January 16, 2017

Pine Nut Mountain Wild Horse Herd Management Area Plan, BLM planning team
BLM, Nevada State, Carson City District, Sierra Front Field Office
5665 Morgan Mill Road,
Carson City, NV 89701

Attn: John Axtell, Wild Horse & Burro Specialist

Email input to: PineNutHorses@blm.gov; Fax input to: 1-775-885-6147

link to document: http://bit.ly/lt1Opmz (Public input link also here); comments due by Jan. 22, 2017.

Dear Sir/Mame:
Thank you for providing me with the opportunity to give input on your draft Pine Nut Mountain Wild Horse Herd Management Area Plan. I have now reviewed this extensive document together with maps, tables, and public comments, and appreciate your efforts to gather and present this information for public scrutiny. However, in reviewing this report and proposal for the ten-year future of this important wild horse herd, I am struck by a certain narrowness of focus, and I expected better of you as public officials. Basically there is a failure to give the fuller context of interrelated factors in which this unique wild horse herd and its unique habitat are embedded. While there has been an improvement in recognizing some additional factors such as the effect on the Pine Nut Mountain aquifer by water pumping activities in surrounding valleys, there should have been a much more proactive stance taken to further investigate and to improve the situation for the benefit of the wild horses, other wildlife and plant species, and the ecosystem as a whole.
Here I quote from page 34 of that section of your report entitled: “Final Summary of Current Conditions”: “Data is not available to determine the exact causes of loss of riparian functionality, e.g., soil compaction, groundwater drawdown from surrounding valleys, or climate change …” – These are major factors, not just as concerns the Pine Nut Mountain herd and ecosystem but as concerns wild horse/burro/wildlife populations and their respective habitats throughout the West. Rather than just giving this a passing mention in your plan that will govern for the next decade, I urge you to quantitatively and qualitatively analyze these and other related factors. From my earlier report submitted to you, you will note that OHVs (Off-Highway Vehicles) are a major factor that are undoubtedly compacting soils, and the pumping of lavish amounts of water by human residents and businesses in the surrounding communities are undoubtedly having a serious deleterious effect on the aquifers of the Pine Nut Mountains (as documents I reviewed in the Carson City USGS office revealed). As public officials, you should be striving to provide more abundant and evenly dispersed water sources for the Pine Nut Mountains as a natural and integrated ecosystem, including its relatively small wild horse population. Doing so would prove key to solving many of the issues you raise about the impacts that wild horses are having, especially around sources of water. By alleviating these pressures on certain limited water sources, the wild horses would be enabled to more broadly distribute their foraging pressure, both in space and in time. This is definitely doable; and I am confident that, with all the wild-horse-supporting people living in and around or visiting the Pine Nut Mountains, there would be an enthusiastic response were you to take the initiative here. As a wildlife ecologist who grew up in and around the Pine Nut Mountains and as one quite familiar with the herd and its history, I again offer my collaboration.
To continue: I am also concerned about your ignoring of my point concerning the patchiness of wild horse foraging patterns and how this relates to preserving grasses and other types of foraged species in the ecosystem. Such patchiness of grazing is linked to the horses’ great mobility and naturally tends to conserve and ensure the ongoing reproduction of the plants being foraged, provided the wild horses in question are not forced into unnatural, for example, overly fenced or in other ways constricted areas. (For details, see my earlier submitted report, also included in your HMAP’s public comments section.)
Since your draft HMAP was published on December 22, 2016, major storms have occurred in Nevada, California, and other parts of the West. Consequently, high levels of precipitation in the form of both snow and rain are rapidly restoring depleted aquifers, raising water tables, restoring vegetation and their dependent animal symbionts. For this reason, I call upon you, as responsible and responsive public officials, to readjust your plans and assign higher and more truly viable population numbers for the Pine Nut wild horse herd. This will also prove a very wise step in preventing possible upcoming catastrophic wildfires. With the increase in vegetative growth that is certain to result from this increased precipitation and as the Pine Nut Mountain ecosystem rebounds from earlier drier conditions, an abundance of vegetation will be subject to drying, particularly during the late spring, summer and early fall seasons. If you reduce the herd from over 500 (which you claim is the current level) to the very low and marginal level of ca. 90 horses, as you have indicated, there would be insufficient wild horses to prune down vegetation so as to prevent catastrophic wildfires. These fires could reach such extreme intensities as to sterilize soils, kill off wildlife species, including the “sensitive” Bi-State Sage Grouse, as well as rare and endangered plants, such as Gordon’s Ivesia. Basically, I am asking you to recognize this positive, ecologically & economically valuable role that the wild horses play in our shared Pine Nut Mountain ecosystem, and to allow them to more greatly fill their natural, ecological niche here, and not to be reduced to a frustrated, thwarted, mere “token” population. This would do great injustice to these magnificent animals, who have done so much for our human kind. Is this how they should be repaid?!
