Comment for Environmental Assessment for the Antelope Complex and Triple B Complex Proposed Wild Horse Gather due August 21 2017
August 18, 2017
BLM Elko District Office
Re: Public comment on Environmental Assessment (EA) for the Antelope Complex & Triple B Complex, DOI-BLM-NV-E030-2017-0010
Overall, I believe your proposal represents an abandonment of your legal duty to protect and preserve the wild horses as truly vigorous, long-term viable, and ecologically well adapted populations in the wild in their several Herd Management Areas (HMAs) of the Antelope and Triple B Complexes of HMAs. My chief reasons are as follows:
1. You have failed to present a reasonable choice of alternative proposals for the protection, preservation, and management of these wild horse herds. For this reason, I would favor the No Action Alternative. Though I have earlier presented to you a Reserve Design alternative that would do justice to these unique and valuable wild horse populations, the merits of this Reserve Design strategy were not seriously recognized in your EA. For this and other reasons, I request a full Environmental Impact Study be conducted, chiefly because of the major detrimental impact that your proposed action would have on these wild horses themselves, both individually and as concerns their social units, both harem-type bands and the closely interbreeding collection of bands known as herds, or populations.
2. Your proposal to reduce the HMA herds to the low end of their Appropriate Management Levels (AMLs) is grossly unjust. I have visited all of these herds and their HMAs and would be personally and professionally harmed if you proceed with the proposed draconian wild horse reductions. The unfairness of your proposal is revealed by the following breakdown of the numbers:
The Antelope Complex consists of the following HMAs by name: Antelope, Antelope Valley, Goshute, and Spruce-Pequop, all of which I have visited over a period of many years. The total legal areas for these wild horse herds are ca. 1,324,745 acres and the AML for the entire complex is 155 low range to 259 high range. But if you reduce the interbreeding herd of this comple to the low range of 155, there will be only one remaining wild horse for every 8,547 acres. This is a ridiculously unfair allocation of space and habitat for the wild horses here that will cause a serious setback in the social stability of the various bands and the entire herd – a stability which itself is a natural and benign way of limiting horse populations and can be combined with other elements of Reserve Design to achieve population self-stabilizing (see my Reserve Design proposal attached with this letter). Even at the high range of the AML: 259 horses, there would be 5,115 acres per individual wild horse. This would also be a grossly unjust provision for the wild horses, whose Carrying Capacity in Great Basin habitats such as these is in the order of one horse per 100 acres – and this is being quite conservative!
For March 1, 2017, BLM employees estimated the wild horse population of the Antelope Complex to be at 1,320, not including young of the year, or foals born in 2017. This figure translates into 1,004 acres per presently surviving individual wild horse. This is not an overpopulation of wild horses but rather an under-population within the Antelope Complex, given the carrying Capacity (K) of this ecosystem for the horse species, conservatively set at 100 acres per wild horse.
3. In the EA’s Introduction, I take issue with the statement that “the BLM Wells Field Office has determined that even though there has been an above-average amount of precipitation [this past] winter and spring, there are still no known water sources in the area for wild horses to obtain water late in the spring and summer”. Having visited this area, I perceive this as a bogus justification for the wild horses’ over-reduction, one designed to further the near monopoly of resources, including both forage and water, by public lands ranchers as well as mining and energy companies operating in the area. There exist plentiful water sources for the wild horses in the Antelope Complex, which I have personally visited, but it’s up to our public officials/servants to secure adequate water and other habitat requirements for these protected and valued animals, not abandon their duty toward them in this regard. (See photos attached.)
