Public Comment to Ely District Water Canyon Wild Horse Growth Suppression Pilot Program
June 14, 2015
Attn: Paul E. Podborny, Schell Field Mgr.
Having reviewed your document, I am writing to oppose your plan to administer reproductive suppression to the Water Canyon wild horses. This would cause serious aberrations in wild horse physiology and behavior and thwart their ability to adapt and survive.
I furthermore object to the gross favoritism you are showing to the livestock permittees. These ranchers do not possess a right to graze these allotments. In contrast, wild horses do possess a legal right to live in thriving numbers upon their legal areas. Your assignment of only 25-30 horses as an Appropriate Management Level (AML) on 31,000 acres in the Water Canyon portion of the HMA and only 150 – 324 horses in the 331,000 acres Antelope HMA is grossly unfair. I have reviewed the forage allocation to ranchers and their livestock and it is grossly disproportionate when compared to that given to the mustangs. You should employ C. F. R. 4710.5, “Closure to Livestock” in order to bring the wild horse population back up to a viable level.
I recommend that you explore the principles of Reserve Design in order to establish not only a more truly viable but also an ecologically well adapted and naturally self-stabilizing population (ask me). Your average AML works out to be over 1,600 acres per individual wild horse. This is a nearly wild-horse-empty ecosystem that makes a mockery of the law, particularly the Wild Free-Roaming Horses and Burros Act of 1971.
The GnRH treatment of wild horses is a detrimental invasion of their natural biology and life style and contrary to the “minimum feasible management” mandate of the WFHAB.
Also, your frequently repeated assertion of 20-25% annual growth rate for the wild horses seems plugged into your document as if by rote. Other studies have indicated that a rate of 10% or less is more factual given ca. 50% annual foal mortality before their first year and ca. 5% annual mortality of adult wild horses. And there is also much illegal capture and killing that is occurring on the public lands, and this is accelerating.
You should take a careful look at The Wilderness Act as concerns the Becky Peak Wilderness and the Government Peak Wilderness. These areas should not be subject to overgrazing and monopolization by livestock, which appears to be the case! So to make up for this, the wild horses are targeted. It is plain to me that this is what you are doing!
Taken overall, I see your document as yet another scapegoating of wild horses in their legal areas and not at all the honest, fair-minded, and courageous upholding of all the laws of our nation and of the General Public’s great interest in this important Quality of Life issue, I.e. our great interest and concern for the wild horses together with their rightful land, or natural habitat, and natural freedom.
Please revise this proposal and feel free to contact me for further input.
Craig C. Downer