September 19, 2019
Stacy Silvester, Project Lead
Bureau of Land Management, Stillwater Field Office
5665 Morgan Mill Road
Carson City, NV 89701
Attention also: Kenneth R. Collum, Field Manager

Tel. (775) 885-6000; Fax (775) 885-6147

Email: blm_nv_ccdowebmail@blm.gov

Re: PTMA DEA, Pilot Table Mountain Grazing Permit Draft Environmental Assessment. Comments due by October 24, 2019. Email comments permitted.
Draft EA & associated documents link: https://go.usa.gov/xV25G

Dear Public Official:

Thank you for providing me with this opportunity to give input on your informative draft Environmental Assessment (DEA) for the Pilot-Table Mountain grazing allotment (PTMA). I have thoroughly read this & consulted some of the maps & other appendices. I appreciate being able to participate in the BLM field trip last November 16, 2018, along with a number of interested parties, including the rancher permittees.
This enormous area of 512,449 acres of public land & 8,771 acres of private land lies approximately ten miles east of Hawthorne, Nevada. And the final decision by BLM might give a ten-year grazing permit to the rancher. Currently 900 cattle are permitted to graze on the allotment from November 1st to March 31st & another 150 cattle are permitted to graze from April 1st to October 31st, in both cases all on BLM public land. Only twelve domestic horses are allowed year-round on the allotment. Basically, domestic livestock grazing is year-round & sums to 5,667 Animal Unit Months (AUMs). The PTMA includes the majority of the Pilot Mountain Wild Horse Herd Management Area (HMA) & the Appropriate Management Level (AML) that has been assigned here is only 249 low to 415 high wild horses. Also the 79,600-acre Gabbs Valley Wilderness Study Area (WSA) is entirely within the northern half of the allotment.
Table 2 on page 7 of the DEA shows serious negative impacts being caused by domestic livestock, particularly cattle. This is affecting vegetation & water sources, especially springs, streams & associated riparian habitats &, consequently, a variety of wildlife species, including rare, threatened & endangered ones. Over half of the 37 springs present are Non-Functional; cattle are the primary cause for this unacceptable situation. A definite shift is occurring from a grass-dominated state to a shrub-dominated state for which cattle have been again determined to be the major cause. This is affecting mule deer, bighorn & pronghorn populations, all big game species promoted by the Nevada Department of Wildlife (NDOW). But many other equally valuable species are being harmed by the status quo of cattle ranching’s domination of habitat resources in & around this allotment. This greater majority of species needs to receive much fairer consideration, e.g. the Pygmy Rabbit, the Pinyon Jay, the Pinyon Mouse, a variety of reptiles, amphibians, birds and bats, as well as a host of other mammal species, both large & small. Also deserving fairer consideration are therare, threatened & endangered plant & animal species & their special roles & niches & how these help create a more balanced, resilient & viable ecosystem. In this regard, I appreciate the discussion of the endangered Hiko White River Springfish & its clinging on in a certain pond in the allotment. These precious fish must be saved & to do so we must save & restore their uniquely suited habitat. With the major ongoing changes to life communities of all sorts that Global Warming is producing, it is imperative that the greatest variety of natural species be preserved, as some of these, even those heretofore rare in occurrence, could play crucial roles in restoring the integrity of the life community, permitting it/us all to adapt to the major ongoing changes all life is experiencing.
You have presented five alternatives: (1) proposed Cool Season Grazing; (2) Year-round Grazing; (3) Permittee Alternative; (4) No Action; & (5) No Grazing (of livestock), I strongly urge you to adopt (5) No Grazing. Given the extreme degradation to soils, water sources, vegetation & wildlife & the fact that most of the PTMA is also a wild horse HMA where the wild horses are scarcely present, in many places seeming to be totally absent, this choice would be the wise & fair one that would serve to curb the present excessive monopolization of habitat resources by livestock interests. No Grazing would allow for a much-needed restoration of the ecosystem here & justly implement a variety of other national laws that include NEPA, Endangered Species Act, Clean Water Act, Clean Air Act, Wilderness Act &, of course, the often overlooked Wild Free-Roaming Horses & Burros Act (WFHBA) itself. This choice would also be in tune with a higher, more ecological, public spirited interpretation of FLPMA of 1976 & PRIA of 1978.
