The Wild Horse Conspiracy

Blue Wing Wild Horse & Burro Complex Gather, Environmental Assessment Scoping Comments due 4/7/16

March 30, 2016

Samantha Gooch, Wild Horse & Burro Specialist, Project Lead (
Humboldt River Field Office, Bureau of Land Management
5100 East Winnemucca Boulevard, Winnemucca, NV 89445
Tel. (775) 623-1519/1518
Attention: Steve Sappington, HRFO Asst. Mgr.,; Winnemucca BLM District Manager Email comments may be submitted: & are due 4/7/16.

Subject: Blue Wing Wild Horse & Burro Complex Gather, Environmental Assessment Scoping Comments

Dear Ms. Gooch & BLM officials:
Thank you for the recent tour to various sectors of the vast Blue Wing Complex of Wild Horse & Wild Burro Herd Areas (HAs) and Herd Management Areas (HMAs) that occurred on Sat. Mar. 19 & Sun. Mar. 20. It was great to get out on the public lands and really see, hear, etc., what is going on with the ecosystem. I appreciate your willingness to explain the BLM’s plan for these areas and its wild horses and burros and to allow me to ask questions and express my concerns. This type of field trip is an important facet of our nation’s democracy and I wish more people would take an interest in their public lands and what is present and occurring here.

Nonetheless, in all honesty I must firmly object to and protest BLM’s plans concerning the relatively small populations of wild horses (Equus caballus) and wild burros (Equus asinus) remaining in this vast and legal complex of 7 HMAs/HAs that was established by the Wild Free-Roaming Horses and Burros Act of 1971 (WFHBA). As our guide, you (Gooch) repeatedly stated there were around 2 million acres of legal areas for the wild horses and burros in the Complex, which I took it to correspond to the original 1971 Herd Areas where the equids lived at the passage of the WFHBA. However, in the BLM Nevada News release from the Winn. District Office of March 4, 2016, it states that “the complex is comprised of 1,230,364 acres. Perhaps this corresponds to the HMAs that have been reduced from the HAs. However my examination of the 2007 Public Lands Statistics (USDI) gives a different set of figures for the seven HMAs/HAs (see below). Is the case that there has been a shrinkage of the original area from 2 million to 1,230,364 acres? If so, this would indicate a substantial reduction of 39% of the lands to which the wild equids were originally entitled. This should then mean that the wild horses and burros would get a much fairer treatment on those lands that remain as their HMAs, particularly as concerns their share of the life-sustaining resources, i.e. forage, water, shelter, and other habitat requirements.

I am very concerned here because I notice that right after the announcement states there are 1,230,364 acres in the legal Blue Wing Complex, it goes on to state that: “[m]anaging wild horse and burro populations is necessary to maintain healthy and viable wild horse/burro herds and prevent deterioration of range and water resources.” Then it continues that: “there are currently an estimated 1,733 wild horses and 704 wild burros in the Blue Wing Complex” …and that “AMLs [Appropriate Management Levels] for the Blue Wing Complex are 333-553 wild horses and 55-90 wild burros.” I notice that in Fiscal year 2007 the AML for wild horses was set at 770 individual, so the allowable wild horses have been cut about in half during the past decade, which, in my opinion, is very unfair, given the large acreages to which they are legally entitled! Also, the BLM announcement makes no mention of all the other user types in the Complex, chief among which appears to be cattle and, to a lesser extent, sheep ranchers, recreational vehicle users, and mining companies. This strikes me as very narrow and exclusionary and signals a possible set-up, or tendentious line of reasoning, that targets the wild horses and burros for blame and, so, for large-scale reduction. Further analysis of the situation has confirmed these suspicions; and here are two major reasons:

A. I have divided BLM’s current populations estimates in the Complex of 1,733 for wild horses and 704 for wild burros into 1,230,364 acres. The results indicate that there are 710 legal acres per individual wild horse and 1,748 legal acres per individual wild burro in the Complex at present. This is surely not an overpopulation but is well below the carrying capacity for this ecosystem, where one wild horse per 200 acres and one wild burro per 130 acres would still be reasonable in the high, wet, cool deserts of the northern Great Basin. These unfair population assignments are aimed at taking away the resources to which the Blue Wing Complex’s wild horses and burros are entitled! Here is an important reminder about the law: according to Section 2 ( c ) of the WFHBA, the legal wild horse and burro areas were to be considered as follows: “… the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros … and which is devoted principally but not necessarily exclusively to their welfare in keeping with the multiple use management concept for public lands.” Clearly, the wild horses and burros are not being provided the “principal” share of resources in the Blue Wing Complex, nor are they being given “principal” status in this complex – but rather they are being marginalized where they should be honored as top priorities! The whole complex taken as a whole has scant numbers of wild horses and burros, and they are far from filling their ecological niche here (see my discussion on Reserve Design below).

