Spring Mountain Complex, s. Nevada, input to stave off tragic plan for wild horses and burros, June 30, 2013

June 30, 2013

Ms Terri Frolli, Project Leader; Mr Randall G. Swick, Spring Mtn. NRA Area Mgr.; Ms Deb MacNeill, BLM Pahrump Field Office Mgr.
4701 North Torrey Pines Drive
Las Vegas NV 89130-2301
Email: smwhbcomplex@fs.fed.us
Re: Spring Mountains Wild Horse & Burro Complex Herd Management Area Project Plan, Humboldt-Toiyabe Nat’l. Forest, Spring Mtns. NRA & Bureau of Land Management, So. Nevada District. USFS Project # 40960; BLM Project # DOI-BLM-NV-S030-2013-0010-EA

Dear Sir/Mme:

Thank you for sending me your notice of proposed action. I have carefully read through this and in turn offer for your careful consideration the following:

I fully understand your duty to fairly represent all legitimate interests upon the public lands and their ecosystems. Knowing this, I am very disappointed that you continue to grossly minimize the wild horses and burros in the vast 784,325-acre Spring Mountains Complex, 21% of which is managed by USFS and 79% by BLM.

I have visited the Complex and its equid herds many times dating back to the 1970s but with special intensity during the past six years. In 2010 I even flew around the complex to get an overview of this fascinating and bio-diverse range and to assess the population density and distribution of its wild horses and burros. I have spent many days observing the wild horses and burros around Cold Creek and in diverse seasons, and have also observed wild horses on the western side of the Wheeler Pass HMA and the wild burros of the Red Rock JMA.

These animals are not the overpopulating misfits they are too often portrayed as! As returned native species in North America, they are simply in the process of filling their respective ecological niches; and their filling such enhances the Spring Mountains Complex ecosystem. As members of the mammalian order Perissodactyla and its family Equidae, they possess distinctive biological characteristics and a distinctive ecological role that is, in fact, complementary to the many other species of plants and animals inhabiting this region. I say this not because I am merely partial to these beautiful animals but because of my objective investigation of their natural history and ecological relationships over many years. These are semi-nomadic species who possess post-gastric, or caecal, digestive systems as opposed to the ruminant digestive system of the other large herbivores who inhabit the Spring Mountains: bighorn sheep, the mule-tailed deer, and Rocky Mountain elk. There have been elaborate, multi-year studies that prove the remarkable extent to which wild equids actually assist such ruminant species, as well as many other species of plants and animals, large and small. These equids act as natural gardeners wherever they roam, fertilizing and building the nutrient-rich and moisture retentive humus content of soils. This is due in large part to the slow decomposition of their droppings. And they also disperse the viable seeds of many diverse native plant species that find a fertile bed in which to germinate in their slowly decomposing feces. In this way, naturally living horses and burros contribute to the ecosystem they inhabit to a greater degree than do the ruminant grazers who more thoroughly decompose the forage they ingest, leaving in their droppings relatively nutrient-poor and drier organic material. This is abundantly proven but it takes that rare commodity known as an open-mindedness to recognize these wonderful facts.

The greater story concerning horses’and burro’ reoccupation of the Spring Mountains region, as well as many other parallel regions, reveals that a wild-horse/burro-containing ecosystem is an ecologically enhanced ecosystem, one with a giant missing piece, or role, that has been restored. Rather than cursing their presence here, this is true cause for celebration, for this contributes to the thriving of the many other marvelous plants and animals who go together in this magical, and uniquely alive and inter-dependent community. Both the horse and the burro are species whose origin and vast majority of time on Earth – measured in the millions of years – occurred in our amazing part of our world: the North American continent. And so much of the inspiring beauty of these animals, I believe, is owing to their natural harmony and benign fitting in with all the Rest of Life – including us humans – if we would only recognize this!

Your 26-page document is full of clever wording and the tricky presentations of filtered and incomplete facts and their biased interpretations. These do no justice to the wild horses and burros with rights to inhabit their several legal herd areas (BLM) and territories (USFS) nor do they do justice to members of the General Public, both in southern Nevada and in the United States as a whole. Among the General Public are literally millions of people who truly love the wild horses and burros and their freedom to truly be themselves out in the wide-open spaces of the West. As public officials you are sworn to fairly and justly represent all the laws of the land and not to favor big vested interests such as public lands ranchers, big game sports hunters, mineral and energy extractors, and big profit-driven corporations that would ride rough-shod and trample down many values and presences on the public lands if so allowed. Wild horses and burros in the wild are a Quality of Life issue, both for America and for all the world. They must not be sacrificed in order to placate greedy, narrow-minded, and selfish interests who do not have the long-term Common Good uppermost in their value and priority systems.