Here are some additional important points I ask you to consider:
* The issuing of a 10-year grazing permit is very dangerous & could lead to an inflexible program of cattle grazing that would even more severely degrade the ecosystem.
* BLM’s proposed cancellation of the permit to run a mere dozen domestic horses, equivalent to 144 year-round AUMs seems unwise & unfair. The post-gastric-digesting horses actually balance & compensate for damaging effects of excessive ruminant-digesting herbivores, such as cattle, mule deer, pronghorn & bighorn sheep, species that are given preferred treatment because of unquestioned traditions. Horses actually compensate for depletion of soils & vegetation caused by these ruminants; a number of sound scientific studies prove this point. Here is the link to one important study: https://www.researchgate.net/publication/239848265_Facilitation_between_Bovids_and_Equids_in_an_African_Savanna
*The PTMA allotment fails on all five Resource Advisory Committee (RAC) Standards for Rangeland Health; an alarming 97% of assessed springs are not up to Properly Functioning Condition (PFC).
* The Proposed Alternative 1 includes the construction of 45 miles of pasture fencing to allow rotational grazing of cattle as well as to protect springs & implement existing range improvements. While the protection of springs & provision of troughs at their sides may be warranted, the large-scale creation of the fenced pastures would overly interfere with the free-roaming lifestyle & healthy seasonal movements/migrations of the wild horses, who have legal right to this area. For this reason, I oppose these large-scale fencings & recommend you give much more attention to the rights of the wild horses in this their legal area (see Section 2 [c] of the WFHBA); legally they should be given the principal resources, not marginalized within their own legal area! Choosing Alternative 5: No Grazing would allow you to truly & fairly implement the WFHBA for a change. In the process, you should restore the AML to a much higher & fairer level in order for it to be long-term viable. I recommend 2,500 horses to be viable in the long-term; this recommended by the IUCN SSC Equid Specialist Group (Equid Action Plan, 1992).
* I find it questionable how you focus only on 43 C.F.R. 4710.5 (b) in order to eliminate domestic horses from living here but ignore the 43 C.F.R. 4710.5 & 4710.6 statutes that would allow you to reduce/close the area to domestic cattle grazing in order to ensure a thriving & viable herd of wild horses in this their rightful, legal Pilot Mountain Herd Area/Herd Management Area! This is “pick-&-choose” application of the laws & regulations to favor ranchers.
* Page 11. ‘During livestock distribution monitoring flights between 2016 & 2018, the BLM consistently counted higher numbers of cattle than what was reported by the permittee (see Appendix B, Table 5 showing billed AUMs & cattle numbers). The lack of grazing management & summer grazing in excess of 150 head of cattle after 2014 has resulted in declining rangeland health conditions & has contributed to failure to maintain rangeland health standards.’ – These points give strong reasons for BLM to choose the Alternative 5: No Grazing. This would be fairest to all interests, e.g. the General Public on our lands.
* Page 11: “… Up to 16 original base waters may be determined not suitable for base water use or transfer to an alternative water source, and, as such, would no longer have any associated AUMs. This base water evaluation supports limiting the maximum AUMs …” – Again, this observation would further justify Alternative 5, No Grazing (of livestock).
* Pages 14-15. I support fencing the pond where the federally endangered Hiko White River Springfish lives, as well as providing troughs on the side of this pond for wild horses & other wildlife to drink. I recommend Buck-&-Pole long fencing as an effective barrier & also that the wild horses periodically be allowed to munch down cattails & bulrushes, etc., in order to open up the pond habitat & prevent it from being overgrown & filled in with sediment to the detriment of the endangered Springfish.
* Pages 15-16: Regarding Corral Springs, it is not right to merely lump livestock & wild horse impacts together when assigning responsibility for damages to this – or any – riparian habitat. These are separate species with distinctive lifestyles, physiologies & ecological relationships. The cattle tend much more to camp on riparian habitat; their ruminant digestive systems, lack of upper incisors, & sharp, pick-like, cloven hooves often produce more damage to & result in more desiccation of the wetland margins of springs, lakes & streams, & to/of these bodies of water themselves, when compared with naturally living horses. Wild horses usually do not linger, or “camp,” at spring, stream or lake sites as much as cattle – unless they are forced into doing so by fences & other unnatural restrictions! To merely lump the impacts of wild horses with those of cattle upon springs & other riparian habitats is grossly unfair & not in accord with scientific methodology & goals – nor with the law.