B. Currently assigned AMLs show outrageous numbers of allowed acres per individual wild horse and per individual wild burro! The AML for the Blue Wing Complex for wild horses is between 333 at the low end and 553 at the high end for an average wild horse AML of 443 horses. The AML for the Blue Wing Complex for wild burros is between 55 at the low end and 90 at the high end for an average wild burro AML of only 67.5 burros. Thus, at the average of 443 wild horses, there would be 2,777 acres per individual wild horse and at the average of 67.5 wild burros, there would be 18,228 acres per individual wild burro within the complex. In other words, our BLM officials, supposedly the public servants who fairly uphold all the laws of our nation and who fairly represent all the citizens of the United States, must think Americans are either so stupid or so uncaring as to allow this extreme inequity toward the rightfully present wild horses and burros on their own legal lands to pass as something fair and just and in accordance with the law, when nothing could be further from the truth! Both AMLs are terribly unjust and in my opinion illegal, and the AML for the wild burros, of which so few are left, is a sure set up for their inbreeding and die out! To maintain that such a low population number is genetically viable is very misleading and makes a mockery of the true science of Conservation Biology, in my professional opinion as a wildlife ecologist! (See below re: IUCN SSC wild equid population viability standards.)

… We toured major portions of the Blue Wing Complex on the 19th and 20th of March, and I closely observed and photographed the land and its life community, including the wild horses and burros. It became apparent to me during the tour that livestock, primarily cattle but also considerable numbers of sheep, are being given the main share of the grazing resources as well as the water and that other disturbance factors operating in the Complex, notably recreational vehicles including OHVs/ORVs/ATVs and motorcycles as well as mining operations are also having a major detrimental effect upon the ecosystem. When I questioned the BLM officials guiding the tour concerning the relative proportions of resources being allocated to livestock grazers versus wild horses and burros, I was given evasive answers and Wayne, the BLM Range Conservationist, has yet to deliver to me, as promised, the exact figures concerning how the rangeland forage resources, or AUMs (Animal Unit Months), are divided up among the various animal grazers including cattle, sheep, wild horses, wild burros, deer, bighorn, elk, and other wildlife animals including rabbits. I would still appreciate receiving this information and fully intent to give further input as the Environmental Assessment process continues beyond this initial Scoping stage.

Another aspect of public lands protection and management that I am very concerned about are the allotment fences that may be disrupting the free-roaming life style of the wild horses and burros. This important issue was never addressed during the tour, but I expect that it will be in the E.A. It should definitely be addressed as it relates to the wild equids natural rest rotation of foraging patterns over the seasons and course of years … something they naturally perform. Please remember that their free-roaming life style is part of the core provisions for these animals in the WFHBA. This natural movements, i.e. their natural freedom, should not be overly thwarted within their legal areas!

The issue of PZP administration to wild horses and burros was given much approving attention during the tour by you (our chief guide & wild equid specialist, S. Gooch). I am very alarmed because of this! You expressed a strong support for its blanketing application, or darting to all the wild mares. On the first day of the tour, I indicated that some serious adverse effects are caused by PZP both to individual wild horses and their social units, i.e. their bands and herds. I appreciated your allowing me to voice my concerns in spite of another supposed wild equid advocate trying to over-talk me, especially when I described the sound alternative to the PZP approach – Reserve Design. I mentioned some of the biologists who have documented these detrimental and adverse effects of PZP both to individual wild horses and their families and regional populations. I here take the opportunity to give you a list of some of the published studies that corroborate my concerns about both the short- and the long-term effects of PZP, and I urge you and other officials and wild horse/burro supporters to carefully read these and not just cite Dr. Jay Kirkpatrick’s works, which are not impartial, since he was the inventor of PZP and widely promoted it throughout his career and via his Center for Conservation Biology in Billings, MT. Here are some of the peer-reviewed sources publications I would like you to carefully consider:

Ransom, J.I. Cade, B.S., & Hobbs, N.T. 2010. Influences of immunocontraception time budgets, social behavior, and body condition in feral horses. Applied Animal Behavior Science 124: 51-60.
Powell, D.M. 1999. Preliminary evaluation of porcine zona pellucida (PZP) immunocontraception for behavioral effects in feral horses (Equus caballus). Journal of Applied Animal Welfare Science 2: 321-335.
Powell, D.M. & Monfort, S.L. 2001. Assessment: Effects of zona pellucida immunocontraception on estrous cyclicity in feral horses. Journal of Applied Animal Welfare Science. 4: 271-284.
Nunez, C.M.V., Adelman, J.S., Mason, C., & Rubenstein, D.I. 2009. Imunocontraception decreases group fidelity in a feral horse population during the non-breeding season. Applied Animal Behaviour Science 117: 74-83.
Nunez, C.M.V., Adelman, J.S., & Rubenstein, D. I. 2010. Imunocontraception in wild horses (Equus caballus) extends ovulatory cycling beyond the usual foaling season. In review, possibly published now.
Smith, J. 2010. The inoculation of porcine zona pellucida and its behavioral and physiological effects on the feral mares of Shackleford Banks. Princeton University, Princeton, N.J.
Linklater, W.L., Cameron, E.Z., Stafford, K.J., & Vetma, G.J. 2000. Social and spatial structure and range use by Kaimanawa wild horses (Equus caballus: Equidae). New Zealand Journal of Ecology 24: 139-152.
Klingel, H. 1975. Social organization and reproduction in equids. Journal of Reproduction and Fertility. Pages 7-11.
Asa, C.S. 2002. Equid reproductive biology. Pages 113-117 In: IUCN SSC Equid Action Plan. P.D. Moehlman, Editor. Gland Switzerland.
Nunez, C.M.V. 2009. Management of Wild Horses with Porcine Zona Pellucida: History, Consequences, and Future Strategies. Ch. 4 In: Horses: Biology, Domestication, and Human Interactions. Ed. J.E. Leffhalm, Nova Science Publishers, Inc.
Sadlier, R.M.F.S. 1969. The Ecology of Reproduction in Wild and Domestic Mammals. Methuen & Co., Ltd., London, U.K.

Further analysis of 7 HMAs/HAs in Blue Wing Complex according to Public Lands Statistics FY 2007 (USDI, Washington DC): The following are the HMAs in the Blue Wing Complex where the wild horses and burros were recently allowed to remain as best I can determine. Included here are the original codes assigned to the areas and their acreages. These start in the extreme northeast and work to the extreme southwest along this elongated Complex, according to the map in my possession and which I obtained from BLM (Nevada Herd Management Areas, BLM, Nevada State Office, 2/18/11).

1. Jackson Mountains, NV 0208, 275,300 HA & HMA acres + 8,399 other acres; Horse AML: 217; 305 horses present in 2/2003; Burro AML: Zero, zero burros present in 2/2003.
2. Kamma Mountains, NV0214, 54,410 HA & HMA acres + 2,980 other acres; Horse AML: 77; 53 horses present in 11/2005; Burro AML: Zero, zero burros present in 11/2005.
3. Lava Beds, NV0215, 232,928 HA acres + 71 other acres; 232,880 HMA acres + 68 other HMA acres; Horse AML: 148; 102 horses present 11/2005; Burro AML: 16; 18 burros present 11/2005.
4. Seven Troughs, NV0216, 131,409 HA acres + 17,474 other acres; 131,388 HMA acres + 17,474 other acres; Horse AML: 156; 108 horses present in 11/2005; Burro AML: 46; 47 burros present in 11/2005.
5. Blue Wing Mountains, NV0217, 17,854 HA & HMA acres + zero other acres; Horse AML: 36; 20 horses present in 11/2005; Burro AML: 28; 19 burros present 11/2005.
6. Shawave Mountains, NV0218, 87,790 HA & HMA acres + 19,288 other HA & HMA acres; Horse AML: 73; 52 horses present in 11/2006; Burro AML: Zero; Zero burros present in 11/2006.
7. Nightingale Mountains, NV0219, 72,754 HA & HMA acres + 3,690 other HA & HMA acres; Horse AML: 63; 46 horses present in 11/2005; Burro AML: Zero; 3 burros present 11/2005.

