Sept 27, 2013 (Deadline for public input, but you can still contact them anytime)

Field Office Manager and Wild Horse and Burro Division officials
Surprise Field Office
Bureau of Land Management
Cedarville, CA
Email: casrpubcom@blm.gov

Dear Sirs/Mames:

I have reviewed your proposal for the Massacre Lakes HMA wild horse herd and
take this opportunity to strongly object to this proposal.
I am personally familiar with this herd having observed this spirited bunch
over a period of decades and most recently since 2009 when I made the
High Rock Canyon jeep treck and including during 2012.

Your proposed AML is much too low for a viable population and runs contrary
to the core intent of the WFHBA that is contained in Section 2 c and that states
that their legal areas where they occurred in 1971 (meaning year-round habitat) are
to be”devoted principally but not necessarily exclusively to their welfare in keeping
with the multiple-use management concept for the public lands.”
What you are planning is clearly not in conformance with this but gives the great
majority of the grazing resource to the livestock rancher and greatly minimizes the wild
horse presence even to the extent of making it non-viable. I remind you that
the IUCN Species Survival Commission’s Equid Specialist Group recommends
a healthy population size of 2,500 individuals to be viable (Duncan, P. 1992 Zebras,
Asses, and Horses: An Action Plan for the Conservation of Wild Equids. IUCN
Species Survival Commission, Equid Specialist Group, Gland Switzerland:
International Union for Conservation of Nature)

I would like to add that this herd has reached a plateau that appears to
be naturally self-stabilizing at around 200 horses. If you take this down
to less than 50 individuals you will disrupt the natural social controls
on population because you will throw into disarray the harem-style bands
in which the lead horses, often older horses, guide the survival of their bands
and inhibit the reproduction of younger immature horses.

You should leave these spirited horses alone in Massacre Lakes HMA
and reduce livestock grazing in order to be more equitable in your
forage allocation. This rugged area has all the ingredients for a successful
Reserve Design strategy that will result in naturally self-stabilizing populations.
Here I refer you to Ch. II of my book The Wild Horse Conspiracy where I
explain this in detail. This may be obtained by googling my name and the
title of the book and is available through amazon.com. I would also like to
remind you that wild horses make wonderful contributions to the natural
ecosystem including the building of soils through humus, and the dispersing
of the intact seeds of many native plant species and that this they do
to a much greater degree than is the case with ruminant grazers, which
they in fact complement since these equids possess a different type
of digestive system. They also are the perfect preventers of catastrophic
fires since their post-gastric digestive systems allows them to munch
down dry coarse and very flammable vegetation without overtaxing
their metabolism (which is the case with ruminants having to consume
similar fare). They are also highly mobile and their anatomy facilitates
their occupation of much more rugged and rocky, steep areas where
the cloven-hoofed grazers often have a very hard time and avoid. To gut
the wild horse herd, as you propose, would only result in increased
chance of extensive fires that the US taxpayer would have to pay
to suppress. This has been born out in the 315,000-acre Twin Peaks fire, that
occurred two years after taking the wild horse and burro herd down
to a very low level. Think about it!

I look forward to future observation of these valuable and picturesque
wild horses and am planning on making a trip soon this autumn.
To me it would constitute a grave assault upon my quality of
life and ecological career if this authentic old mustang herd were to be gutted, thus
thwarting its natural adaptive process, as your proposed plan
would do if approved.

Please do not hesitate in calling upon me for addition input and
especially to work out a strategy that incorporates the principles
of Reserve Design. These would be the true fulfillment of the WFHBA.

Sincerely and Respectfully Submitted,

Craig C. Downer, Wildlife Ecologist
President: Andean Tapir Fund
P.O. Box 456
Minden, NV 89423
T. 775-901-2094