September 25, 2017

Mr. Clay Stott
Wild Horse and Burro Specialist
Bureau of Land Management, Lander Field Office
1335 Main Street, Lander, Wyoming 82520

(307) 332-8400

Email: wy_north_lander_gather@blm.gov

Link to document: http://bit.ly/2017_North_Lander_Gather (Comments due in by 4 PM Mountain Time, January 31st, 2017.)

Dear Mr. Stott

I have received your Scoping Document for the North Lander Complex in Wyoming in which you state there are ca. 1,016 wild horses remaining in this vast complex. Though you do not specify whether this does or does not include the young of the year, this number is still relatively small for such a vast legal area for these mustangs. I am opposed to your draconian and grievously low and unjust Appropriate Management Levels for the various herds and their HMAs. These are not genetically viable and fall far short of what the natural niche space for these returned North American natives would allow.

Given the fact that there are 368,000 acres in the North Lander Complex that consists of the
Conant Creek, Dishpan Butte, Muskrat Basin, Rock Creek Mountain Herd Management Areas, there are ca. 362 acres per individual wild horse at present. This is far below the ecological Carrying Capacity (K) for the horses in this ecosystem. Please recall that according to the Wild Free-Roaming Horses and Burros Act of 1971, the wild horses (or wild burros) are to be the principal recipients of natural resources within their legal areas, not livestock ranchers, nor mining or energy corporations, or big game hunters, etc. This is according to Section 2(c) which defines their legal areas where they were in 1971 as year-round habitat as “the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros … and which is devoted principally but not necessarily exclusively to their welfare in keeping with the multiple use management concept for the public lands.” Obviously the law does not intend for the wild horse to be marginalized within their own legal areas, but this is what your proposal is trying to do! This is illegal and you may rest assured that I will oppose it if adopted!

I am also concerned about your contention that the wild horses of the four adjoining HMAs should be considered one interbreeding population. Having observed these greatly reduced herds, I notice that their identification with distinctive home ranges and social groups does provide a significant degree of separateness among these four populations. I therefore consider your four Appropriate Management Levels to be very inadequate and to constitute prescription for their inbreeding, un-adaptiveness, and decline. I say un-adaptiveness, because by gutting these herds you will be, in effect, destroying so much of the ecological adaptations that generations of these unique horses have accomplished over many generations. This is very insensitive and shows that you care little, appreciate very little these wonderful presences and “national heritage” herds.

The levels you plan to bring each population down to are as follows: Conant Creek 60, Dishpan Butte 50, Muskrat Basin 160, Rock Creek Mountain 50. Thus the total population would be only 310 individual wild horses. This would then mean there would be a vast 1,187 acres per remaining individual wild horse. –This is outrageous and represents a practically empty habitat for the wild horse within their own legal areas. This makes a mockery of the WFHBA and will be denounced in the Federal Courts, I can assure you!

You should have an AML of at least 2,500 wild horses living in nature in order to assure genetic viability according to the IUCN Species Survival Commission Equid Survival Group (Duncan 1992). Better yet you should employ the sound principles of Reserve Design and allow the horses themselves to show you what is their appropriate population level. This would demonstrate true respect and appreciation for the mustangs and their place in our shared home world: Planet Earth, rather than the continuation of an arrogant, selfish “know it all” attitude toward these ancient and positively contributing presences. (See my peer reviewed article “The Horse and Burro as Positively Contributing Returned Natives in North America” that is linkable through my website www.thewildhorseconspiracy.org for some great and factual information on this! Also my book “The Wild Horse Conspiracy” particularly its Chapters I & II, available online or via my webpage.)

I strongly recommend that you do a thorough ecological evaluation of this wild horse complex of HMAs and that in this you give full and objective attention to ALL of the factors that are disrupting the sound functioning of this ecosystem, including all the human activities here, including ranching, mining and energy extraction, Off Highway Vehicles, hunting, etc., and not just do a dishonest and biased targeting of the magnificent wild horses, full of resentment and hostility, as was the case with the persecution of the Native Americans who lived in their centuries – even millennia – old ways. Do not allow the WFHBA to become another “broken treaty” displaying the treachery and dishonorableness of a ruthless and morally sluggard establishment. I know you can break this vicious pattern. I am counting on you to do so much better!

I oppose any further reduction in this already substandard wild horse population and urge you to secure the greater habitat resources which they should enjoy now and for generations to come, according to both our human and even more according to the higher natural and moral laws that govern all life in and upon our shared home Planet Earth!

Sincerely,

Craig C. Downer, Wildlife Ecologist
Wild Horse and Burro Fund
P.O. Box 456,
Minden, NV 89423
Tel. 775-901-2094
ccdowner@aol.com

Cc: Various interested parties.

P.S. Scoping document is available at: https://eplanning.blm.gov/epl-front-office/projects/nepa/70450/93476/112583/North_Lander_Scoping_2016.pdf