wild Horse & Burro Specialist. Tel. (702)
515-5024 &
LVFO Manager
Dear Mame/Sir:
As per letter from Christenson of 7/11/07, please keep me on
your mailing list for receiving wild horse and burro
information, wilderness and wildlife, grazing allotment, and
other activities involving the many values and presences of
our public lands. As concerns the roundup of 178 wild horses
conducted between July 6th and 8th, 2007, on the eastern
side of the Nevada Wild Horse Range (NWHR) and the proposed
gather of an additional 800 to 850 so called “excess” wild
horses from the NWHR in December of the present year, I
strongly object to the further reduction of this at present
minimally viable herd! By taking the population down to 300,
the lower end of your Appropriate Management Level (AML) of
300-500 wild horses, you will jeopardize the natural
adaptability and resilience of the herd!
A given population of wild animals derives an adaptive
benefit from more generational lineages in adaptive ascent
to the present. Also a population has a way of
mutualistically conditioning its habitat; and this is
particularly true in the case of the wild horses who seed
many of the native plants they eat and whose feces
contribute significantly to the humus component of soils,
lending vital plant nutrients and water retaining qualities
to such.
I consider it a glaring oversight that you have established
such a very low AML for the NWHR! This vast area used to be
home to several thousand wild horses. To reduce the herd to
merely 300-500 animals is a gross injustice! This, of all
places, should be a herd area that supports an optimally
viable wild horse population numbering in the thousands, not
just a minimally viable one. And I would professionally
argue that 300-500 does not even meet the latter standard. I
believe that the BLM is abrogating its responsibility under
the law to defend and promote the rights of the wild horses
in their largest legal herd area in the nation! According to
the BLM Wild Horse and Burro Evaluation of January 29, 1997:
“Nevada’s only designated wild horse range is within the
Nellis Air Force Base. Established in 1962, the Nevada Wild
Horse Range (Range) covers 394,000 acres out of the
2,209,326 acre Air Force Base. While the majority of the
wild horses occupy lands outside of the Range, BLM’s
agreements with the Air Force only allow for managing horses
within the Range. ... In 1990-1991, BLM conducted an
environmental assessment of the Nevada Wild Horse Range for
wild horse suitability using water, distribution of animals
and forage utilization as criteria. Based upon this
assessment and an agreement with the Air Force, the
appropriate management level for the Range was determined to
be 1,000 horses. At the time of the assessment there were
approximately 5,000 horses on the Range.” – So just why is
the current AML now set at 300-500 wild horses, more than a
halving of the earlier recommended AML, itself a great
reduction of the former population?! Another publication of
the BLM called Nevada Wild Horse Range, Clark, Lincoln, and
Nye Counties, Nevada states “Permanent water sources consist
of springs found at the base of the mountains and the
temporary standing water in the playa lakes. ... playas can
hold rainfall runoff for several weeks and furnish an added
source of water for the horses and wildlife found in the
area.” It seems to me that a lot more could be done to
assure that the wild horses have adequate water to support
an optimally sized wild horse population, one viable in the
long-term and capable of really thriving in this vast area!
The present AML of 300-500 is not an optimally viable herd;
indeed, it may not even be a minimally viable herd,
especially given the harem social structure of many of the
wild horse bands, with one stallion, the “patron”, doing the
majority of the breeding, and hence limiting genetic
intergenerational exchange. BLM’s reliance upon only one
geneticist to determine that a minimally viable population
consists of only 150 wild horses is another glaring proof of
its negative tendentiousness toward the wild horses in the
wild!
Also noted in Nevada Wild Horse Range, Clark, Lincoln, and
Nye Counties, Nevada: “The horses share the area with
pronghorn antelope, desert mule deer, coyotes, fox and
mountain lions, as well as many species of small wildlife.”
Not noted however is the impact the mountain lions have upon
reducing the wild horse population, which can be a very
significant one!
I am requesting a breakdown of the total legal acreage of
the NWHR and surrounding legal herd areas. Leaving only 300
wild horses in the core NWHR works out to leaving 1,313
acres per remaining wild horse. If the bigger Nellis AFB is
considered this works out to 7,364 acres per remaining wild
horse. I am also requesting a breakdown and description of:
(1) the water sources to which the wild horses are entitled
and how this compares with all existing water sources in and
around the NWHR, (2) the fences presently existing within
the refuge and how these might disrupt the seasonal wild
horse migratory patterns and impede their access to water,
and (3) other grazers and browsers present in the NWHR,
including livestock and big game animals that. would allow a
fair appraisal of the relative proportions of resources
which the wild horses are actually receiving vis-a-vis
livestock, big game, and other uses going on within this our
nation’s greatest wild horse sanctuary!
