Comments on Draft E.A. for Population Control Research on Wild Horses for the Conger Mountain and Frisco HMAs

Subject: Comments on Draft E.A. for Population Control Research on Wild Horses for the Conger Mountain and Frisco HMAs

May 14, 2016

BLM Fillmore Field Office

95 East 500 North

Fillmore, Utah 84631

Tel. (435) 743-3100

Fax (435) 743-3135

blm_ut_fm_comments@blm.gov

In response to public announcement on www.kcsg.com/view/full_story/2715862/article-BLM-Seeks-Public-Comment-on-Proposed-Wild-Horse-Gather-in-Central-and-Southern-Utah ;

Dear Sir/Mame:

I strongly object to the proposed sterilization experiments involving the gelding of wild stallions in the Conger Mountain and Frisco HMAs.

These are enormous legal areas, 151,506 acres for the Conger Mountain HMA and 60,367 acres for the Frisco HMA. Here wild horses should

be given principal consideration under the Wild Free-Roaming Horses and Burros Act (Section 2 c) and other acts. And you should adhere to the

“minimum feasible level” tenet of this Act that is found in Section 3 a. Sterilization is far from “minimum feasible level” of management!

Only Alternative 2 is acceptable of the alternatives you presented in the E.A.

The lost of male vigor in the stallions would have serious disruptive effects upon the individual bands and the encompassing herds to which each band belongs.

This would result in less control over the young horses, which could actually result in more reproduction. It has been proven that the mature stable bands

produce less offspring and come into balance with available resources. See ISPMB website and also www.thewildhorseconspiracy.org (various articles).

I am advocating for the employment of a Reserve Design strategy for the provision of adequate habitat suitable for long-term

viable horse populations. Through appropriate restrictions on area occupied, we would see the “filling of the wild horse niche” and natural self-

stabilization of the herd. This is what ecological “climax” species are capable of, given the chance. But this requires patience and caring.

I would welcome the opportunity to discuss this approach with you further and have given my number below.

Again, I wish to register my strong objection to the proposed sterilizations. I have visited some of the Utah wild horse herds, such as the

Moriah last year and the herds in western Utah in the area of this project. I have reviewed the overall AML numbers and areas BLM is planning

for the few wild horse herds that remain in the state. In general I feel that these herds are being slighted as to their rightful resources and population levels.

They are being targeted as does not befit honorable public officials sworn to defend all the laws and interests in our great nation.

I recommend that you increase allowed wild horse population levels to more truly viable levels by expanding their resources while at the same time

employing Reserve Design. You should do your duty by requiring other competing interests to back off on their

attempts to monopolize the public lands at the expense of those truly under-populated and overly squeezed mustang herds and their habitats in your awesome state.

These horses would be such a wonderful asset to your state if treated fairly and with true appreciation and respect.

Sincerely,

Craig C. Downer, ecologist

Wild Horse and Burro Fund

P.O. Box 456

Minden, NV 89423