* Page 16: Concerning the visual quality of the Gabbs Wilderness Study Area: Yes, healthy springs, seasonal creeks & other riparian habitats are very important beautifiers of this area, as well as being of vital importance to myriad species. And I would like to add that the returned-North-America-native wild horses are greatly appreciated by most people for their natural beauty as well as for their fascinating & spirited behavior. They are harmonious with wilderness values, regardless of what wild horse detractors sometimes say. Wild horses benefit native wildlife & vegetation in many ways; they help build healthy, nutrient-rich, moisture-retaining soils, increase aquifers, or water tables, disperse intact seeds of a great variety & help them to germinate via their positive effect on soils. And these species include many natives. Horses also open up bushy thickets & vital water sources during both winter & summer, thus benefiting myriad, diverse organisms. Their wallows form natural catchments that aid many species of plants & animals, especially during critical dry seasons. I know of these benefits after many years of direct observation & study.
* Page 16. Cornelius Spring. This was rated Functional At Risk (FAR) in 2016 by means of a Proper Functioning Condition (PFC) assessment. I agree with fencing this to allow recovery & also with installing a spring box at the head, & provided with side piping & trough for wild horses & other wildlife to drink. Also, ladders in troughs & boxes would allow small animals to exit if become trapped in the water.
* Page 17. Footnote 1. “During a recent inspection in July 2019, BLM discovered that the water was diverted from both spring sources [Cornelius has two]; & all the water had been trenched away from the spring to a trough … [this] caused the wet meadows to almost completely dry up and wetland vegetation to die off …” –This deliberate & thoughtless manipulation of the spring & its water is another strong reason for BLM to choose Alternative 5: No Grazing (of livestock)!
*Pages 27 – 28: “BLM has billed the permittee for numbers in excess of the number of cattle authorized during the summer months and has also found discrepancies in the number of livestock reported /authorized and those actively grazing in the allotment [by means of] a livestock distribution compliance flight (Appendix B, Appendix A, Table 5).” – This page goes on to describe other serious violations of cattle grazing on public lands by the permittee, including failure to maintain range improvements & violation of Nevada state law regarding livestock’s year-round grazing pressure on riparian areas & springs, failure to rotate grazing & allow vegetative recovery, etc., again justifying Alt. 5: No Grazing.
* Page 29. Here is described the BLM field trip to PTMA of Nov. 16, 2018, in which I participated. Nearly all professionals were shocked by the amount of overgrazing, spring & riparian destruction by cattle, etc. I did not observe a single sign of any wild horses present in the allotment & for some time past, i.e. no old droppings or tracks in & around the several springs & livestock grazing areas we visited, even though all of these areas were within the Pilot Mountain Wild Horse HMA, as was confirmed to me by BLM Wild Horse & Burro Specialist John Axtell. The great majority of participants urged that livestock be greatly limited & prevented from doing further damage to the ecosystem. However, the grazing permittee & some of his associates were very defensive & the permittee himself was even rude & threatening at times. This again is a strong justification for BLM to choose Alternative 5: No Grazing. Cattle were clearly the preponderant cause of ecological deterioration – which was of serious degree & extent, especially notable in & around the springs we visited. … I appreciated this opportunity to meet those concerned with the area & to voice my concerns & propose remedies & solutions. This area had a special charm & some places were quite colorful & scenic; the cattle rancher should not be allowed to monopolize this area & to flaunt the laws protecting the native life community any longer.
* Page 30: On Table 12 regarding Supplemental Authorities, I am displeased to find the Wild Free-Roaming Horse & Burro Act excluded.