Having earlier toured NWHR during the early 1980's, I
remember how certain springs were maintained in
collaboration with wild horse groups (such as the National
Wild Horse Organization, as I recall, in Las Vegas) and that
an optimally viable herd was then present and in good shape.
This herd was over 2,000, as I remember. I also remember the
reports of a huge die-off during a drought period in which a
rescue effort turned out to be a very tragic affair with
hundreds of horses dying. I have also heard how the wild
horses were “set up” for this tragedy by their enemies’
preempting their waters and overly restricting their
movement patterns to which they were guaranteed under the
Act.
As a wildlife ecologist with instruction in wildlife
management and ecology and population biology, I know there
is a way of providing for the needs of a much more
substantial and truly viable number of wild horses than the
AML of 300-500 here in their greatest legal public lands
sanctuary, the NWHR! What seems to be lacking is the
political will to assure an intelligent and positive wild
horse-containing sanctuary design that allows for a viable
wild horse population in the thousands here, not the low
hundreds. So many of the other legal herd areas have been
zeroed out across the nation or reduced to such ridiculously
low AML’s as to assure the inbreeding and chance die-out of
remaining wild horses, especially when coupled with the use
of PZP that more or less sterilizes the remaining mares. In
regard to the proposed use of PZP on remaining mares allowed
to remain in the NWHR, I am very much opposed to this as it
will reduce the natural herd vitality and resilience,
further contributing to the herd’s decline. This would,
indeed, be adding insult to injury by so negating the
ability to reproduce among those relatively few remaining
wild equids!
I am a strong advocate of alternative approaches to wild
horse management, approaches that are true to the original
spirit and intent of the Wild Free-Roaming Horse and Burro
Act in being minimally invasive. These are approaches that
respect the wild horse-containing ecosystem and allow the
natural cycles to operate, including that most natural cycle
involving birth and death and the contribution that the wild
horse makes as a prey or scavenged species. What more
fitting end than to contribute one’s mortal remains to the
ecosystem that has supported one since birth?! The wild
horses space their bands in mosaic fashion filling up their
niche space at any given period of time, through a type of
personal band space largely governed by the stallion. Once
they have spaced out their available habitat, then they
stabilize their population numbers as a member of the climax
ecological sere. For this reason, they are called “climax”
species, something I learned in graduate courses in wildlife
management and population biology. Now the key point for
allowing any given wild horse population to stabilize is:
where and how do we so design a wild horse-containing
sanctuary in regard to its natural or semi-permeable
artificial boundaries that would act as barriers to the wild
horses’ expansion. It is absolutely of critical concern that
we identify wild horse or burro habitats that are of
sufficient size and of appropriate floral and faunal
composition, as well as elevational range so as to provide
all the needs for a long-term viable wild equid population
numbering in the thousands. This, of all places, should be
the Nevada Wild Horse Range established many years ago by
government decree and in accordance with the general will
and advocacy for wild horses in the wild by the public . The
“why?” of this situation is that we owe it to this returned
North American native: the horse (Equus caballus) whose
presence restores the North American ecosystem and who
deserves to live freely and naturally here for myriad benign
and just reasons, including those that pertain purely to
horse kind itself!
This now brings us to the question of “when?” this design
must be carefully thought out, proposed and implemented. The
time is clearly NOW!, because the wild horses cannot wait
another year! There must be a turnaround for them as a truly
returned native wildlife species here in their legal herd
areas. They must be restored to viable numbers, not continue
to be “sold down the river” to cripplingly low population
numbers and finally to elimination from the wild, as is
currently the case! Our public servants must take their
responsibility to them seriously and stop siding with the
wild horses’ shameless detractors and out-and-out,
shameless, unreasonable and in-your-face enemies! This is
the sacred duty of our chosen public servants in the BLM and
USFS, the two agencies chosen by the people to guard our
nation’s last wild horses: to defend all the values and
presences on the vast public lands, and to prevent any
subset of vested interests, such as livestock, hunting,
mining, timber, housing development, ORV’ers, etc., from
monopolizing these public lands and upsetting the very sane
balance in their biodiverse ecosystem. – I therefore
strongly urge you to be true to your – what I consider to be
– sacred duty toward these wild horses.
