The Wild Horse Conspiracy

Egan and Johnson Basin Restoration Project Preliminary Environmental Assessment

Craig Downer’s Comments:

August 27, 2017
Ms. Katie Walsh, Natural Resource Specialist
BLM Ely District, Bristlecone Field Office
701 N. Industrial Way
Ely, NV 89301-9408
Tel. (775) 289-1869; Fax (775) 289-1910
Subject: Egan and Johnson Basin Restoration Project Preliminary Environmental Assessment, Comments re: this major Pinyon Pine and Utah Juniper reduction and reseeding proposed project. Comments due by 4:00 PM on Monday, August 28, 2017, by email OK. Link to document:
Dear Ms. Walsh:
Thank you and your office for alerting me to this PEA, which I have now reviewed. I very much appreciate this opportunity to give you and your team these inputs:
1. After reading through the PEA, I am struck by the lack of consideration given to the value of the Pinyon Pines and Utah Juniper community, both as concerns these individual native tree species and their PJ-community as a mutualistic symbiotic association. You would greatly reduce P-J woodland in 24,375 acres, or 65% of 37,500 acres and conduct manual thinning by chainsaw of these two important trees throughout the entire 84,675-acre project area. This is a major impact and as it is stated it requires and Environmental Impact Study under NEPA.
I am also concerned about the failure to consider the increase in the PJ community as a response to ongoing Global Climate Change/Warming. The PJ community is an ancient one in the Great Basin and it has advanced and retreated over the course of the centuries according to relative changes in precipitation and temperature. It is a biodiverse one in its own right and offers much to us people, such as the pinyon nut and the juniper berry. These latter could be moderately harvested and would yield a great and ecologically compatible use, particularly the pinyon nut, as the ancient Native American cultures abundantly attest. Your team should consider the significant role that these trees have in stabilizing soils via their extensive roots, and in contributing to soils and to water tables when they recycle their leaves or very bodies. You should also consider the many species of wildlife that do benefit from these woodlands, such as the various rodents, birds, lizards, insects, etc. Species like the Pinyon Jay and the Pinyon Mouse nest in and around these trees and derive their sustenance from the pinyon nuts. When they cache them, they naturally disperse these trees. Also the PJ woodlands are very important for the shelter and even nesting of many mammals, birds, reptiles, etc. They are also a vital barrier to strong winds that typify the Great Basin, and thus prevent wind erosion, or scouring, of precious desert soils. These woodlands save the lives of many animals both during extremely hot summers and extremely cold winters by their provision of shelter, which is a major concern for deer, bighorn, elk, mustangs, pronghorn, canids, felids, lagomorphs, and many other species. There is much else that can be said in favor of this ecological community and I refer you to the 1974 UNR M.S. thesis by Dwight W. Beeson entitled: “The Distribution and Synecology of Great Basin Pinyon-Junipers” and other works such as Ronald M. Lanner’s “Trees of the Great Basin: A Natural History” (1984, Univ. of Nevada-Reno Press). On this subject, I would just like to again ask you and your team to carefully consider my earlier statement that the increase in the Pinyon Pines, and particularly the Utah Junipers, is a natural response to the very unusual and high increases in temperatures that the living Earth is experiencing in our day and age, and that the wiser response by us humans could be to adapt to these natural changes, by altering our own lifestyles, rather than insisting on maintaining lifestyles, such as continued high levels of cattle and sheep grazing or deer hunting, that are not positively adapted to the Global Climate changes that continue to escalate.

2. I am very concerned that under the guise of Greater Sage Grouse rescue, BLM would be in fact through this project perpetrate the continuing near monopoly of resources by the public lands livestock ranchers, including both cattle and sheep. I have spent weeks in and around the project area and have also overflown it and have given reports to BLM and to conservation organization in this regard. It seems just too convenient that the various grasses that are chosen as priority species are those that help the ranchers the most, while the exact needs of the other wildlife species, other than big game hunted species, are not adequately treated. It seems to me that there is a sort of “green-wash” going on here that is not really all that “green”.

3. In my capacity as an ecologist, I have made observations throughout the project area in connection with the legal wild horse presence as part of the Triple B HMA. I have given input in the defense of this national heritage species to your office and made declarations in court proceedings for their fairer treatment, e.g. higher AMLs, better resource allocations, etc. This stated, I particularly protest your dismissal of wild horses as an impacted legitimate interest by the project. The Pinyon Pines and the Utah Junipers in question are very important shelter species for the wild horses, and the great reduction that your project proposes would have a major negative impact on their survival during both very hot seasons (lack of shade) and very cold seasons (lack of shelter from storms, wind, etc.). I also resent the exclusion of the wild horses in your discussions of cheat grass reduction, for the wild horses are perfect reducers of cheat grass when allowed to eat such before they mature and set seed. Again I see that livestock such as cattle, sheep, and goats are favored here, but the wild horses are ignored in this regard. As I have observed in the field in the project area, the problem stems from their not being given their rightful legal access to their entire HMA because of a series of fences that interfere with their natural migratory patterns during the course of the day, month, and year. You also very much overlook the major beneficial role wild horses have in preventing catastrophic wildfires. As you are undoubtedly aware, these fires are alarmingly on the increase, along with temperatures, due to humanity’s pollution of the atmosphere with all his machines, livestock, etc., i.e. Global Warming. But the wild horses, if allowed to fill their niche here in their legal Triple B HMA would become perfect “fire-prevention brigades”. They would not only reduce the fuel load but convert it through their droppings into more nutrient-rich and moisture-retaining soils than would be the case with the current status quo that promotes a major monopoly by ruminant herbivores, i.e. cattle, sheep, mule deer, etc. The horse’s post gastric digestive system does not as thoroughly digest what the horse ingests, and in this and many other ways thus lends a much needed balance to the ecological community. And this goes hand-in-hand with their wide-ranging movements and their not camping on the riparian habitats, as domestic cattle set out on the rangelands tend to do. I urge your team to seriously consider these positive points about the wild horses and to integrate these into your further analysis.

4. I favor the No Action alternative, because the alternatives presented are too extreme and give me no other choice. Because of the major impacts that would ensue should you carry out this proposal, I assert that under NEPA you should perform an EIS.

Please keep me informed of further opportunities to participate in this EA/EIS process and of any decisions you are making. I am providing my address, email, and telephone number, should you wish to discuss any of the points I have risen. I would appreciate a response to the points I have raised. Again I greatly appreciate this opportunity to give my input and trust that you will give it due consideration.


Craig C. Downer
Wild Horse and Burro Fund
P.O. Box 456
Minden, NV 89423

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