* Pages 32-33: Table 13. Concerning Global Climate Change & greater Greenhouse Gas, it is incorrect to ignore the large quantities & heat-trapping nature of the gases that cattle emit & their contribution to Global Warming. To ignore Methane emissions by livestock is a glaring omission! This insidious gas traps many times more heat from the sun than does Carbon Dioxide. Methane & other gases emitted by livestock constitute a serious threat to the future of precious Life on Earth! … Again, major reason for choosing Alternative 5: No Grazing.
* Pages 78 ff. Section 3.5.9: Wild Horse & Burro. The Pilot Mountain WH HMA has ca. 475,440 BLM acres & extends into the Dunlop [grazing] allotment of the Battle Mountain BLM District. Ca. 255,040 acres are under Carson City BLM District. 91% of HMA acres are within the PTMA (i.e. Holmgren); 5% in the Cedar Mountain Allotment & 4% in the Gillis Mountain Allotment. The wild horse AML was determined by the 1993 Final Multiple Use Decision to establish a range between a low of 249 [&] a high of 415 wild horses. This signifies that the mean number of wild horses equals 332, which corresponds to 1,432 acres, or 2.24 square miles, per individual wild horse. At the low end of 249, this is 1,909 acres, or 2.98 sq. mi, per individual horse, while at the high end of 415, this is 1,146, or 1.79 sq. mi., per individual horse. These allowances for the wild horses are extremely sparse & disobey Section 2 (c) of the WFHBA, which asserts that the wild horses & wild burros in their legal areas where they occurred in 1971 are to be given the principal resources. For this reason, it is the duty of BLM to increase the allowed wild horse population level of the Pilot Mountain HMA to a much fairer & more just level, one that honors the WFHBA, rather than makes of mockery of it! I suggest that 200 acres per individual wild horse as a fair standard in this semi-arid Great Basin desert. This would signify an AML of 2,377 wild horses & would be near the level for viability that is recommended by the IUCN SSC Equid Specialist Group: 2,500 individuals (Duncan, IUCN SSC Equid Spec. Group, 1992).
* Though it is noted in your document that within the PTMA portion of the wild horse HMA, there should be 302 horses, I observed neither wild horses nor any old spoor of such in our extensive field trip. The area covered represented a large transect of several miles within the PTMA on Nov. 16, 2018. I therefore suspect that the Pilot Mountain wild horses are being deliberately eliminated from a large portion of their legal HMA. During the field trip, I actively searched for them; & I am expert at detecting their presence, having observed them all of my life. I am a Nevada native stemming from pioneer stock & used to extensive forays into remote areas of my state.
* Concerning the 388 wild horses located outside the HMA & outside the PTMA on the Hawthorne Army Depot Lands, these were counted by BLM workers on May, 2017, to come up with a total of 581 horses (see App. B & App. A). This as an excellent opportunity for BLM to establish a Cooperative Agreement with the U.S. Army, as well as the Town of Hawthorne & other interested parties. This would be legally justified by Sections 4 & 6 of the WFHBA & would secure adequate habitat for a truly viable & thriving wild horse population. This would be a positive & proactive action by BLM on behalf of the wild horses & the General Public’s great support of & interest in them for a change! The area is very scenic, with Walker Lake & Grant Mountain providing a picturesque backdrop — & the whole scene is greatly enhanced by the beautiful & spirited wild horses! As indicated earlier, mustangs enhance ecosystem that are appropriate to them, contributing greatly to improved soils because of their addition of humus; & humus improves the moisture-retaining capacity of soils. Again, horses also contribute by dispersing a great variety of vital seeds, for which their droppings create well fertilized germination beds. And they munch down excessive vegetation that becomes flammable during drier times of the year. They can even munch this down after it has become fairly dry & without overtaxing their metabolism, as would many multi-stomach, ruminant-digesting herbivores. In this way they also greatly mitigate/prevent catastrophic wildfires. The latter pose a great threat to life today because of Global Warming.
* Page 80 ff.: Continued Range Improvements. I suggest BLM construct one or more natural habitat (including soil & vegetation) Overpass(es) over Highway 361 to accommodate the natural movements & seasonal migrations of the wild horses & other wildlife species, if fences must be build due to threats from traffic to the animals & people. This would involve populations of many diverse yet always interrelated species. The Overpass(es) would prevent the fragmentation & inbreeding with each species The Overpass(es) would help keep the wild horse population here at a genetically viable level & allow for natural rest rotation of foraging pressure by horses, deer, pronghorn, bighorn & other herbivores.
