Fifteenmile HMAP & Gather
February 26, 2019
Wild Horse Specialist, Cam Henrichsen (Tel. 307-347-5100)
Bureau of Land Management, Worland Field Office
101 South 23rd Street
Worland, WY 82401
Note: Input by email or mail must arrive by Monday, March 4th, 2019, at 4:30 PM Mountain time.
Subject: “Fifteenmile HMAP & Gather” DOI-BLM-WY-R010-2018-0036-EA
Dear Wild Horse Specialist:
Thank you for this opportunity to give input to your plan for the spectacular Fifteenmile wild horse herd and Herd Management Area (HMA WY0011). After considering various aspects of your proposal, I strongly urge you to adopt the NO ACTION ALTERNATIVE. This is the only one that is anywhere near fair.
At an estimated 284 wild horses in 2016, the rate of population increase these wild horses are actually showing in no way supports your agency’s claim of 25% annual population growth. The proof is that BLM estimated ca. 100 wild horses in 2009. At a 25% annual increase, 100 horses would have given rise to 472 wild horses in 2016. Yet we observed only 284 wild horses. The facts indicate that this population is self-stabilizing as it fills is ecological niche. This process should not be interfered with but be carefully observed. It is very encouraging.
Furthermore, BLM range evaluation indicates that 97% of the HMA’s habitat is in good condition and that the wild horses are having a beneficial effect here. As a wildlife ecologist, the latter is one of my specialties; and I have recently composed a presentation on the many positive contributions that members of the Mammalian Order Perissodactyla make to ecosystems, including species in the Equidae (Horse), Tapiridae (Tapir), and Rhinocerotidae (Rhino) families. I would be willing to come and give this slide show and talk to you and your community.
Among the contributions the amazing but persecuted Perissodactya make are:
(1) the building of healthier soils, ones that are more nutrient-rich and water-retaining, thus building also greater water tables, or aquifers;
(2) the dispersal of a wide variety of viable seeds that replenish the ecosystem including many grasses and forbs – many native – and for which wild horse dung provides supportive fertilizer aiding germination;
(3) the mitigation or even prevention of major wildfires because wild horses munch down grasses, forbs, etc., which later during drier seasons can accumulate to dangerous levels that are easily set afire by lightning, campfires, sparks from vehicles, etc.; and also they can better handle coarser drier plants;
(4) the proven mutualistic symbiosis that exists between post-gastric digesting horses and ruminant-digesting herbivores like deer, bison, bighorn, even cattle and sheep when present in more moderate and ecologically balanced and adapted levels;
(5) the “opening up” effect wild horses can have both by breaking ice on frozen water or snowy/icy crusts on vegetation so that other weaker animals can access water and/or forage, as well as the opening up of thickets and the creation of trails of benefit to other animals.
(6) the creation of natural water catchments through wallowing that can benefit many diverse plants and animals, particularly during the drier season of the year;
(7) the contribution of their “mortal remains” to natural predators and scavengers such as Felids, like mountain lions, Ursids, like black and grizzly bears, and Canids, like wolves and coyotes, as well as myriad other species, including birds, rodents, reptiles, insects, & microorganisms who naturally recycle.
We should also take a hard look at the Fairness Issue of your proposal. The original Herd Areas included where the wild horses were in 1971 as year-round habitat according to the core tenets of the Wild Free-Roaming Horses and Burros Act (WFHBA). For the Fifteenmile herd HA this totaled 261,910 acres, of which 217,849 were BLM. Since the Appropriate Management Level (AML) has a low of 70 and a high of 160 horses, the Mean AML is 115 wild horses. The latter divided into 261,910 gives a figure of 2,277 acres (3.56 square miles) per individual wild horse, which is a density of only 0.28 horse/sq. mi. By any reasonable assessment, this would present a very wild-horse-empty Herd Area. However, the HA has been greatly reduced to only 81,127 total acres, of which 68,607 are BLM. Thus, the AML Mean of 115 hoses divided into 81,127 acres gives a figure of 705 HMA acres (1.1 sq. mi.) per individual wild horse, which is a density of only 0.91 horse/sq. mi. Again this is hardly excessive! Precipitation averages 8” annually here and the vegetative productivity is fairly abundant in this semi-arid area. The 705-acre-per-individual wild horses is still a very sparse wild horse population.
