The Wild Horse Conspiracy

Input due June 4 2018 4 pm re DOI-BLM-ORWA-B050-2018-0016-EA Spay Feasibility and On Range Behavioral Outcomes Assessment and Warm Springs HMA Population Management Plan

June 2, 2018
Lisa Grant, Wild Horse & Burro Specialist
BLM, Burns District Office, Oregon
28910 Highway 20 W
Hines, OR 97738
Tel. (541) 573-4555
Attention: Comments due in by 4 PM PDT on Monday, June 4, 2018
Regarding: DOI-BLM-ORWA-B050-2018-0016-EA (Spay Feasibility and On-Range Behavioral Outcomes Assessment and Warm Springs HMA Population Management Plan)
Dear Ms. Grant:
On behalf of the Wild Horse and Burro Fund, I am offering the following input in strong opposition to the proposed spaying of wild mares. This should not happen, neither in the field nor in BLM holding facilities, such as the one in Hines, Oregon!

These spayings are the exact opposite of what the unanimously passed Wild Free-Roaming Horses and Burros Act of 1971 (WFHBA) says to do. Section 3 (a) of this WFHBA stipulates that the BLM & US Forest Service must manage wild horses and burros so as “to achieve and maintain a thriving natural ecological balance on the public lands” and “at the minimum feasible level”. This spaying operation would violate both of these legal points of law. – What is “natural” about spaying?! It is gruesome and would result in untold suffering by the mares being so callously victimized. Its consequence would also be a serious disruption of the social integrity of the wild horse bands and herds. It would create a hellish and chaotic situation all to accommodate the selfish ranchers and other traditional enemies who have not yet learned the value of compassion as this applies to our relationship to these animals … presences here on this Earth for whom people in their right mind recognize a natural affinity.

The greater place and role of horses is realized when they are living freely and naturally and can occupy a habitat where this is possible and where they possess sufficient habitat and niche space in which to realize their long-term genetic viability and ecological adaptation not just in the short-term but in the long-term covering many generations and extending far into the future. – This would be to honor the true meaning and core intent of the WFHBA – not the Frankensteinian butchery you are proposing here!
You should heed Section 43 Code of Federal Regulations (C.F.R.) § 4700.0-6 (a) and protect and defend the free-roaming lifestyle of wild horses and wild burros. Your sterilization of these animals would turn them into listless, demoralized shells of their true selves! And this was recognized by a U.S. Idaho District Court judge in 2017 (Case No. 1:16-cv-00001-EJL).

Section 43 C.F.R. §4700.0-6 requires that “…wild horses and burros shall be managed as self-sustaining populations of healthy animals in balance with other uses and the productive capacity of the habitat” and, furthermore, that government “…activities affecting wild horses and burros shall be undertaken with the goal of maintaining free-roaming behavior” (4700.0-6 (c)).

Instead of this serious transgression against the wild horses under your charge, you should be making every effort to secure fairer forage allocations and adequate, dependable water sources as well as other wild-equid habitat requirements such as shelter, reproductive and seasonal migratory habitat, mineral sources, etc. You should also be engaged in a positive educational campaign to bring to the attention of the general public all of the many positive contributions that wild horses and burros make such as soil building via their feces, food web augmentation, seed dispersal & germination and catastrophic wildfire prevention – so important today with exacerbating Global Warming!

Drawing near to a close, I offer Reserve Design for your careful consideration as the true way forth for all of us, horses and humans alike. This is explained in the report I recently finished and which represents over a year’s work and assessment, including visits to five wild horse herds in Oregon. You can access this report on my website at this link: . And I would appreciate your acknowledgement and reaction to this document – which also includes some disturbing exposes concerning the unfairness that is happening to Oregon’s few remaining wild horses on both BLM and USFS lands.

Also, I would like to remind you that a U.S. District Judge recently stopped BLM from creating sterile herds in his ruling in U.S. Idaho District Court Case No. 1:16-cv-00001-EJL.

Please discard this backward and perverse proposal to spay wild horses. This must never occur, not even as an experiment! It is the exact opposite of what the WFHBA intended and shows an extreme disrespect especially for the wild horses themselves, let alone their human appreciators, supporters and defenders such as myself and those many people I represent.

Do not hesitate in contacting me regarding this input.
Most Sincerely,
Craig C. Downer, wildlife ecologist
Wild Horse and Burro Fund
P.O. Box 456
Minden, NV 89423
Cell. (775)901-2094
Attached: Report on 5 Oregon Wild Horse Herds and HMAs
Cc: Various interested parties

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