Please reconsider your proposal to remove 800-850 wild
horses from the NWHR! This is grossly unfair and unnecessary
and further plays into the hands of the wild horses’ crass
enemies, those whose conscience is seared when it comes to
these beautiful, adaptable, and ecologically positive
“Returned North American Natives” of ancient origin and
long-standing ancestral duration here! Not a single wild
horse should be further removed, but you should assure that
their natural grazing, water, mineral, etc., supplies are
not monopolized by their enemies, especially the ranchers
and big game hunter establishment! Please let me know what I
can do as a wildlife ecologist to make this most just dream
a living reality here in my home state of Nevada.
Sincerely yours,
Craig C. Downer
P.O. Box 456
Minden, NV 89423
January
12th, 2007
Bureau of Land Management, Tonopah Field Station
P.O. Box 911, Tonopah, NV 89049
Attn: Andrea Felton, Wild Horse and Burro Specialist
(Comments due 4:30 PM 1/16/07)
Tel. (775) 482-7800 (main off) Felton: 482-7847; Fax (775)
482-7810; Andrea_Felton@blm.gov
Re: Stone Cabin Complex Wild Horse Gather Environmental
Assessment NV065-EA07-028
Dear Ms. Felton:
I have just thoroughly reviewed your Environmental
Assessment that purports to justify the drastic reduction of
wild horses within the Stone Cabin Complex of herd
management areas. I am taking the present opportunity to
strongly protest this very unfair treatment of the wild
horses and the sizeable public interest in their welfare and
preservation in the wild. It becomes apparent early on in
the document that you and your colleagues are setting the
wild horses up for reduction to a very small population
level by blaming them for ecological problems that are not
their fault. I note a frequent lumping of wild horses with
livestock when describing ecological problems and then your
going on to paint a very rosy picture of how great the
situation will be when the wild horse herd is gutted by the
drastic roundup. No where do you give the relative
proportions of livestock, big game species and wild horses
within the areas in question. I have been able to obtain
some figures on this, however, and am appalled by the
extremely disproportional share of resources that is
allocated for the wild horses here in their legal herd areas
where they are by law the “principal” presence! I urge you
to redo this entire anti-wild horse document and to issue a
much fairer allocation providing for higher numbers of wild
horses within their vast legal herd area. It is plain to me
that you and your agency are aiming to squeeze the wild
horses off their legal herd area contrary to the law in
order to allow a practical monopolization by livestock
mainly and also by big game animals at the urging of local
ranchers and their organizations and at the urging of the
Nevada Dept. of Wildlife, both traditional enemies of the
wild horses. Your job is to defend the wild horses’ rights
upon the public lands, but you are abrogating your
responsibility here!
Below please find my specific comments with reference to
page number:
P. 1: Your opening paragraph starts out leveling blame on
the wild horses and describing them as a negative element in
the ecosystem. You arbitrarily state that there is a current
overpopulation of wild horses while giving no true
perspective or definition of overpopulation, no relative
proportions of livestock, big game animals and wild horses,
no accounting of human caused abuse to the ecosystem, which
includes overgrazing of livestock, overemphasis on promoting
big game, target animals by NDOW, elimination of predators,
ORV’ abuses of the land, mining abuses of the land,
tampering with natural springs and livestock and camper
trampling thereof, etc. It is very apparent to me that you
are laying the groundwork for undermining the wild horses’s
presence here, while overlooking the true culprits when it
come to ecological deterioration!
P. 3. Here you fail to report the proportions of livestock
and big game relative to wild horses in their legal herd
area of the wild horses. This should logically be done to
give perspective, something your document glaringly lacks!
The Appropriate Management Level of 547 wild horses in a
combined area of 1,227,000 acres (itself a reduction from
the much bigger original legal herd areas) yields 2,243
acres per wild horse. This is very unfair and is contrary to
the Wild Free-Roaming Horse and Burro Act, P.L. 92-195, that
states that the wild horses/ burros shall be treated as the
“principal” presence within their legal herd areas. Rather
you are treating livestock primarily as the principal
presence, and after livestock: target game animals. Within
the Stone Cabin Complex including the HMA’s of Stone Cabin,
Reveille, Saulsbury and Monitor Wild Horse Territory on USFS
lands, there is allocated 44,282 Animal Unit Months, while
the wild horses here are only allocated 6,564 AUM’s, or only
about one-seventh of the forage given livestock. When both
the Fish Creek and the Stone Cabin Complexes of HMA’s are
considered, a total of 2,027,945 acres of HMA’s is present
upon which only 540 horses will remain. This yields 3,755
acres per wild horses – hardly a fair proportion considering
these areas are part of that minor portion of the public
lands where the wild horses are supposed to be treated as
the “principal” presence! Between 2005 and 2006, 1,179 wild
horses have just been gathered from the Fish Creek Complex
adjacent to the Stone Cabin Complex. The latter used to
support well over 2,000 wild horses, but is now planned for
reduction to the paltry figure of 181. It is clear that
livestock interests are expanding their monopoly at the
horses expense and that our public servants are doing
nothing to stop this!