4. I strongly object to the hasty dismissal by BLM officials of inputs contained in Sections 2.6.5, 2.6.6, 2.6.7, 2.6.8, and 2.6.9. These recommendations deal with the very crux of the unfairness issue at hand. Particularly in 2.6.5 where it is brought up that the wild horses’ legal areas are to be “managed principally” for their herds under 43 C.F.R. 4710.3 and nearby codes, I believe the BLM preparers of the EA are quite remiss in their official duty. And the same applies to 2.6.6 recommending a raising of AMLs for wild horses in their HMAs and to 2.6.7 recommending the removal or reduction of livestock. These three suggestions are logically what must happen if the current gross injustice toward the wild horses is to be remedied. To also dismiss the ability of nature to control the population number of wild horses, as presented in 2.6.8, “flies in the face” of the true and core intent of the WFHBA. This concerns the right of these wild horses “to achieve and maintain a thriving natural ecological balance on the public lands” and “at the minimum feasible level” of management, or interference with their natural lifestyle from people including the two federal agencies charged with their protection and preservation “in the wild” upon their rightful national public lands (see Section 3 a of the WFHBA). I also take this opportunity to remind all of us that the WFHBA clearly states that wild horses and wild burros “contribute to the diversity of life forms in the nation and enrich the lives of the American people … shall be protected from capture, brandings, harassment or death … are to be considered in the area where presently found [1971 as year-round habitat area] as an integral part of the natural system of public lands”.
5. Concerning Section 3.2.12 on page 117 of the EA, the proposed Alternative A presents a significant impact upon the wild horse populations of the Triple B and Antelope Complexes themselves as it undermines their long-term well-being, vitality, and genetic viability. Thus, under NEPA, an EIS should be required; and I ask for this unless BLM willingly modifies its proposal to allow for greater numbers and more adequate habitat and resources for the wild horses here.
6. On page 2 of the EA, I question the meaning BLM adopts for Thriving Natural Ecological Balance (TNEC) as mandated by the WFHBA in its Section 3A. From the evidence, BLM is distorting the true significance of this phrase to insert mainly unnatural rather than truly natural components into what should be a much more “hands off” situation concerning the wild horses and their habitat.
7. On page 3 and throughout the EA, I question the assertion that the wild horse population grows at 20% or higher annually and will always do so regardless of its circumstances. In fact, very high mortality rates of newborn foals usually occurs, even up to 50% or more, and there also occurs relatively high mortality rates among adults that are typically 5% or more. Additionally, BLM should not overlook the increasing mortality or other types of removal rates of wild horses and burros from the public lands that are occurring today. This is due to increased lawlessness on our public lands and is a very serious threat to our remaining wild horses and burros. I have received much testimony as well as observed first-hand evidence of this. BLM officials should be transparent on this issue, for in reducing the herds to grossly underpopulated levels, they are setting them up, not only for genetic inbreeding and ecological un-fulfillment in what should be a thriving biodiversely enhanced, wild-horse/burro-containing ecosystem, but also for their very sudden disappearances altogether. Also, I must add that such substandard, low population levels render the wild horse/burro populations much more vulnerable to disease, Global Climate Change/Warming with its attendant increasingly erratic storms and droughts, along with a host of other natural and human-caused factors.
8. Concerning the WRMPWHA requirement, stated several places throughout the EA, that pre-livestock release levels of winter forage be limited to 10% usage in winter-use areas, I very much object to this devastating requirement being placed upon the wild horses within their legal areas! The BLM never should have agreed to this, as, as its own admission would seem to imply, such a requirement produces a devastating blow to the wild horses’ true viability and filling of their ecological niche here in their legal areas (true intent of the WFHBA). That BLM officials merely acquiesce to this outrageous demand proves their abandonment of duty toward the wild horse and their well-being in order to favor livestock interests primarily, even within the legal areas of the wild horses. I strenuously object to and protest this and request that BLM find a much fairer stipulation here! By its own admission, BLM acknowledges in the EA that the no-greater-than-10%-winter-forage-usage-pre-livestock-release places a severe constraint on the wild horses here in their legal areas – areas which are supposed to be “devoted principally” to the wild horses’ welfare, not that of the public lands ranchers! To wit: on page 5 of the EA: WRMPWHA states that “the availability of forage for winter usage is considered the most limiting factor for wild horses.”
9. From page 6 of the EA, by its own admission, the BLM has not yet received the statistical analysis of the 2017 wild horse survey of the Antelope Complex concerning the foals born and their survival/mortality rates. I therefor strongly object to BLM proceeding to include the 2017 “foal crop”. This ignores natural and human-caused mortality of foals that is often very high, even to 50% or more.