Section 2 c of the Wild Free-Roaming Horses and Burros Act of 1971 (WFHBA) plainly states that the land where the wild horses & burros lived in 1971 (meaning their year-round habitat by any fair and judicial view) were to be “devoted principally … to their welfare …” The proposal contained in your document, however, ignores this core legal intent by assigning ridiculously low Appropriate Management Levels that are both genetically non-viable and would create tortured populations of wild horses and burros. These would be frustrated in realizing their natural, ecological niche, or place in the life community. Here I present a Table for your consideration based on the data you have supplied in your document:

Table of Existing and Proposed Acres per Individual Wild Horse/Wild Burro for Spring Mountains Complex, USFS/BLM Joint Management Areas (JMA) Proposed Action (WH = wild horse; WB = wild burro) Lettered Columns: A = WH Median
2013 Pop. Est.; B = WB Median 2013 Pop. Est.; C = WH Median 2013 Proposed AML; D = WB Median 2013 Proposed AML; E = Total JMA acres; F = WH # acres per individual, current 2013 pop.; G = WB # acres per individual, current 2013 pop.; H = WH # acres per individual, proposed AML 2013; I = WB # acres per individual, proposed AML 2013.

JMA A B C D E F G H I
Red Rock 77 72 22 39 187639 2437 2606 8529 4811
Spring Mtn.Wheeler Pass 369 137 57 28 379812 1029 2772 6663 13565
Johnnie 105 207 24 81 216874 2065 1048 9036 2677
Total/Overall 551 416 103 148 784325 1423 1885 7615 5299

The mathematical analysis of acres per existing individual 2013 wild horse/wild burro and proposed 2013 AML individual wild horse/wild burro reveals the gross unfairness of the proposed joint BLM/USFS plan for the Spring Mountain Complex toward the legitimate wild horse and burro populations. I have double checked these figures and they clearly reveal: (1) that the current wild horse and burro populations in the Complex are not overpopulated, but rather are still in the process of filling their respective horse or burro ecological niches in this region. Even in the drier portions of the Complex, the number of acres per individual wild horse or burro should be in the low hundreds per individual, not in the low thousands per individual (existing 2013 population) and much less in the several thousands of acres per individual wild horse or wild burro! That the proposed Appropriate Management Levels for the enormous 784,325-acre Spring Mountains Complex plans to allow for only one individual wild horse per 7,615 legal JMA acres and for only one individual wild burro per 5,299 legal JMA acres reveals the disgusting extent to which our BLM & USFS public officials are subverting the true intent and purpose of the unanimously passed WFHBA! This is a travesty of justice and must not be allowed by a caring public! It makes mockery of American democracy and caters to the traditional enemies of the wild horses and burros, especially in the case of the Spring Mountains Complex to the big game hunting interests represented by the Nevada Department of Wildlife. This agency has traditionally sought to eliminate wild horses and burros from the state of Nevada, including its majority of federal lands and in spite of their great popularity with the general public both in this state and nationwide.

As a wildlife ecologist and individual human being, I wish to go on record that I will legally protest and challenge this proposal through every means available. It represents a hostile betrayal both of the magnificent wild horses and burros and their freedom; and of the majority of Americans – the General Public – whose Quality of Life would be grievously damaged were this shameless and deceptive plan to be officially adopted and implemented! Below I list some of my major objections on a page-by-page basis to points contained in the BLM & USFS proposal.

Page # Specific Comments
2-3: I propose that you employ Reserve Design in order to achieve a “Thriving Natural Ecological Balance” with “naturally self-stabilizing populations” of wild horses and wild burros. This is a branch of wildlife conservation that has been used in many places and for diverse species and ecosystems. I describe and adapt its principles for the wild horses and burros and their inhabited ecosystems in a proposal as well as in my recent book The Wild Horse Conspiracy, Ch. IV, and would be glad to send you a copy of both.

6: Concerning water in the Johnnie JMA, BLM & USFS should take steps to secure year-round water sources for the wild horses & burros here. Both agencies should avail themselves of the Implied Federal Water Rights that came with the WFHBA.

Allow the wild burros to naturally occupy the drier habitat to which they are well adapted, such as the Mojave Desert, but do not interfere with the natural process of niche separation between the wild horses and the wild burros. Simply allow it to occur.

Various pages & tables: There is clearly no overpopulation of wild horses and burros in the Spring Mountains Complex. The populations of both species should be allowed to fill their respective ecological niches and naturally self-stabilize within their bounded but sufficiently large habitat areas. This they will do as ecological “climax” species. (See my description of Reserve Design for ideas on how to contain these wild-equid-containing ecosystems in Ch. IV of my book, also for definition of “climax”.)