P. 4: 138 wh’s in Reveille HMA is much too small and the BLM
should have appealed this livestock-favoring decision.
1.3: You present no facts, just an arbitrary statement. You
fail to differentiate between livestock impact and wild
horse impact in attributing blame for ecological
deterioration. It is usually the livestock who have caused
the damage, not the wild horses. But it is convenient to
livestock interests to always blame the wild horses and
shirk their own responsibility! You fail to look at the
possibility of reducing livestock in this area, but only
continue in very suspect manner to heap blame upon the wild
horses. This is neither fair nor honest!
P. 5: You need to maintain a larger population of wild
horses in order to prevent inbreeding. Gathering below the
AML, as you propose, is illegal! Your statements concerning
overutilization are arbitrary and tendentious. You present
no facts, no perspective. The public is not able to judge
the relative proportion of herbivore classes: livestock,
deer, horses.
P. 7: Concerning those commenting on the plan, only a few of
the traditionally conforming commenters are mentioned. You
fail to mention many other wild horse supporting groups and
individuals who oppose the excessive roundups and unfairly
low AML’s that have been decided upon by our supposed public
servants in the BLM and USFS. The ranchers who commented are
clearly blaming wild horses for range deterioration that
they and their livestock are largely responsible for! ...
Movements of the wild horses relates to their semi-nomadic
life style and is a way of their dispersing their grazing
pressure and allowing a natural rest rotation. For this
reason fences should be eliminated within their herd areas
wherever possible. ... Concerning possibility of accidents
along U.S. Hwy 6, you should urge the Nevada Dept. of
Transportation to install Strieter Lite reflectors along the
highway. These would prevent collisions at night between the
wild horses and other wildlife and vehicles. See
www.strieter-lite.com and call Lauren & Julie Keller at
775-241-0535.
2. Description of Prop. Act. & Alt’s: You make it all sound
so very rosy, like eliminating wild horses is the very best
thing anyone can do. How very unfair and lacking in basic
honesty!
P. 8: Proposed gathering to 88 wh’s is much too low for
Reveille! Saulsbury: Gathering below AML here to 25 (40 is
AML). This jeopardizes the herd. Even the AML is non-viable.
What is the proportion of livestock here? Big game animals?
Stone Cabin HMA: Gathering to leave only 181 wh’s in such a
vast area is much too low. Leaving 60% stallions in a harem
species will create an unwholesome situation in which much
friction among the males will ensue.
P. 9-10: I favor the No Action Alternative (No wild horse
gather). Having 821 wild horses in the Stone Cabin Complex
in Jan 2007 is not excessive and may just be a minimally
viable population. Remember there are 1,227,000 legal hma
acres for the wild horses here. This yields 1,495 acres per
wild horses, hardly an overcrowded or excessive population,
especially considering these areas are to be managed
principally for the wild horses, not the livestock,
according to the law! Your reduction of the complex to a
mere 300 wild horses will work out to 4,090 acres per wild
horse, which leads me to ask: is this not a mere token
number for the wild horses in these their legal areas where
they have the right to exist? What interests are displacing
them here? The local livestock operators? The big game
hunters? The ones the federal govt. is supposed to defend
the wild horses against?
P. 11: I oppose PZP immunocontraceptive fertility control.
This will negatively affect the wh herd’s vitality.
P. 13: Air Quality: The dust stirred up by the helicopters
during the roundups causes a serious risk of causing dust
pneumonia in the wild horses rounded up. Env. Justice: I
disagree: wild horse supporters and observers are being
seriously discriminated against by the proposed action!