10. Again regarding issues raised on page 6, I very much object to BLM’s failing to recognize the negative impact that fences and other artificial barriers within the wild horses’ legal area are having upon their ability to obtain sufficient forage, water, shelter, minerals, space, and reproductive habitat requirements. Fences are major excluders of wild horses in these HMAs; and to ignore their negative impacts on the wild horses constitutes a dereliction of duty toward them and the U.S. public who support them. I observed many grazing allotment separation and other types of fences in the HMAs in question and observe that they are having serious harmful effect upon the wild horses in these two complexes.
11. On pages 11-17, as elsewhere throughout the EA, BLM plans for the use of fertility controls of various methods including the use of PZP, GonaCon, Gelding of stallions, and 60%-
Male-to-40%-female sex ratio skewing. I very much object to and protest these highly invasive and disruptive assaults upon the integrity of these unique wild horses! These methods are contrary to the core intent of the WFHBA that mandates letting the wild horses/burros be themselves, wild and free, upon the relatively natural public lands and specifically prohibits their domestication or semi-domestication. What BLM is here proposing clearly violates WFHBA! Need I remind BLM that Section 3 a of the WFHBA clearly states that management of the wild equids is to be done “at the minimum feasible level” and that they are to be allowed to become an “integral part of the natural system of public lands”. To me personally and as a wildlife ecologist, this signifies their being allowed to fill their natural ecological place/role/niche on the public lands and that Natural Selection, not humans’ artificial selection, should be allowed to operate. In the Reserve Design strategy for wild horse/burro protection, preservation, and management, the true mandate of the WFHBA is upheld.
This EA similarly state that the short- and long-term effects of gelding of stallions would be monitored. I strenuously object to the gelding of the wild stallions — many of whom would be the band leaders, or “patrons” that are so important to the protection and education of the wild horses! First off this is very painful and often lethal and would place the geldings at great jeopardy in terms of their survival in the wild. Geldings often find themselves ostracized by intact stallions and even mares, kicked, bitten and otherwise abused, beaten, cast off, or even killed! This is clearly not right! I also strongly remind you that male genetic diversity/heterogeneity is dangerously low among horses worldwide, including wild horses, and that your further compromising this would put the entire populations of wild horses at serious risk as far as their long-term survival is concerned. Again, this is yet another example of the human domestication of the horses and this works very much against Natural Selection and the horses’ short- and especially long-term vigor, viability, and survival upon this beautiful planet Earth that we share as home and place of unfoldment with them and so many other worthy species.
Consider all that horsekind has done for humankind! Now, isn’t it high time that we people do something truly decent and good for horses?! And what better way of paying our debt of gratitude than simply allowing them a just portion of this world wherein to be themselves, to live in their age-old, wonderfully evolving, unfolding manner – in short, to live and to be truly free to fulfill themselves in the sight of God and His plan for all beings?! This, to me, was and remains the true and core purpose of the WFHBA. This true intent was and remains a sacred one that we humans abandon only at our severe peril.
Wild horses both can and will self-stabilize when allowed to fill their proper ecological niche, play their legitimate role within the ecosystem and within the ecological process of ongoing life. If they were the destructive misfits that their enemies like to portray them as, they would surely not have lasted all the millions of years they have upon this venerable, ancient, yet ever renewing and young Earth.
Also remember that the horses as well as the burros are post-gastric digesters and that they restore soils and successfully disperse the intact seed of many plant species for germination. Remember too that they greatly help by preventing catastrophic wildfires – something very much needed in this era of Global Climate Change, or Warming.
They are also quite beautiful in their own special way … ancient and very wise and sensitive presences who deserve to live freely and to carry on, one with the entire life community on Earth where they belong and to share in the common destiny – which is a good one for all concerned! It is perverse o ignore wild horses’ value here and their claim to worthiness, to freedom, to suitable Earth home, or viable habitat, wherein to realize themselves! But to generously honor these horses and their rightful land and natural freedom constitutes a great virtue, indeed, and would be a great leap forward for all humanity.
Craig C. Downer, Wildlife Ecologist