* Section 3.5.10: Concerning the non-native invasive plants, like thistle, cheat grass, etc., wild horses could help eliminate many of these by eating them before they reproduce, or “set seed.”
* Page 83, Section 3.5.11: Socio-economic. Based on the figures given, e.g. 0.2 / 0.5 additional jobs, the cattle grazing on these public lands really does very little for the local economy. I suggest a more substantial wild horse population & more emphasis on restoring the natural ecosystem as mutually complementing goals. This would greatly contribute to the local economy, since many people both in our country & worldwide love to observe the naturally living horses & the natural world they inhabit as returned, community-enhancing natives. This is a great opportunity, if people would view these returned natives positively instead of negatively & give them a chance. For they are great healers & restorers of ecosystems, as well as harmonizers & up-lifters of the spirit of all life. We humans should learn to share the land & freedom with these great paragons of the animal kingdom. They have done so much for us humans over the centuries. Now isn’t it high time we do something truly good for them … like letting them be themselves & have the sufficient space & appropriate habitat wherein to do so? Humans would be taking a giant leap forward for humanity in so doing!
* Page 85, Section 3.5.12.2, Environmental Consequences of WSA’s: Here I object to BLM’s pusillanimous cow-towing to the livestock interests in these Wilderness Study Areas. Wilderness is supposed to be for naturally living plants & animals & for people to enjoy without destroying — not just another pasture for livestock, who never are allowed to naturally integrate to any great extent, but are abruptly removed to be fattened then consumed by people! To merely perpetuate livestock within areas that could become wilderness is contrary to the true &core purpose of The Wilderness Act!
* Page 97. Section 3.5.13.2.6. I object to the lack of thoroughness in the analysis of wild horse population dynamics. Remember that reproductive rate is not the same as population growth rate, aka recruitment. Often 50% or even much more of the newborn foals are killed or otherwise perish before reaching one year of age. Also, adult mortality is often 5% to 10% or even much more & that this must be taken into consideration for an accurate assessment of what is happening. Also we should recognize that the mustangs’ social units, or bands, naturally self-limit herd size & that busting these up through draconian roundups, usually by helicopter, seriously disrupts the natural stability of a wild horse population. And these roundups also set way back the generations-old adaptations to the particular ecosystems where the mustangs live. Such positive adaptation is what the WFHBA means when it says to allow the wild horses & wild burros to become natural integral parts of the public lands ecosystem. Please consider these points. They are of paramount importance.

–More detailed information & analysis should have been presented concerning the Pilot Mountain & vicinity wild horses. I come away from your DEA with the conclusion that these protected “national heritage species” really don’t matter much to you & that neither does the great & continually demonstrated public interest in & concern for them. To me this is an unacceptable situation, but one that should & could easily change. Public officials must not merely buckle under because of the outrageous demands of selfish & narrow-minded individuals. Their shallow goal is to monopolize the public lands; & this would only create an unwholesome situation for all concerned, one that would only lead to disaster. Wild horses, Wilderness, Restored Endangered Species, etc. – these are very important Quality of Life concerns to which we should all awaken, even those who presently wear the same-old blinders that their narrow vested interests have created. Americans of all stripes & backgrounds must rise up & insist that the wild horses of Pilot Mountain & elsewhere be restored & treated to their true & rightful lands & justified adjacent areas so that they can enjoy long-term-viable habitats that correspond to complete & long-term-viable populations. For in the ultimate analysis, their rights equal all of our rights, & if they lose out, so would we all.
Sincerely,

Craig C. Downer, Wildlife Ecologist
Wild Horse & Burro Fund / Andean Tapir Fund
P.O. Box 456, Minden, NV 89423.
P.S. I would appreciate your response to all of the above points. CC: Various interested parties. Links:
https://www.nevadaappeal.com/news/local/candidates-accused-of-overgrazing-blm-land/
https://www.oha.doi.gov/IBLA/Ibladecisions/175IBLA/175IBLA321.pdf