P. 15: 3.2: I note there are five livestock grazing
allotments within the Stone Cabin Complex HMA’s. This is
clearly the problem! The wild horses are being squeezed out
by the ranchers even in their own legal herd areas! The
fences you note as here constructed interfere with the
freedom of movement of the wild horses, so essential to
their survival and to their equitable proportioning of
consumption patterns in this desert area. This may cause
them serious survival problems if interfering with seasonal
migrations, i.e. Winter kill, prohibition of water in
Summer.
P. 16: The vacant Monitor and Ralston grazing allotments
should be left vacant to provide for more wild horses here
within their legal herd areas.
Table 5: Clearly this reveals that livestock, not wild
horses, are the principal presence being ca-tered to by BLM
even in their legal herd areas, contrary to the original
intent of Wild Horse Act!
P. 17: Top: Ok, here BLM admits that by removing wild horses
to substandard levels it is catering to livestock interests
by providing more feed for cattle. The solution here called
for is to reduce livestock to allow more wild horses in
their legal herd areas. Bottom: You overlook the wild horses
role as seed dispersers (through feces) of many native
plants and as builders of soil.
P. 18: No Action Alternative: You overlook the important
role of wild horses in dispersing native seeds of many
species through their feces, thus helping the ecosystem.
Many other positive ecological mutualisms you overlook when
considering the importance of the wild horses.
3.4: Lumping wild horses with livestock is a typical
maneuver by wild horse enemies, who always blame the wild
horses and minimize or ignore the negative impacts of their
livestock, for obvious reasons. ... You again lump wild
horses and livestock in assigning responsibility for
deteriorating vegetation. Look at the relative numbers and
grazing pressures above alluded to! How much have livestock
been adjusted? Your arbitrary judgement that wild horses are
“overpopulated” is your excuse to cripple the wild horses
populations here, while promoting the further livestock
monopoly on these public lands! Bottom Paragraph: You fail
to recognize the horses with their post-gastric digestive
system as better able to derive sustenance from high fiber,
relatively nutrient poor forage which they pass in greater
bulk as compared to ruminant grazers such as cattle. You
also overlook the role of this in helping to build the humus
content of the soil.
P. 19: No Action: You state these negatives against wild
horses but present no factual proofs. These are just
convenient to your agenda of wild horse minimization even
within their legal area.
3.5: Do not lump wild horses with livestock and recreational
use. This is unfair and leads to guilt by association, not a
very scientific or honest approach, since prejudiced views
creep in.
P. 20: Top: Are you sure it is wild horses causing riparian
degradation, not livestock or recreational use? Middle. You
fail to discuss the relative proportions of grazers in the
herd area, i.e. what is the relative proportion of wild
horses to livestock present? To big game? This causes me to
suspect that you are targeting the wild horses. Bottom: Wild
horses have much less tendency to congregate around riparian
areas than do cattle. They disperse their grazing pressure
over a wide area. No Action: This is an unfair statement
which blames wild horses for degradation caused by other
factors, especially livestock. Very unfair!
P. 21: 3.6: Please give the relative proportions of
livestock and big game animals within all of the wild horse
herd areas here and describe the amount of acreage in the
original herd areas, relative to present hma’s. ... Are
these factual and well analyzed, weighed statements or just
convenient to your targeting of wild horses for drastic
reduction?
Bottom: The Wild Horse Act protects the free-roaming
lifestyle of the wild horses and burros. This is
ecologically healthy, allowing them to disperse their
grazing pressure and rest rotate vegetation within their
home ranges. Bottom. 403,000 acres in Stone Cabin is a lot
of legal acres for the wild horses! This is chiefly for the
horses not for livestock! Please remove the fence which is
proving fatal to horses during winter snows, as you admit.
P. 22: Top: Fooling with hormones of wild horses is very
dangerous and can very adversely affect their well being!
... Did test horses suffer and die? Middle: Sounds like an
excuse for practically eliminating the wild horses: only 50
to remain post gather in an HMA that is 403,000 acres in
size. this works out to over 8,000 acres per wild horse.
This is outrageously unfair! The other HMA’s also receive
very unfair treatment in numbers of horses to remain. This
is contrary to the law.
P. 23: Top: The median of this AML works out to 104,000
divided by 155 = 671 acres per wild horse. Such a sized area
could support at least 3 times as many wild horses. What
interest is monopolizing the legal wild horse herd areas
here? Livestock? Big game? Both? Middle: The unique Stone
Cabin Grey deserves higher numbers to preserve truly viable
population.