Whole document: You need to contrast the wild horses & the wild burros with other herbivores living in the Spring Mountains Complex, especially the big game species for which the Nevada Dept. of Wildlife is managing: elk, mule-tailed deer, bighorn sheep. You give no relative comparison of forage consumption, annual migration patterns and overlaps, type of forage consumed by the various species and dietary overlap, and similar factors.

Whole document: You should recognize the very crucial role wild horses & wild burros play in preventing catastrophic wildfires by eating the coarser, drier, more flammable vegetation over broad areas and their converting this via their droppings into rich and moist soils. With their post-gastric digestive system, they are ideally equipped in this capacity. To ignore this salient biological fact is wrong. The ruminant grazers: deer, elk, bighorn, cattle, etc., are not nearly as capable in this regard and burn up their metabolisms in the more thorough digestive processing of such dry and coarse vegetation. In the era of Global Warming, this is a major consideration, as the wild horses & burros, if allowed to fill their niches, will greatly assist in catastrophic fire prevention. In many regions where equid populations have been either drastically reduced or eliminated, catastrophic and extensive fires have resulted due to their no longer being able to consume and process the dry vegetation for which their post-gastric digestive systems are ideally suited. (See my book, Ch. II & Bell, R.H.B, 1970 reference in book’s bibliography.)

5, top: As returned native species, wild horses & wild burros restore and enhance the wilderness ecosystems of the Spring Mountains Complex. They should not be excluded or overly reduced. It is biased and unfounded to treat them as non-natives (see Ch. I of my book).

6 & whole doc.: The wild horses & wild burros must not be arbitrarily excluded from slopes greater than 30%, but rather the various species present, including bighorn, deer & elk, should be allowed to naturally define their niche space within the Complex. In fact, the presence of the wild equids will help the ruminant grazers, by enhancing their habitat and making it more productive (see references to two works by Fahnestock & Detling in my book’s bibliography).

Whole doc., incl. p. 5: Another point is that the Spring Mountains Complex’ sloped terrain where not exceedingly steep can to a large degree multiply habitat, or niche space, for many species. This is due to the provision of greater surface area exposed to precipitation, air, and sunshine (see p. 36 of my book).

Not allowing wild horses & wild burros to fill their ecological niches actually thwarts their natural population stabilization because this interferes with harmonious processes of social and ecological adaptation that take time and being left alone (see pages 125-128 of my book).

6: Per Section 6 of the WFHBA, BLM & USFS need to set up “cooperative agreements” with other agencies, private parties, etc. Also options under Section 4 of the WFHBA should be promoted in order to secure complete habitats, including adequate water, for long-term viable and ecologically well-adapted wild horse & wild burro populations of the Spring Mountains Complex.

6 bottom: In spite of your claim that there is not enough forage, are not the wild horses’ & wild burros’ very abilities to survive proof that there is adequate forage and water for them?

7: This 30% utilization standard can be quite arbitrary and unjust to the actual species inhabiting the ecosystem. Such standards can be out of tune with nature’s balancing processes over time, such as the natural shifts in occupied annual home range over the generations that both wild horses and wild burros display (see Pellegrini 1971 in bibliography of my book).

7 bottom: I caution against using this proportional count of horse fecal ball piles to deer and elk pellet piles. This fails to differentiate between the past-gastric equid digestion (less degraded feces hence taking longer to decompose) and the ruminant digestion (fresh feces already more degraded and hence taking less time to be absorbed into the soils, though providing relatively less nutrients thereto). (See my book, pages 33-34 & 46-48.) These ecological facts are not taken into account, hence the chart in Figure 2 is misleading.

8: You state that your agencies, the BLM & USFS, are trying to maintain a “thriving natural ecological balance.” However, by overly interfering with the wild horses & wild burros, their natural tendencies to fill their ecological niches and to establish natural stabilizations of their populations, your agencies are not respecting what is in truth natural, i.e. your agencies are working contrary to natural processes.

For example, your agencies determination of “excess” is arbitrary. The wild horses & wild burros here are not overpopulated by any objective view. Please take another look at my table deriving # acres per individual wild horse/wild burro. This is on page 3 of this input. To an objective ecological view, these two species are under-populated within the Spring Mountain Complex. Drastically reducing and arbitrarily limiting the wild horses and wild burros to such low, non-viable AMLs, as you are proposing, is anything but “minimal feasible management” and your injection of the phrase “minimal feasible population” is your deceptive invention. Both run entirely contrary to the true intent and purpose of the WFHBA!