Remember that Section 2 c of the WFHBA defines a wild horse/burro legal area 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.” Clearly, this does not mean the wild horses should be marginalized within their own legal areas, nor that these legal wild horse/ burro areas and their resources should be given in their majority to livestock ranchers, mining companies, big game hunters, etc., yet this perversion of the law is exactly what appears to be happening!
Another point that should be made concerns the fact that the original HA has already been reduced by 180,783 acres (261,910 minus 81,127). Given this extreme reduction, it is only honorable, fair and just that in the remaining HMA home of these unique and special wild horses, they be given the “principal” share of the resources in order to realize a genetically viable population in the long-term. The current AML is hardly this! Therefore, I strongly urge BLM to increase the AML for this special herd to a level that will be at least 500 Mean AML, which is the IUCN SSC Equid Specialist Group recommendation for an equid population that due to extenuating circumstances has to be very tightly managed with stud book, mare and birth registry, etc. Furthermore, this expert group’s recommendation for an equid population to be genetically viable in the long term in a natural habitat is 2,500 individuals (see Duncan, P. 1992. Zebras, Asses, and Horses: An Action Plan for the Conservation of Wild Equids. IUCN SSC Equid Spec. Group. Gland, Switzerland). Since 500 is the population that the Worland BLM news release (1/31/2019) indicates the Fifteenmile herd is approaching, I would say: Great! Leave it alone then. It is filling its niche and this population would be equivalent to 162 acres per individual horse given an HMA of 81,127 acres, or of 524 acres per individual horse within the original 261,910-acre HA. We should study them to see how beautifully they are managing on their own, not violently disrupt their great harmony!
I further urge you to restore as much of the original HA acres as possible and also to expand this wild horse habitat into other areas in order to make it as complete and long-term-viable a habitat as possible. This you can do by setting up Cooperative Agreements as intended through Sections 4 and 6 of the WFHBA. An AML of only 70 to 160 horses is a set up for inbreeding and decline; and the 60%-male to 40%-female skewing of the herd’s sex ratio would cause social disruption, great stress in both stallions and mares, and be very much contrary to the true and core intent of the WFHBA! In upshot, this unanimously passed law is positive, not negative, in its attitude toward the wild horses and burros and their living naturally on the land they are meant to occupy!
In June, 2016, I toured the sweeping McCullough Peaks wild horse HMA just to the north of the Fifteenmile HMA and observed how very stressed its stallions were. The mares of the herd had been PZP-darted to prevent their pregnancy causing much frustration both for them and the stallions. Also PZP undermines the herd’s immune systems over the generations, since those mares with weaker immune systems are precisely those who produce more offspring. Also the herd was greater-male: lesser-female ratio skewed, which is, again, very unnatural and causes increased fighting among males. My impression was that these horses were miserable because thwarted in realizing their true natures, both individually and collectively. This is all the opposite of the true and core intent of the WFHBA that I very much urge you to study in its precise and eloquent language and to truly implement while decreasing livestock, mining, ORV land disruption, exclusive big game hunting promotion, among other greedy and narrow-minded would-be monopolizers of the public lands whom the WFHBA is meant to defend the wild horses/burro against!
The wild horses of the spectacular Fifteenmile HA & HMA must be restored along with a truly long-term viable and complete habitat on a year-round basis. And the sound principles of Reserve Design should be employed to realize a truly long-term viable/survivable, ecologically harmoniously adapted, and naturally self-stabilizing unique and valuable mustang population. This would be the true honoring of the WFHBA, not the present, very excessively suppressive wild horse plan.
I again thank you for this opportunity and look forward to your prompt response to my points.
Craig C. Downer, Wildlife Ecologist
Wild Horse and Burro Fund
P.O. Box 456
Minden, NV 89423