P. 24: Top: 1,000 is unfairly low for such a vast legal herd
area. This population should be much greater to assure
long-term viability. Again what are the relative proportions
of livestock and big game within the legal wild horse herd
areas? Midpage: It would seem that in a species with a harem
social structure such as the horse, there would naturally be
more females than males in the population. An inordinate
number of males could cause serious social problems,
increased violence among the stallions vying for the
relatively few females. ... Only 25 wh’s to be left in
Saulsbury HMA. This works out to 15 below AML of 40 in
135,000 acres in HMA which divided by 25 works out to 5,400
acres per wild horse. This is an outrageous treatment of
wh’s within their legal herd area where they are to be
considered the “principal” presence! ... Why is Reveille HMA
so low in wh #? This could be a strong indication of illegal
wh killings and removals, fencing off of waters, etc. ... In
Stone Cabin HMA, wh number to be released is 170 in an area
of 403,000 acres in size. This figure div. by 170 = 2,371
acres per wild horse left. This again shows how outrageously
unfair you are treating the wild horses in their own legal
area! ... Bottom: Re: injuries assoc. with wh gather: This
is a gross underestimation of the extreme trauma, shock,
injury and suffering these brutal helicopter roundups cause
to the wild horses! There is a better way of in-field
management that could obviate these cruel roundups by
allowing the population to self-stabilize through use of
natural barriers and actually allowing them to fill their
niche and assume principal status within their legal ha’s.
... I disagree concerning the reduction of population having
“minimal” impact on herd dynamics and age structure. This
has a big impact and there is a better way.
P. 25: Top: You overlook how these excessive roundups set
back the natural adaptation of the herds in their particular
ecosystem here, as reflected in special behaviors,
phenotypes, genotypes, migration patterns, knowledge of
food, water, shelter, etc. These roundups are disruptive and
impede the wild horse population’s tendency to fill its
niche and stabilize its population. Midpage: That the mosaic
of herd territories that itself stabilizes the population is
overlooked by you. 540 wh’s left after 2005 roundup in such
a vast area should be left alone. This is a tiny number
relative to the enormous amount of area these wh’s occupy!
Bottom: All sounds very rosy, but in fact the wild horses
are not to blame for deteriorating conditions, rather other
users are: notably livestock. Your plan allows livestock and
big game to monopolize the legal wild horse herd areas here.
This is contrary to the law – very unfair to the wild
horses.
P. 26: Table 6: I favor the No Action, No Gather
Alternative. 882 is a fair number of wh’s for such a vast
area. 403,000 div. by 882 = 457 acres per wild horse. This
habitat area can easily sustain a herd of 882. This would be
closer to a long-term viable level, of which there are
hardly any left in the U.S. Also intrinsic
“density-dependent” population limiting abilities would come
increasingly into play as wh’s fill their niche here.
Bottom: Higher % of males would cause increased fighting
among males and abuse to mares.
P. 27: Top. Such drastic roundups will cause Compensative
Reproduction, a surge in births as occurred in Reveille
after the roundup. Therefore it would be better to leave
more wh’s in the area and let the population fill its niche
here and intrinsically stabilize its numbers with a mosaic
of wild horse band territories naturally limiting the
population. Why don’t you let this work?
P. 28: Sometimes gelded stallions are harassed by normal
stallions, kicked, bitten and driven off and can even be
killed. Do you have information on such incidence?
P. 29: Yes, I favor #4: No Action Alternative. It is much
more fair and should be accomplished in a sound manner by
reduction of livestock and big game within the legal wild
horse herd area.
2nd Paragraph: This is hyperbole convenient to your proposal
to gut the wild horse herd. You overlook the alternative of
reducing livestock and big game to give the wild horses
their proper share of resources here and allow a more truly
long-term viable population level to become established. 3rd
Para: This is a cave in to livestock, and big game,
permitting their monopolization of the public lands. This is
an abandonment of the wild horses’ rights. Bottom: These
arguments are so very convenient to your objective, which is
to gut the wild horse herd here, to reduce it to a mere
token level and to accommodate livestock and big game
interests. This is a shameless abandonment of the true
spirit and intent of the Wild Horse Act that provides for
healthy, viable populations of free-roaming wild horses in
their legal herd areas!
P. 30: Given Global Warming and increasing pressure from
more people on public lands, the stochasticity factor tends
to the extremes and argues for leaving a greater population
number of wild horses, rather than the mere token levels you
are proposing. Such a small level as 300 wh’s would be much
more subject to chance die out due to vagaries of climate,
illegal killing (currently on the increase), human tampering
with water sources, disturbances with ORV’s, etc.