8 bottom: Yes, natural movements within JMA must be assured and interior fences removed, also impediments to water access. Also, water sources drained unnaturally to outside JMA must be restored to the extent possible. Exercise your Implied Federal Water Rights (see p. 120 of my book). Also, with regard to natural wild horse and wild burro movements outside the JMA, this often constitutes a natural rest rotation and you should examine possibilities in Sections 6 & also 4 of the WFHBA to see whether cooperative agreements, etc., can be arranged in order to accommodate these movements.

Another point here: what is natural about these arbitrary determinations of population levels set at very low Appropriate Management Levels? To a much greater extent, you should let the laws of nature decide at what levels the wild horses & wild burros should be! Your use of the word “natural” is deceptive.

9 middle paragraph: What are the standards for USFS’ “satisfactory condition or better”? Likewise for BLM’s “healthy rangelands”? This paragraph reveals these agencies’ biased attitudes toward the wild horses and wild burros! The blanketing statement concerning “degraded vegetation” with wild horses & wild burros as implied causal agents is unfounded in fact. No proofs are given. Also it seems you are using MCBB as an excuse to greatly reduce wild horses & wild burros without proof of their detrimental effect. These equids may actually be beneficial to the endangered Mt. Charleston Blue Butterfly. Also, there is no discussion of how large numbers of deer, elk, or even bighorn may be affecting this species.

9 ff: Re: Proposed Action, you need to seriously consider Reserve Design as an alternative to this heavy handed and disrespectful proposal (see earlier comments on Reserve Design).

11 top: 60% male to 40% female sex ratio adjustment. I object! This would disrupt the natural harmony within the wild horse & wild burro societies and further thwart the stable, mature bands, or comparable burro groups, and their important ability to stabilize their own populations. This would result in much stress among the populations, as there would be increased competition and frustration among males and more frustrated mares as well. All this would disrupt the traditional care and education of young equids by older males and females. This is a serious disruption and does not accord with the WFHBA.

11 mid page: There are many adverse effects upon wild horses produced by PZP, including out-of-season births, stress, and social disruptions (see my book, p. 129-130).

17 bottom: Re: genetic diversity & AML: You need to let natural selection operate so that each herd is able to adapt to each unique habitat over the generations. Arbitrarily and periodically gutting the wild equid populations will throw this benign natural process into shambles!

18: Re: Wilderness restrictions against wild horses & wild burros, this is very wrong and shows extreme prejudice against them. See my earlier comments re: how wild horses & wild burros can restore and enhance wilderness ecosystems, i.e. are compatible therewith. Also both species of wild equids greatly reduce fire hazard (see earlier comments).

26: Monitoring and Tracking of Treatments. Point 1: You need to factor in natural mortality rates of all ages and sexes. I have observed that many foals die in nature, including from accidents, disease and natural predation. (It is very misleading to state that there are no natural predators for the wild horses and burros, as BLM & USFS documents and public statements often do!) Your document fails to consider the level of natural and unnatural predation or human attacks on these animals in the Spring Mtn. Complex, e.g. of puma, coyote & wild dog packs, rattlesnakes, and – a major oversight – the illegal capture, removal as well as killing of wild horses and burros by members of our own human species. All of these ignored mortality factors can be in fact major!

–Though with much more to impart, I now close in order get this timely input in by June 30, 2013, to the email address provided in your document. I have a history of giving such input as well as federal court testimony to defend the precious wild horses and wild burros of the Spring Mountain Complex. From any objective point of view, these “national heritage, returned native” species are not overpopulated. Though BLM & USFS have contrived to paint a negative picture of them in the Spring Mountain Complex in this and earlier documents, the truer and fuller story of these wonderful and ancient presences is not to be found in such evanescent and shallow-minded assertions. The greater story concerning both horses and burros is one with All Life’s Greatest Story. This story includes us all as equals, all individuals and all kinds – however minutely or broadly categorized – for each inextricably and indispensably related within the Great Unfolding Tree of Life. And to acknowledge, respect, and honor the precious freedom of brother/sister/blesser of humanity horse/burro to realize its greater calling, purpose, and destiny in relation to All of Life, not just humanity alone – well, my friend, this is nothing short of a supreme and liberating Virtue!

Sincerely Yours,

Craig C. Downer,
Wildlife ecologist, A.B, M.S., Ph.D. cand.
Author: The Wild Horse Conspiracy;
President: Andean Tapir Fund
Board Member: The Cloud Foundation
P.O. Box 456,
Minden, NV 89423.
T. 775-901-2094.
Email: ccdowner@aol.com

Cc: various interested parties.