Number of Original 1971 Herd Areas (HAs): 7;
Number of Herd Management Areas (HMAs): 7
Total number of original HA acres in 7 original HAs: 872,445 BLM acres + 51,902 other acres
Total number of HMA acres in 7 HMAs: 872,376 acres + 51,899 other acres
Total BLM + other acres for 7 HAs: 924,347 acres
Total BLM + other acres for 7 HMAs: 924,275 acres
Total wild horse AML for 7 HMAs: 770 wild horses
Total wild burro AML for 7 HMAs: 90 wild burros (high limit of present 2016 AML)
Total wild horses present as of FY 2007: 686 wild horses
Total wild burros present as of FY 2007: 87 wild burros
Number of legal HMA acres per remaining individual wild horse: 1,347 acres per individual horse
Number of legal HMA acres per allowed (AML) individual wild horse: 1,200 acres per individual horse
Wild Burros zeroed out from 4 HMAs: Shawave, Kamma Mtns., Jackson Mtns., & Nightingale Mtns.
Burros still allowed AML above zero in Lava Beds (AML = 16), Seven Troughs (AML = 46), and Blue Wing Mtn. (AML = 28).
Total legal acres for Lava Beds, Seven Troughs, & Blue Wing Mtn. HMAs for burros: 399,664 acres
Planned density for wild burros in 3 HMAs: 399,664 divided by 90 = 4,441 acres per individual burro.
As of FY 2007 there were 399,664 divided by 84 remaining burros = 4,758 acres per individual burro.


After reviewing the numbers above, I cannot fail but to conclude that there is a terribly unjust conspiracy operating among BLM officials at all levels, whether the Humboldt River Field Office, the Winnemucca District Office, the Nevada State Office, or the NationaL Washington, D.C. Office and the traditional enemies of the wild horses and burros who are chiefly public land ranchers but also include other agencies such as the Nevada Department of Wildlife representing hunter interests and other exploiters of the public lands including mining and energy companies. Whichever way one looks at the assigned AMLs, they are extremely unjust and basically a prescription for decline and demise of the wild horses and burros. The provision for the wild burros is tokenism at its most shameless and shows the planners to be oblivious to any sense of decency or consideration of the burros themselves and their long-term ecological adaptation and very survival itself!

I come away from this review with a sick feeling in the pit of my stomach, knowing that the wild horses and burros are being mocked and set up for cruel torture, and practical elimination, set up to be genetically non-viable, not allowed to adapt naturally to the ecosystem of the Blue Wing Complex, planned for unnatural tampering with their most intimate reproductive organs (PZP darting) and on a massive scale. These are all crimes that the WFHBA said not to do, yet our very government officials appear to be planning these abuses of the wild horses and burros in complicity with the wild horses and burros worst enemies! I can only voice my strongest and most honest objection to this despicable mockery of the wild horses and burros themselves, most of all, and of the American people and the WFHBA law which their Congressional representatives unanimously voted for. It is a sad state of affairs that our nation has reached with this “plan” for the wild horses and burros of the Blue Wing Complex! It is a sinister plan that rivals other notorious genocides for America’s Native Americans, the Buffalo, the Wolf, the Grizzly Bear, and so many other fellow species that modern man has derided, belittled, denigrated, mocked, blamed, and made scapegoats of! It seems that the issues of truth and fairness, or justice, hardly enter into the minds of schemers who seem to idolize decadent ways of life and status quos that are killing life on Earth, and concerning which they seem to be either oblivious or simply not to care!

I can only pray that my words will not fall on deaf ears, that some true spark in the consciences of those who read them may be ignited and that much less cattle and sheep, ORVers, mining and other forms of violence against the ecosystem may be enacted and that a much larger number of wild horses and burros will be allowed to restore their respective populations here in their legal areas on the public lands. It is they, the horses and burros themselves who should be teaching us humans how to live better on this wonderful planet Earth. They are ancient presences and true healers of the land and ecosystem – and if we humans will only allow them, they will show us the way to a healed and harmonious relation with the Rest of Life. …In the ultimate analysis, if we humans do not wake up soon, it will be too late!