This brings us to a crucial point: I was very disappointed to see that your draft HMAP proposes to maintain the very same substandard & sub-viable wild horse population range at 90 to 120 adult horses. This is even lower than BLM’s typical, though substandard, recommended level of 150 & is far below the IUCN Species Survival Commission’s Equid Specialist Group’s recommendation of 2,500 individuals for a wild equid population’s viability in the wild (see my earlier submitted report for further discussion & pertinent references.) Related to this is your dismissal of the many vociferous pleas from many wild horse defenders for you to increase the Pine Nut herd’s Appropriate Management Level (AML) to a more truly viable number & also your failure to recommend a restoration of this herd back into the ca. 50% of its original, legal 1971 Herd Area in the southern half of the Pine Nut Mountains. This is a serious deprecation on your part, both of the wild horses & their importance to nature, & of the many members of our human society who greatly value them. These beautiful and spirited animals do so much for our humanly experienced quality of life! Just locally many thousands of people & many millions in our nation and around the world cherish these wild horses. To overlook our wishes concerning the mustangs is a serious abrogation of responsibility as public officials/servants sworn to uphold all the laws of the land and not just some (usually those favoring the rich and powerful, including corporations).
I again take this opportunity to urge your restoration of this herd to as much of the full 1971 Pine Nut Mountain Herd Area as possible. This, along with securing more reliable and evenly dispersed water sources would enable you to cancel your plan to gut this precious and unique herd and jeopardize its long-term viability, ecological adaption, and natural self-stabilization (all generations in the making). In place of this I strongly recommend that you adopt a Reserve Design approach for the herd’s protection, preservation, and management (see my earlier input). What you are presently proposing is a mere token and disrespectful, minimalist effort and provision on behalf of these unique mustangs—a vital branch of this “national heritage species”!
I thank you for at least publishing in the present document much of my input to your earlier Pine Nut Wild Horse HMAP process. This includes the summary results of my ecological evaluation, aerial census, and species list. This will allow members of the public to get another take on what is happening with the Pine Nut wild horses and their legal habitat and to compare this with the evaluation and recommendation your BLM team presented.
Before I forget, I must voice my disagreement with the statement on page 77 that the native bunch grasses of the Great Basin evolved in the absence of horses. I have read a great variety of scientific, peer-reviewed studies on this subject, so I know that this one view is not the only one and that there exists an alternative view that is substantiated by sound biology and ecology that upholds a benign, mutualistic symbiosis between horses and the grasses and other vegetation they consume. This has to do with the horses adding more soil-building humus through their droppings and also their dispersing more intact seeds and from a greater variety of species when compared with those ruminant species, e.g. cattle, sheep, deer, elk, bighorn, that our society excessively promotes. The fact that horses, burros, and equids in general lend a very much needed balance to the Pine Nut Mountains’ – as to the West’s and North America’s – ecosystem is one we should not ignore. And I urge you to read my book: The Wild Horse Conspiracy, particularly Chapters I & II to gain a greater understanding on this critical question. Though I have made a copy of my book available to your office, feel free to contact me if you need another copy. I also have a peer-reviewed article I could share that would be valuable to you.
I would like to request the raw data, including photos and tabulations for your census flight over the Pine Nut Mountains made in April 2016 and by which you estimate the wild horses’ population at 534 and calculate the herd’s growth rate.
It is very important that you plan and implement Range Improvements for the wild horses in the Pine Nut Mountain in order to allow them to reach a more truly long-term viable, ecologically well integrated, and naturally self-stabilizing population. This is legally possible for you to do under provisions of the Code of Federal Regulations (CFR) 4100. Conjointly you should set up Cooperative Agreements under Sections 4 & 6 of the WFHBA for the benefit of the wild horses and their habitat. You should incorporate the Singatze and Buckskin minor mountain ranges on the east side of the Pine Nut Mountains into the Pine Nut Mountain Wild Horse HMA. These are vital habitats for the wild horses and should have been originally included in the Pine Nut Herd Area, as the horses were there in 1971! They are especially important as wild horse over-wintering habitat. Also remember that Nevada is an Open Range state and that it is the responsibility of property owners to fence out wildlife, including wild horses, if they do not want them onto their property that adjoins the HMA. Thus, I urge you to restore the Deer Run Road wild horses. Also you should restore the Pine Nut wild horses’ historic access to the Carson River, both on the northern and northwestern boundaries of the Pine Nut Mountain HMA.
It is your responsibility to protect and defend the rights of America’s last remaining wild horses and burros. So few actually remain in the wild and on our public lands; and these must not continue to be targeted for further reduction or elimination. This would be contrary to the core intent of the Wild Free Roaming Horses and Burros Act as well as to several other acts, including a more honest and benign interpretation of the Multiple Use and Sustainability Act, the National Environmental Policy Act, and the Natural Historical Heritage Act. Mustangs are a valuable “living heritage” and no herd more so than that of the Pine Nut Mountains (see my earlier report).
I look forward to further discussion with you concerning this very vital wild horse issue. Please do not hesitate in contacting me.
Taking this opportunity to wish you & the wild horses in your charge bright & fulfilling new and future years, I am,
Sincerely,

Craig C. Downer
Wild Horse and Burro Fund
P.O. Box 456
Minden, NV 89423
ccdowner@aol.com