P. 31: The No Action Alternative, #4, produces reasonable
population numbers for such vast areas of legal herd area.
Table 7: What you should do is let the wild horse population
fill its niche within its legal herd area and stabilize
through intrinsic controls, including those self imposed and
the construction of barriers along natural boundaries so the
herd would be self contained. The roundups would become a
thing of the past. This reveals to me that something else is
going on here, i.e. an effort to displace wild horses from
their own legal herd areas and supplant them with other
interests, especially livestock, big game, etc. Please note
that the Stone Cabin Complex has 1,227,000 legal acres for
wild horses. At the median projected population for year
2011, this would be occupied by 1,458 wild horses. This
would work out to 842 acres per wild horse, which is not an
overpopulation – far from it!
P. 32: 1st Paragraph: You choose a scenario convenient to
your agenda of reducing the wild horse population to mere
token levels! Your talk of wild horses destroying the
ecosystem is hyperbole and overlooks the real culprits here:
overgrazing by ranchers and their livestock, especially.
3rd Para: I notice that you select the extreme high in the
projected figures. You should use the median figure in your
discussion. This shows your tendentiousness. Your projection
of degradation of rangeland is wrong since this area could
and should sustain a level well over 1,000 wh’s and the
other grazers, i.e. livestock and big game, should be
adjusted to permit this.
P. 33: Wildlife: You fail to recognize that the wild horse
has a positive influence on the native ecosystem though seed
dispersal and soil building by means of its feces, breaking
ice in winter that permits other species to access food and
water, pawing to water in summer to permit other species to
drink, and in many other ways by which it restores the
ancient and long standing equid component of the ecosystem
in Western North America.
P. 34: I note the importance of Pinyon- Juniper forests to
the Bald Eagle and to the Ferruginous hawk, as to many other
species, yet these forests are often chained to promote
livestock.
P. 35: Are you sure the Greater Sage Grouse is being
impacted by wild horses and not livestock? Take care not to
blame wild horses for abuse to habitat caused by livestock!
I would like to see the factual proofs of your claims here.
Env. Consequences: What about effects on wildlife species
that benefit from wild horse presence – of which there are
many? Bottom: Here you ignore wild horses’ positive effects
on many native wildlife species (See enclosed article).
P. 36: Top: Your merely saying so doesn’t make it so! End
1st para: You should reduce livestock not wild horses and
you should stop blaming wild horses for ecological
destruction caused by ranchers, ORV’ers, overemphasis on big
game target animals, the elimination of natural predators to
favor livestock and game – all in the ultimate analysis
caused by modern man!
No Action: Here you project such a dire consequence of
letting wild horses fill their niche and stabilize, but
overlook the real problems, i.e. to many livestock whose
relative proportions to wild horses you conveniently omit
from this otherwise lengthy EA that keeps repeating itself!
Same goes for big game in relation to wild horses.
P. 37: Top: Yes, the wild horse is a wildlife species not a
domesticated one, especially when it returns to living as it
has over the vast majority of its presence on Earth. ....
Dense juniper provides good shelter for wild horses. ...
Chukar is an introduced game species from the Old World but
is promoted by the hunting establishment. I see no
complaints about its presence from the establishment, yet
the same will often viciously attack the returned native
wild horse as a “destructive exotic”. How unjust and bias!
Kawich WSA: Note: a large population of mule deer in Kawich
indicates a possible underlying reason for wanting to reduce
the wild horse population to such a crippling low level.
Bottom: Wild horses enhance wilderness values. Indeed, they
restore an age-old ecological component to the North
American ecosystem that itself was depauperated of its large
mammals during the Pleistocene age (See enclosed article).
P. 38: 2nd Para: I object: it is unfair to establish a horse
free area. You portray the wild horse as a negative rather
than a positive. this is wrong. You omit its many positive
contributions to the native wilderness ecosystem, its
mutualisms as a prey species for mtn. lions, as a seed
disperser for native plants, as a soil builder through its
feces, etc. Clearly you are grinding an axe against the wild
horses. ... No Action: This is an unproven and fatuous
statement, convenient to your purpose of minimizing wild
horse presence within their own legal areas! I protest!