Remember that 2,500 reproducing individuals is the true viable population size in the wild for an equid species according to the IUCN SSC Equid Specialist Group as noted on page 5 of its Action Plan for the world’s remaining equids, a figure many times greater than your AML for the burros and several times greater than your AML for the horses (Duncan, P. 1992. Zebras, Asses, and Horses: An Action Plan for the Conservation of Wild Equids. IUCN Species Survival Commission, Equid Spec. Group, Gland Switz.) Also remember that “in the wild the true vigor of the species is preserved,” which is so true! And if any species deserve to have their true vigor and long-term survivability on Earth preserved it is the horse and the burro, real paragons of Nature!

I end these scoping comments with a call for you to greatly reduce the cattle that are camping on the various springs you showed us on the tour, and any other similar water sources throughout the Complex. Please do not blame the deterioration of these watering areas on the wild horses and burros. This alarming situation is not their fault! Do not set them up for blame, make them scapegoats for ecological abuses whose true perpetrators are people, not these restorers of the North American ecosystem. And also consider the pumping by wells I mentioned during the tour and how this affects the water tables, especially in the mountains, for there is definitely a strong relation. Also consider that the erosion caused by heavy rains is related to the overgrazing and ORV abuse of highland watersheds, since the “living sponge” that could absorb and equitably release this water over the seasons and that is present in healthy vegetation and soils is destroyed by these human-foisted influences.

I strongly recommend that you erect strong fences around the springs and stream sources, etc., and that you provide for strong watering troughs on the sides of these for large herbivores such as the wild horses and burros, mule deer, and livestock. There are some excellent fence and trough supplying companies that can meet our needs here in a very adequate way. This will allow these springs, streams, ponds, lakes, and headwaters to be restored; and it is of crucial importance to the survival of the ecosystem that they be so restored. As the saying goes: ‘water is the lifeblood of the desert.’

During the tour it surfaced that in certain areas, collisions were occurring between vehicles and wild horses and burros as well as other animals such as deer and cattle, mainly around highly transited public roads. In these areas, I very much recommend that you erect the Strieter-Lite vehicle headlight reflectors. These have proven very effective in nearly eliminating such accidents involving many kinds of animals, from large herbivores like horses, deer, and cattle to smaller ones like rabbits and coyotes. The website of the company is and a knowledgeable representative of the company I recommend you contact is Ms. Julie Keller, a highly educated wild horse advocate who has introduced these ingenious devices to the State of Nevada, as elsewhere. Her email is and telephone is (775) 830-7739.

Finally, I urge you to check out my Reserve Design proposal in Ch. IV of my book The Wild Horse Conspiracy ( Reserve Design is a branch of Conservation Biology that I studied and whose sound principles I have followed in my career as a wildlife ecologist, including in the Andes of South America. By taking a win-win Reserve Design approach to the Blue Wing Complex, this splendid area could be restored and made to flourish as a wild-horse-&-burro-containing ecosystem, which is an enhanced ecosystem – and I am fully willing to help you realize this, both as a professional ecologist and as one whose ancestral pioneer roots are in the Lovelock area. But it is incumbent upon we people to possess the humility and the patience, the wisdom, the good faith and uplifted vision to not just make but to let this happen … to allow the horses and burros and the whole complex of plants and animals to restore their own inter-harmonization, as they surely can and will if only we humans allow. We should respectfully learn from rather than arrogantly impose upon them.

In the Blue Wing Complex, as in the Earth itself, the choice is ours. Do we merely allow old and destructive ways of life to continue their headlong course to further disaster, or do we courageously chose to follow a realistic, proactive course into the future, one lighted by a positive vision for all that life can yet become, meaning ALL of life, including these ancient presences known as the horses and the burros. They have done so much for us humans over the centuries, even millennia, but their greater place and role is in the awesome natural world that gave them birth over millions of years and which all Earthlings, including those of us in human form, should greatly respect and set about to restore to its full well-functioning and in its fuller glory!

Sincerely yours,

Craig C. Downer
Wild Horse and Burro Fund/Andean Tapir Fund
P.O. Box 456
Minden, NV 89423













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