September 7, 2017

Garret Swisher, Wild Horse & Burro Specialist
BLM Black Rock Field Office
5100 E. Winnemucca Blvd. Winnemucca, NV 89445
Email: BLM_NV_Smoke_Creek_Complex_Gather_EA@blm.gov
Source document: http://bit.ly/2vSSE9Y
Comments due in by 4:30 PM Pacific Daylight Time on September 10, 2017 (alright by email)
Re: Smoke Creek Complex of Wild Horse HMAs Proposed Gathers of Wild Horses EA
DOI-BLM-NV-W030-2015-0001-EA

Dear Sir/Mame:
Thank you for providing me with your Environmental Assessment for the gathering of wild horses within the Smoke Creek Complex for wild horses. This consists of the Fox and Lake HMA and the Buffalo Hills HMA. I have both visited and overflown these HMAs and viewed their wild horses and habitat both recently in early August (flight) and previously during on-the-ground as well as flight overviews that date back since the early 1980s. I am concerned that under proposed Alternative A, the hardy and special wild horses here would be overly compromised as concerns their natural vigor and survival abilities. Taking them to the mid level of the AML, or to 414 horses, works out to leaving only one wild horse per 748 acres (total 309,585 acres in Complex; AML range: 310-518). Even in this arid area, this is a grossly unfair allocation and proves a favoring of other uses within the legal HMAs of the wild horses. I am also very concerned about your planned application of PZP-22 and the gelding of 105 of the stallions. This would further contribute to an unnatural state where the survival ability in this demanding habitat is overly compromised. I have observed the pitiful degree of frustration and dysfunction experienced by remaining wild horses who have been PZPed and gelded, and it is not a pleasant scene. Such leads to the breakup of their social structure –of paramount importance to their long-term survival – and to the anguish brought on by hormone imbalance, and the overall weakening of their immune system, which sets them up for decline and eventual demise. Basically, this is very contrary to the “minimum feasible” management tenet of the WFHBA. Alternatives B and C, also suffer from similar fatal flaws as far as the wild horses long-term well-being is concerned.

Your failure to reveal the relative proportion of livestock forage allocation vs. wild horse forage allocation is also egregious. This should be clearly spelled out in your document. In general, you are treating the wild horses in an unfair manner and failing to fend for their legal rights to forage, shelter, water, and other year-round habitat requirements. Nor are you safeguarding their reproductive vitality – so important to long-term survival in demanding habitats such as Smoke Creek Complex. Your plan counters the operation of natural selection which would permit them to realize their natural place in this sizeable legal area of theirs. Basically you are allowing other interests, particularly livestock, to have the monopoly here and are squeezing the wild horses into an unnatural situation. This should be considered contrary to the Wild Free-Roaming Horses and Burros Act. I therefore urge you to redo this EA and to assign a higher AML and a greater forage allocation, to curb livestock monopoly within these wild horse HMAs, as well as other possible monopolizers of resources, such as mining, or ecosystem damagers, such as ORVs. And you should pay more attention to the needs of wild horse appreciators and observers and give a more positive view of the wild horses that encourages the public to get to know them in the wild.

In conclusion, I favor Alternative D, the No Action alternative, because A, B, & C, are alike in their gross unfairness to the wild horses. I urge you to redo this EA and to employ the sound principles of Reserve Design in order to establish truly long-term viable, ecologically well adapted (to this particular ecosystem), and naturally self-stabilizing populations, or herds, of wild mustangs here. Please feel free to contact me for further details concerning Reserve Design.

Sincerely,

Craig C. Downer
Wildlife Ecologist
Wild Horse and Burro Fund
P.O. Box 456
Minden, NV 89423-0456