P. 39: Table 8: Provision is made for game birds. This same
effort to accommodate higher, more viable numbers of wild
horses is not being done by BLM! Bottom,
Cultural/Historical: Unfair to lump livestock with wild
horses for assignment of blame. They should be treated
separately! This is a convenient way of targeting wild
horses for practical elimination while the real culprits
continue their abuses. This is disgraceful!
P. 40: 4.2.2: Again you are lumping wh’s w/ livestock. This
is very unfair! ... No! High numbers of livestock have
caused deterioration of rangeland! This shows your
prejudice. ... You equate wild horse reduction with
ecological improvement, casting the wild horses in a
negative light. This is grossly unfair! ... Again prejudice
view in next to last para. ... Livestock should be reduced
here to allow for a truly long-term viable wild horse
population!
P. 41: 4.2.3: Unfair to lump wild horses and burros with
livestock, gives a misleading conclusion and attribution of
blame. 3rd para: You overlook seed dispersal by wild horses,
building of soils. Last para: This is a gross
oversimplification and very misleading and unfair!
4.2.4: Livestock, esp. cattle, camp on riparian areas. Wild
horses use them briefly, then trail off to graze over the
drier areas, and do not camp on riparian like cattle. You
fail to recognize the scientifically proven facts!
P. 42: Top: “Excessive” numbers are arbitrarily defined to
support your agenda of wild horse minimization and to
maximize livestock and big game even in the wild horses’s
legal herd areas. This is grossly unfair! ... AML should be
increased with proper monitoring. ... You should use
Strieter Lite Reflectors to prevent horse and wildlife
collisions with automobiles. These are being used in other
parts of Nevada, U.S., and world. Call Lauren and Julie
Keller at 775-241-0535 and www.strieter-lite.com ....You
admit possible genetic inadequacy due to low population
numbers to which you are bringing wild horses in the Stone
Cabin Complex. Bottom Para: Wrong to assign blame on wild
horses when the degradation has been caused by people,
though innocent livestock, ORV’s, etc. ... This is another
rosy statement overlooking detriment of your excessive
roundup to the wild horses population, which is being taken
to a non-viable level to favor livestock primarily!
P. 43: Top: This is hyperbole! BLM could implement in-field
mgmt strategy that would allow wh’s to intrinsically
stabilize their population numbers without recourse to the
cruel and drastic helicopter roundups. You give no fair
consideration to this very feasible alternative.
4.2.6 Wildlife: Again you overlook wh’s benefit to other
wldf species and portray them entirely as a negative. This
is grossly unfair! Bottom: Grossly unfair to state simply
“Wild horses and livestock utilize the same natural resource
as wildlife”. In the first place you are lumping the two and
in the second place it depends on which wildlife. This is a
gross oversimplification and blanketing statement. You also
ignore now many species of wildlife benefit from the wild
horse presence. Bottom: Another rosy scenario convenient to
your targeting of wh’s. You are wrong when you project an
extremely destructive scenario under No Action. Wild horse
would reach a truly viable level and though a proper
non-intrusive management strategy could stabilize their
population. This is a very unfair and unjust statement and
very far from the truth!
P. 44: 4.2.7: Again very unfair to lump wh’s w/ livestock in
attributing of blame for riparian degradation. You must
separate the two! What about livestock numbers and their
destructive impact? This is the real problem, not wh’s!
4.3: Here you reveal your real agenda: livestock and hunting
maximization even within this legal wild horse herd area &
at the direct expense of the wild horses. This is grossly
unfair!
P. 45: A lot of words all repeating the same preconceived
and lopsided justification for wild horse minimization! Very
wrong! ... When you mention “additive future effects of
livestock grazing”, here you reveal your real agenda of
livestock maximization even here within the wild horses’s
legal herd areas! This is very devious and wrong!
5. Suggested Monitoring: Separate your analysis of the
different species, please!
Stone Cabin Complex Interested Party List: Please place me
on this list. I notice this list is heavily weighed in favor
of wild horse enemies, e.g. ranchers and game managers, etc.
Thank you for your careful consideration of my comments and
please do not follow through with the proposed action as
this is grossly unfair to the wild horses in the wild that
have a legal right to be here in these herd areas. They
contribute so much to the quality of life here in Nevada, my
native state. Please let me know how I can help facilitate a
fairer treatment of and provision for the wild horses in the
wild of the Stone Cabin Complex as elsewhere in your
jurisdiction.
Sincerely,
Craig C. Downer
P.O. Box 456
Minden, NV 89423; ccdowner@yahoo.com
Enclosure: article
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